FAA Voluntary Compliance approach should compel Airport Audit to prevent Serious Loss of Trust

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ARTICLE: FAA wants progress reports from Fayette airport authority


The Fayette County Airport Authority has run afoul of the FAA. Some of the problems involve

· allowing airport facilities to be used for non-aeronautical purposes;

· permitting tenants in hangars without a lease

· not charging fair market value for the hangar use; and

· failure to install fencing between the airport’s taxiways.

The article intimates that the FAA may have found other deficiencies which have already been corrected. The County Solicitor and the Airport Manager have committed to providing “progress reports” to the Airport District Office.

What the article does not convey is how truly serious this breach is. The quintessential premise of the FAA’s regulatory oversight is VOLUNTARY COMPLIANCE. There are not enough inspectors for the FAA to surveil 100% of the airports within its jurisdiction. They must rely on (or even “trust”) the regulated to comply with all of the rules.

If the basic relationship is breeched, there are serious, real consequences. Whereas the FAA in the past assumed that the airport was doing its job, post such a fault finding, the presumption shifts to a negative perspective. The investigators look for failures and when they find a close question, they shade their interpretation towards a violation.

The best way to compound that fracture is to promise to fix “Problem #1” by Day X and fail to do so. The tight rein will then become a choke collar. Once in the reaction/fix mode, all representations by the regulated to the regulator must be made with certainty of their timely, complete compliance.

Best practice would be for an airport, even a small KWS, to bring in a 3rd party audit team. The dollars required to engage in such a preventative safety review are much smaller than the remedial costs expended once a violation has been found (what does it cost the County to have its Solicitor to track the progress of a fence installation?).

If that rational does not work with the Airport’s Board and/or City Manager, it might be wise to work with other small airports in the area and establish a collaborative effort among similarly situated facilities in an area. Getting the new set of eyes of another airport professional’s review may save an airport a continuously difficult relationship with your ADO and a painful bit of press exposure.

Your relationship with your FAA team is the single most important asset of your airport. Yes, those buildings and runways show up on your financials as very expensive capital expenditures, but they are worthless if the FAA suspends or revokes your authority to operate.

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