Airport Improvement Program (AIP) Project Eligibility and Justification

If your airport is like most airports in the country, you are usually in the process of making improvements to your airport and need FAA AIP grants to make those projects happen. To obtain those AIP funds, you need to start the process by understanding project eligibility and justification. Note that there are multiple other requirements your project will have to meet, but if you are proposing a project that isn’t eligible or not justified…well, you’ll need to break open the airport’s piggybank and pay for it yourself.

The first thing we must understand is that the AIP law is permissive; if the statute doesn’t provide authority to fund a project, then it cannot be funded under AIP. Although this concept is fairly basic, it is not always crystal clear which projects are eligible and justified. What do we mean when we say project eligibility and justification? Having an eligible project means the FAA is authorized to fund an action or item by law. Having a justified project means the FAA has made a determination that the action or item is really needed at the airport. Guidance is provided through FAA Order 5100.38D, Airport Improvement Program Handbook, also known within the industry as “The AIP Bible”. This order provides guidance and sets forth policy and procedures for AIP based on current laws. It is important that airport sponsors have a reasonable understanding of the order when pursuing AIP grants.

Let’s take a little closer look into project eligibility. There are five general project types that may be funded with AIP: 1) Airport Planning, 2) Airport Development, 3) Noise Compatibility Planning, 4) Noise Compatibility Projects and 5) Navigational Aids. For AIP eligibility, we will primarily focus on airport development projects. There are five general airport development project types to consider: 1) Maintenance, 2) Rehabilitation, 3) Reconstruction, 4) Replacement and 5) New Construction. Projects for Rehabilitation, Reconstruction, Replacement and New Construction are normally eligible projects through AIP. Maintenance projects are normally considered ineligible; however, routine runway, taxiway or apron pavement maintenance projects at non-hub primary airports and non-primary airports are eligible when approved by the FAA. Examples of eligible maintenance projects include, but are not limited to: crack sealing, patching pavement and remarking pavements. One thing we must keep in mind: just because the project is eligible does not mean it is fundable.  It must also be justifiable.

Now let’s look at project justification. This is where the lines become a little more blurred. When considering project justification, the FAA Airport District Office (ADO) must apply three basic tests. First, the project must advance the AIP policy. Some examples include, but are not limited to: airport safety, meeting FAA standards and airport planning. Next, there must be an actual need for the project. The FAA ADO must determine if there is an actual need for the project at the airport in the next five years. For expansion projects, in many cases, your planning projects will develop forecasts for your airport to help justify future capacity needs, which in turn will help justify your project to the FAA ADO. Don’t expect the FAA ADO to blindly accept the “build it and they will come” approach; there must be a FAA-approved forecast to back up your capacity needs. Finally, the project scope must be appropriate. The FAA ADO must determine that only the elements required to obtain full benefit of the project are included. More information can be found on this item in FAA Order 5100.39, Airport Capital Improvement Plan.

So, you have determined that your project is eligible and justifiable. What’s next? Show me the money! Not so fast, my friend.  You will still have to make sure your project meets the many requirements detailed in sections 4 through 17 of Chapter 3 of the AIP Handbook. In summary, there are many aspects of project eligibility and justification that may not always be crystal clear. As a Sponsor, you are not expected to have the AIP handbook memorized but knowing where to look and doing a bit of research will help you understand what you can use AIP funds for and will make the project process go much smoother. In most cases, your consultant and your FAA Program Manager should be able to help you navigate “The AIP Bible” and better position yourself for a AIP grant offer to help keep your airport in tip-top shape and meet the needs of your community and the airport’s users.