Building with federal funds: What’s eligible?

The Bipartisan Infrastructure Law (BIL), passed in late 2021, has opened up new opportunities for airports wanting to construct buildings. Over the last 20 years, the federal funding most general aviation (GA) facilities received—through the Airport Improvement Program (AIP)—has focused on maintaining existing pavement infrastructure and acquiring maintenance equipment. By receiving almost double the amount of federal funding for fiscal years 2022–2026, airport sponsors can shift their focus to airport buildings—something long overdue. 

Buildings that can be constructed with federal funds at a GA airport include snow removal equipment (SRE) buildings that house federally funded SRE, terminals or arrival/departure (A/D) buildings, T-hangars, and transient storage hangars. These buildings are eligible for funding from the FAA at a 90 percent share of the project costs; however, when preparing the Capital Improvement Plan (CIP), airport sponsors should understand that the eligibility of items within these buildings may not be the same. And airports should expect the local share to be greater than the typical 5 to 10 percent because of the eligibility review. Based on the final determination of items eligible within each building, the FAA will develop a proration for federal funding.

This article will explain which common items are eligible and which are not when planning for construction of a building at your airport. You can use this information when preparing your CIP and when discussing airport building projects with your airport board, airport commission, city council, county board, or other governmental agency responsible for providing local funding for improvements at the airport. 

The best guidance available on eligibility of building items is the FAA Airport Improvement Program (AIP) Handbook, Order 5100.38D, Change 1. Another resource is your FAA program manager. You should involve them in the CIP preparation and design process as soon as possible to manage expectations and keep the FAA aware of the project’s funding status. 

General considerations

Prior to proceeding with planning for a building project, you should consider the following parameters: 

• The project must be shown on an approved airport layout plan.
• To use federal funding for a building, no pavement maintenance grants can be requested for the next three years at the airport. The pavement must be in acceptable condition.
• The useful life of a building constructed with federal funding is 40 years. 
• All building projects will need an environmental review prior to construction. Most environmental reviews can be completed through a categorical exclusion (CATEX). Field work may be necessary to determine wetland boundaries or cultural resource areas. 
• A Form FAA 7460-1, Notice of Proposed Construction or Alteration (also known as an airspace analysis), must be filed to evaluate the location and height of the building in comparison to the airspace at the airport. 
• FAA Buy American preference requirements (49 U.S.C. § 50101) apply to construction of a new building at an airport.

SRE buildings

The purpose of an SRE building is to protect the federally funded SRE at the airport. For GA airports eligible for only one snow removal carrier vehicle, or airports that are not Part 139 certified, FAA policy specifies a maximum eligible size for an SRE building at 1,600 square feet (typically 40 feet wide by 40 feet deep). This is important, because some airports’ existing SRE facilities, previously constructed without federal funding assistance, are larger and house other equipment or workspace. The FAA will only fund the area necessary to accommodate the federally eligible SRE. At the time the building is programmed for federal funding, the eligible SRE must be owned, on order, or budgeted by the airport sponsor within the next five years. Once the airport sponsor has decided to move forward with construction of an SRE building, they should schedule a kickoff meeting with the design team followed by a kickoff meeting with the FAA program manager to share project details and determine eligibility.

Terminal or A/D buildings

A terminal building, also known as an A/D building, is a public-use facility that passengers may need to occupy as part of their air travel. Most A/D buildings were constructed when the state’s airports first opened prior to 1970. No updating, remodeling, or changes have been made to the these buildings because of funding shortages. Most remodeling or upgrades to an A/D building are ineligible for federal funding. Communities sometimes reach out to the state department of transportation to help fund those projects, such as roof and window replacement, flooring repairs, or updates to the bathroom facilities. 

Work with your FAA program manager when considering the eligibility of a new A/D building, including the components inside the building. Also ask, “Is the space or item essential for pilots and passengers using the building?”

Hangars

Construction of airport-owned hangars that will increase the revenue-producing ability of the airport are eligible for federal funding. These facilities include T-hangars, transient storage hangars, ranch hangars, or box hangars. Another requirement: A hangar facility must only be used for aeronautical purposes; non-aeronautical use is prohibited. 

Pavement in front of the hangars, such as the apron, is eligible but cannot be used for public parking or for aircraft taxiing, including the wingtip clearance from the building. Taxilanes serving the hangars are also eligible. 

The FAA may request additional planning prior to constructing a new taxilane or hangar. As airport sponsors gather waiting lists of pilots wanting to occupy hangar space at an airport, those on the waiting list may move on or find other hangar options if too much time passes before hangar space becomes available. Once a hangar project is ready for funding consideration, the airport sponsor should revisit the hangar waiting list to determine if the interest is still relevant. Collecting the first month’s rent or another form of payment may be necessary to document the seriousness of future occupants. Completing this documentation before applying for a federal grant will be vital for the project to proceed. 

Going forward

While hangar space and building upgrades are a high priority at GA airports across the country, the funding has until recently been focused on pavement maintenance and equipment needs. With the passage of the BIL, airport sponsors have an opportunity to explore additional projects to meet deferred needs. Reacquainting yourself with the eligibility of airport buildings can help tailor the appropriate discussions with the decision makers in your community. 

­— Melissa Underwood is a senior aviation planner with SEH.