Regulatory Compliance Costs and the Impact on Small Airports Findings of ACRP Report 90 and Application to [INSERT NAME OF AIRPORT]

Issues Small airports face increasing regulation Compliance adds costs to [INSERT AIRPORT NAME] Compliance adds substantial industry costs Small airports have limited means to raise revenue Federal funding is shrinking Compliance reduces funds available for revenue- generating services and facilities “One-size-fits-all” standards result in extra costs on small commercial airports Options to reduce compliance costs 1

Small commercial airports face increasing regulatory requirements 291 requirements adopted from 2000 to 2010 Equivalent of one new requirement every two weeks Requirements continue to grow COMPLIANCE ACTIONS ADOPTED IN

Compliance Adds Costs to [INSERT AIRPORT NAME] Compliance Costs for [INSERT AIRPORT NAME] FAA/DOT Requirements Environmental Requirements Security Requirements OSHA Requirements Total Compliance Costs 3

Most Costly Requirements for [INSERT AIRPORT NAME] Requirements with Highest Initial Cost Requirement$$$$$$$$$ 4

Most Costly Requirements for [INSERT AIRPORT NAME] Requirements with Highest Recurring Cost Requirement$$$$$$$$$ 5

Compliance Results in Substantial Aggregate Industry Costs Total Small Airport Industry Costs FAA/DOT Requirements$1,459,500,000 Environmental Requirements$90,200,000 Security Requirements$610,800,000 OSHA Requirements$11,700,000 Total Compliance Costs$2,172,200,000 6

Most Costly Requirements for the Small Airport Industry Requirements with Highest Industry Initial Cost (Before Deducting Federal Funds) RSA Requirements (FAA)$695,166,000 “Any other” Equipment or Systems for Access Control (Security)$265,608,000 Perimeter Fencing for Security (FAA)$146,982,000 Perimeter Fencing for Wildlife Hazards (FAA)$138,296,000 Physical Access Systems (Security)$130,122,000 7

Most Costly Requirements for the Small Airport Industry Requirements with Highest Industry Recurring Cost (Before Deducting Federal Funds) Vehicles in AOA, Enforcement & Control (FAA)$29,191,000 Vehicles in AOA, Emergency Operations (FAA)$12,229,000 Use of GIS Techniques (FAA)$5,642,000 ARFF Requirements, Newly Certificated Airports (FAA)$3,278,000 Vehicles in AOA, Vehicle Access (FAA)$3,040,000 8

Federal Funding is Shrinking AIP and PFC funds are available only for capital projects – Most recurring costs are administrative or operational and do not qualify for these funds AIP funding remained level at $3.5 billion from FY 2008 to FY 2011 and declined starting in FY 2012 The federal AIP share decreased from 95% to 90% for small airports in recent legislation The PFC cap has not increased since

Compliance Costs Take Resources Away from Revenue- Generating Development and Operations Grant funds, PFCs and other airport revenue used to pay for compliance requirements cannot be spent on projects Example – [TO BE COMPLETED BY AIRPORT] 10

Compliance Costs Take Resources Away from Revenue- Generating Development and Operations Limited budgets force small airports to use existing staff to comply with requirements—taking time away from running the airport and providing service to the public. Example – [TO BE COMPLETED BY AIRPORT] 11

“One-Size-Fits-All” Compliance Standards Result in Disproportionate Costs to Small Airports More cases of the FAA adopting uniform requirements for all size categories of airports – Standards usually based on characteristics of large airports – Standards may be excessive to needs of small commercial airports and their users A $500,000 requirement costs San Antonio Airport 7.5 ¢ per passenger. It costs [INSERT AIRPORT NAME] $[INSERT AMOUNT] per passenger Agency estimates of compliance costs (when made) are often below actual impacts 12

Options to Reduce Future Cost Impacts Increased participation by small airports in notice and comment rulemaking to provide better cost information Increased participation by small airports when agencies publish draft policy and guidance documents for comment Other potential options: – Are outside the control of airports – Would require action by government agencies and regulators (and thus were outside the scope of the research) 13