Standards Review

Section 2.8b, paragraph 1. When specialized aviation service operations (SASO), sometimes known as single service operators or special fixed base operators (FBO), apply to do business on an airport, difficulties can arise if the airport sponsor requires that all businesses on the airport comply with all provisions of the published minimum standards. This is not to say that all SASOs providing the same or similar services should not equally comply to all applicable minimum standards; however, an airport should not, without adequate justification, require that an operator desiring to provide a single service also meet the criteria for a full-service FBO. An airport sponsor should develop reasonable, relevant, and applicable standards for each type and class of service. Examples of these specialized services may include aircraft flying clubs, flight training, aircraft airframe and powerplant repair/maintenance, aircraft charter, air taxi or air ambulance, aircraft sales, avionics, instrument or propeller services or other specialized commercial flight support businesses.

NATA Comments:
The FAA must recognize that the industry may not readily accept the SASO term. While NATA does not object to its use, the agency must ensure incumbent operators are not treated unfairly by new SASO operations subverting existing leases and minimum standards. The agency should not include flying clubs because these entities by definition are not for profit.

Other Select NATA Comments
• The FAA should discourage the allowance of through-the-fence operators unless an appropriate agreement, including fees on services and standards for service, is implemented.
• It is highly recommended that the airport have a regularly scheduled [minimum standards] update (e.g., every 3 years) to avoid the appearance of changing a standard after receiving a lease application.
• Specific language on training requirements on aircraft fueling procedures and training on the monitoring of fuel quality should be included. Typically, this training would not be the airport sponsor's responsibility but that of the fueling operator.
• The FAA should provide recommendations or guidance on the enforcement of Minimum Standards by the airport sponsor. This could include implementing the standards through local ordinance, setting procedures for penalties to be imposed on violators of the minimum standards.