08/26/05 Gates/Airport Standards ReviewJames Patrick
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Assurances 3-05
New.doc (152 K-
Fred -
Gary.Gates@faa.gov
Friday, August 26, 2005 9:24 AM
leistiko@digisys.net
James Patrick; Dave.Stelling@faa.gov; Joelle.Briggs@faa.gov; Asher.Bray@faa.gov;
dalke@state.mt.us
Kalispell City Airport Standards review
Assurances 3-05 New.doc; 5190-5a1.pdf
5190-5al.pdf(194
KB)
We have reviewed the Kalispell City Airport Minimum Standards and Rules and Regulations
Documents that were received by our office on July 18, 2005.
We commend the effort in creating these standards and in working to assure that the
airport owner will be able to maintain grant assurances that will be in affect at the time
we issue a development grant, following removal of the radio towers south of the airport.
Currently the airport is not obligated to carry out the assurances associated with the
Airport Improvement Program until such time that the FAA issues and the City accepts a
federal grant for development. We offer the following advisory comments in anticipation
of the airport becoming an obligated airport.
Regarding Minimum Standard Requirements for Providing Airport Services:
Regarding insurance coverage requirements, if not already done, there should be some
analysis to establish market rates that are reasonable for similar types of aeronautical
coverage.
Regarding Self Fueling, may want to designate a place on the airport for self fueling that
meets the fire codes etc, e.g. public ramp area etc. See AC 150/5190-5 for further
guidance on self fueling.
There is nothing that I could find that addresses "Through the Fence access" other than
the definition (page 8). It should be mentioned somewhere that this type of access will
not be permitted. The prior master plan identified a number of existing through the fence
access issues.
Section 3, references standards for FBO's. This section indicates that infrastructure for
only (1) FBO will be provided based on findings from the master plan and if a new entrant
could demonstrate sales exceeding a certain amount. This may be contrary to providing
fair competitive practices and against the requirements of preventing an "Exclusive
Right"
Agreement. The airport may need to provide space for an FBO if land is available and the
airport may have to provide infrastructure such as ramp space consistent with what has
been provided to other businesses on the airport. There should be space reserved near the
aircraft apron for more than one FBO. Airports with similar activity such as Laurel and
Hamilton both have a several FBO's that operate on their airports. Appendix A (ALP) shows
a location for (1) FBO, it appears that a second location could be accommodated near the
"north apron" as well. Section 1. of AC 150/5190-5 (see attached) provides further
background on examples of exclusive rights and provides good guidance on Exclusive Rights
and guidelines for Minimum standards. The following website includes a link to this AC
and Compliance Order 5190.6A:
http://www.faa.gov/arp/compliance/
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Regarding FBO requirements, the 10,000 square feet seems excessive as a minimum
requirement for floor space for aircraft storage plus 5,000 square feet for office etc.
Does the ALP show areas that would accommodate at least two locations capable of
supporting the area required? Seems as though there are a number of FBO's in our state
that have significantly smaller lease spaces (I don't have data to back this up).
Section 5, references the need of a Business Applicant to conform to the approved ALP. As
discussed previously, we should have the Airport's current ALP, since it has changed from
the last that was approved. This will ensure that we do not have any conflicts with
future development and design standards as well as grant assurances. Additionally, any
building that is proposed on the airport would need to be reviewed by our office through
FAA form 7460-1 (this is mentioned in the Rules and Regulations, chapt 4). This section
should be revised to include that all construction proposals summarized through form 7460,
is reviewed by Airport Owner and then submitted to FAA for review and airspace
determination. Attached is the website for form 7460 and instructions.
http://www.faa.gov/arp/anm/publications/Forms/
Section 8, Aircraft and ultra light rental specifies that business hours be
7 days a week, vs. 5 and 6 days required by other commercial operations, is this
customary?
Section 11, Fueling services etc. references lease space requirements. The section says
that provider of fuel must be FBO and states that 40,000 sf of space required, however
section 3, defining requirements for FBO requires 30,000. Why the difference?
Section 17, references building construction criteria; as established by the City of
Kalispell. This section should also reference 7460 process and FAA aeronautical review.
Section 18, references crop dusting, spraying etc. Is there a location on the airport
that is designated for chemical wash down and containment.
This could be an environmental liability for the city if not adequately addressed.
Regarding the City Airport Rules and Regulations, we offer the following
comments:
Introduction states, Two of the assurances given by the airport in exhange for Federal
Funding etc. is that they will establish Rules and Regulation and Minimum Standards. I am
not aware of any assurances that specifically require this? (see attached grant
assurances that are currently in effect for obligated airports)
Section 200.4 refers to Aircraft Maintenance, does this apply to self maintenance as well?
Section 300.2, references construction requirements. May want to include
website and that the city or airport manager review building proposals and provide
location sketch from ALP prior to sending to FAA for review.
Section 600.1 references environmental practices. See previous comment regarding wash
down areas for crop spraying.
(See attached file: Assurances 3-05 New.doc)(See attached file:
5190-5al.pdf)
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