Airport Improvement Program Grant Assurances; Proposed Modifications and Opportunity to Comment

EAA strongly disagrees with comments submitted by the American Association of Airport Executives (AAAE) - FAA-2004-18925-8. In their coments to this docket, page 2, Proposed Grant Assurances C-9, Airport Revenue Use, AAAE urges the FAA to allow airports to use airport revenues to provide direct subsidies to commercial air carriers. AAAE sites two primary reasons why airport revenues are needed for this purpose - the need to create a more competitive environment between all air carriers and to attract additional air carriers to airports. EAA feels that if the FAA granted this request, it would create additional economic discrimination at all airports. Without expanding this request to include providing direct subsidies to all general aviation aeronautical activities - FBO's, SASO's, and private individuals who build personal hangers on airports, a severe economic imbalance would be created as airport revenues would be allowed to fund only one select aeronautical activity at the direct expense of all others. Grants of Assurances were created to prevent this suggested type of economic discrimination on airports. EAA strongly urges the FAA protect all aeronautical users by rejecting this argument. Randy Hansen EAA Government Relations Director

November 5, 2004 Federal Aviation Administration Airports Financial Assistance Division, APP-500 Attn: Mr. Kenneth Ball, Room 619 800 Independence Ave., SW Washington, DC 20591 Dear Mr. Ball: Reference: DOT/FAA Docket No. FAA-2004-18925, Airport Improvement Program Grant Assurances; Proposed Modifications and Opportunity to Comment. EAA (Experimental Aircraft Association) is the world leader in recreational aviation. With an international membership of 171,000 people in more than 100 nations, EAA brings together aviation enthusiasts, pilots and aircraft owners who are dedicated to the continued growth of aviation, the preservation of its history and a commitment to aviation's future. EAA programs, activities and events are known throughout the world for supporting aviation safety and promoting personal enjoyment and responsibility within an aviation lifestyle. These efforts are made possible through massive volunteer involvement in support of the organization, as well as EAA's special interest Divisions, and a global network of nearly 1,000 local Chapters and the affiliated National Association of Flight Instructors (NAFI). EAA has reviewed the proposed revision to the FAA Grants of Assurances and does not have specific comments for improvement. However, in the interest of National Security EAA strongly recommends the following note be added to paragraph C 17, Hanger Construction, when these revised Grants of Assurances are incorporated into FAA Order 5100.30, Appendix 1: "NOTE: The Department of Homeland Security (DHS) has determined that the storage in hangers is one of the most effective methods of securing General Aviation (GA) aircraft from the national security threats facing America. The FAA endorses this security finding and encourages airport sponsors to plan for sufficient hanger construction to meet GA user demands in future Airport Master Plans. TSA Information Publication A-001, May 2004, Security Guidelines for General Aviation Airports." Sincerely, /S/ Randy Hansen EAA Government Relations Director

On Friday September 17, 2004, the FAA extended to deadline for submitting comments to this docket, FAA-2004-19825, to November 8, 2004. This extension was based on "multiple" early public comments. Since that date, only three comments have been added to the public docket, including EAA's (11/5/2004). EAA feels that it is highly possible the FAA has received other comments to this docket that have not been added to this public viewing site. This is because the docket requires the public to respond directly to FAA Airports Division, APP-500 - not to the DOT Docket office. EAA requests that if the FAA Airports Division (APP-500) has received comments to this modification of Airport Improvement Program Grant of Assurances, that have not been posted to this public viewing site (the DOT docket), that they do so prior to the end of the public comment period. This is the only way for the public to be fully informed of the actions the FAA might take in finalizing this modification document. Randy Hansen EAA Government Relations Director