AOPA, along with the Arizona Pilots Association (APA) and the Aviation Safety Advisory Group of Arizona (ASAG), submitted comments to the FAA pushing back on the city of Mesa’s defense of its financial methodology and rationale behind the implementation of landing fees at Falcon Field. The filing comes as part of the FAA’s ongoing review of FAR Part 13 complaints challenging the city’s landing fee program.
To date, four Part 13 complaints have been filed by tenants and users of Falcon Field , alleging that the city has violated federal grant assurances, relied on a flawed financial methodology, and placed an unnecessary burden on local flight schools. The complaints also allege that the city’s landing fee program is, in part, a surreptitious attempt to reduce air traffic and noise complaints, which the FAA prohibits.
The city directed its outside legal counsel, Anderson & Kreiger, to pursue an "independent” audit of the airport’s financial data and the methodology used to calculate the fees. In response to the FAA, the city maintains that it conducted a thorough financial review to justify the fees before approving them in March and met its obligations to engage airport users through meetings and other outreach.
In their July 30 reply to the city’s defense, Falcon Field-based flight schools CAE Aviation Academy and Thrust Flight characterized the fee program as a “façade” intended to force flight schools to leave the airport, and that the fees disproportionately burden flight training. They argued that the city’s 90-day pause to reevaluate its data and new cost center allocation model “suggest that the city adopted the landing-fee structure before completing the analysis necessary to confirm that the fees are reasonable, transparent, and not unjustly discriminatory.” Their response also expressed concerns regarding regional airspace safety.
In their detailed rebuttal of the city's defense submitted August 7, the aviation groups highlighted several issues with the city’s financial methodology and stakeholder engagement efforts, while also questioning the underlying motivation behind the landing fees.
The letter argues that the city failed to determine whether landing fees were “necessary, reasonable, and not unjustly discriminatory” before adopting them, pointing to concerns with recently developed airport cost centers, a lack of explanation for why FAA funding was not considered for future projects, and the city’s own acknowledgment that flight training operations do not significantly affect pavement costs.
“This failure suggests that the City’s motivation to impose those fees was, at least in part, to limit flight training operations and reduce noise complaints,” the groups wrote.The letter also pushed back on the city’s claim that potential safety and airspace impacts from landing fees are “speculative,” arguing that the traffic displaced by landing fees at Falcon Field will not simply disappear, it will move.
Falcon Field sees roughly 300,000 operations per year, including 231,000 small-aircraft landings in 2025, and about half of all operations are related to flight training, making the airport one of the five busiest general aviation airports in the country.
“Forcing a significant portion of that traffic volume into neighboring traffic patterns in already congested Phoenix-area airspace is a foreseeable operational consequence of the fees, not conjecture, and it is the concern Director Helvey identified on April 13, 2026, writing that ‘the City’s unusual landing fee structure has the potential for systemwide impacts’ and could ‘jeopardize or disrupt the Acceptable Level of Safety under which operations are now conducted.’ The City’s refusal to acknowledge this clear issue is concerning.”
AOPA has been engaged on the Falcon Field issue since the fee proposal emerged in late 2025. Before the vote, AOPA joined APA and ASAG in two letters to the city council—on March 4 and March 20—questioning the city’s financial methodology and requesting a six-month delay to allow for a transparent review of the airport’s financial needs; those requests went unanswered.
AOPA also submitted written testimony to city and airport officials and raised the issue directly with the FAA. The agency acknowledged AOPA’s concerns and indicated that a Part 13 or Part 16 complaint would be the appropriate path forward.
The letter warns that Mesa’s actions could have national implications for the GA community: “This matter arises against a national pattern of airport sponsors turning to landing fees at federally obligated airports in response to community noise concerns, often without understanding that grant assurances constrain how and why such fees may be imposed. The FAA's determination here is an opportunity to make those obligations clear, not only to the City, but to every other airport sponsor.”