Tagletter(154)

The Port of Seattle submitted comments to the FAA in April 2023 regarding proposed rules for airport air carrier incentive programs, arguing that airports should have broad flexibility to design their own incentive programs rather than follow a rigid list of prohibited practices. Seattle-Tacoma International Airport (SEA), which has run a New Air Service Incentive Program for over 15 years, raised concerns about a blanket ban on transferring funds to carriers, arguing that reimbursing carriers for pre-approved marketing activities should not be considered a prohibited subsidy. The Port also sought clarification on eligibility rules for competitive services and the 30-day public notice requirement for incentive agreements.

The Port of Seattle issued a March 2023 notice requiring all ground transportation operators at Seattle-Tacoma International Airport to sign and submit renewed operating agreements by April 28, 2023. Operators can submit agreements by email, mail, or in person at the Ground Transportation Office on the third floor of the airport parking garage. Required documents vary by operator type—such as airporters, charter buses, crew vans, and limousines—but generally include a signed agreement, proof of insurance, vehicle registrations, and a company information form.

The Huntsville-Madison County Airport Authority submitted comments to the FAA in October 2022, objecting to a proposed federal policy governing land use changes on federally acquired or conveyed airport property. The authority argues the policy creates unnecessary regulatory burdens that hamper airports' ability to pursue compatible non-aeronautical developments, and calls for clearer, simpler rules — such as broader definitions of 'airport purpose' and airport-led category determinations rather than FAA approval for every land use change.

Charlotte Douglas International Airport (CLT) submitted comments to the FAA in October 2022 opposing a proposed new policy on land use changes at federally acquired airport land, arguing that existing regulations already adequately govern non-aeronautical land use. CLT requested that if the policy moves forward, the FAA clarify approval timelines, lease evaluation procedures, and criteria for mixed-use land decisions. The letter emphasizes that non-aeronautical development is essential for airports to remain financially self-sustaining and to ensure compatible land use around airport property.

Airports Council International-North America (ACI-NA) submitted comments to the FAA in October 2022 opposing a draft policy that would impose new federal review and approval processes on how airports can use land that was federally acquired or conveyed. ACI-NA argued the policy is confusing, could lead to inconsistent decisions across FAA regional offices, and may delay airport development projects and increase costs. The organization urged the FAA to grandfather existing land use designations, clarify key undefined terms, and work collaboratively with airports to revise the policy.

The National Association of State Aviation Officials (NASAO) submitted comments to the FAA in October 2022 regarding a draft policy on land use changes at federally acquired or conveyed airport land. NASAO raised concerns about lengthy lease review processes, the lack of defined timelines for approvals, and unclear procedures for lease renewals and extensions. The letter also questioned how the policy would affect existing leases and called for greater consistency across FAA regions.

The American Association of Airport Executives (AAAE) submitted formal comments in October 2022 opposing a proposed FAA policy that would require federal review of individual leases, subleases, and non-aeronautical development projects on federally acquired or conveyed airport land. AAAE argues the policy would reduce airport revenue, slow development, and exceed FAA's appropriate role, which should be limited to aviation safety oversight rather than involvement in specific real estate transactions. The organization urges FAA to maintain existing policies and work collaboratively with the airport industry on any needed improvements.