January 5, 2003
Docket Management System
U.S. Department of Transportation
Room Plaza 401
400 Seventh St. S.W.
Washington, DC 20590-0001
Re: FAA Docket FAA-2003-16227, Policy and Procedures Concerning the Use of Airport Revenue: Petition of Sarasota-Manatee Airport Authority To Allow Use of Airport Revenue for Direct Subsidy of Air Carrier Operations
The Aircraft Owners and Pilots Association (AOPA) represents the general aviation interests of over 400,000 members nationwide. AOPA is committed to ensuring the future viability and development of airports and their facilities on behalf of our membership.
AOPA is strongly opposed to the petition to amend the FAA's current revenue use policy to allow an airport operator to use airport revenue for the direct subsidy of commercial air carrier operations. Such a change in policy would have a detrimental impact on financing airport improvement projects, cause financial harm to the existing general aviation tenants at the airport, and use revenues in a manner that is inappropriate for the broader interest of the aviation community.
The safety and utility of our national air transportation system relies on the ability of an airport sponsor to maintain an airport in a safe and serviceable condition. Despite advances in Airport Improvement Program (AIP) funding, an airport sponsor remains responsible for funding airport projects. Using airport revenue to subsidize airline service would take away from an airport's ability to fund airport improvement projects. In addition, the community pressure to attract airline service could cause some airport operators to prioritize funding for airline subsidies, rather than fund airport projects.
Airport businesses, tenants, and users contribute to an airport's revenue through fees, rates, and charges. In turn this airport revenue is used to maintain and enhance that airport. We note that eligible airports in this petition have a large general aviation presence. For example, Sarasota Bradenton International Airport has more than 270 based single-engine and multi-engine aircraft with nearly 145,000 annual general aviation operations. These general aviation users contribute to airport revenue through fees and charges. Using revenue collected from these general aviation users to benefit the financial well-being of a commercial airline would be discriminatory and should not be allowed.
Allowing airport sponsors to use airport revenue to subsidize airline services is not a practice that should be permitted by the FAA. Several comments suggest changes to the petition that would allow more airports to participate. For example, comments to the docket from the city of Fresno state that they do not agree that only "airport sponsors governed by a special-purpose airport authority be the limited beneficiary of a contemplated change" to the policy. In addition, the Grand Forks Regional Airport Authority believes the subsidy should not be limited to communities of 200,000 or more population and that the subsidy time period should be increased to 24 months rather than the proposed 12 months. These comments indicate the problems the FAA will have in preventing wide-scale changes in the revenue policy. The pressure and expectations air carriers will place on an airport to receive such subsidies will cause competition to be based on the amount of subsidy rather than marketability. Programs such as Essential Air Service are already in place to address the commercial air service needs in small markets.
Finally, we note that comments submitted to the docket by both the Sarasota Chamber of Commerce and the Manatee Chamber of Commerce quote a 1997 study that shows a 10 percent increase in passenger traffic at SRQ would increase visitor expenditures, jobs, payroll, and total output. These figures indicate to us that the communities financial benefit of increased airline service warrant the expenditure of community-wide funds, not simply airport revenue.
AOPA strongly believes that in order to maintain our national airport system and to protect the financial interest of general aviation tenants at commercial service airports, the FAA should deny this petition.
Andrew V. Cebula
Senior Vice President
Government and Technical Affairs