Regulatory Compliance Costs and
the Impact on Small Airports
Findings of ACRP Report 90 and
Application to
[INSERT NAME OF AIRPORT]
Issues
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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 revenuegenerating 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 2000-10
Regulatory Area
FAA/DOT
Environmental
Security
Occupational
Safety/Health
GRAND TOTAL
Compliance Action Count
150
39
81
21
291
2
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
Environmental Requirements
Security Requirements
OSHA Requirements
Total Compliance Costs
$1,459,500,000
$90,200,000
$610,800,000
$11,700,000
$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 2001
9
Compliance Costs Take Resources Away from RevenueGenerating 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 RevenueGenerating 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