FAA Airport Compliance Manual - Order 5190.6C – Airports
February 2026
Order 5190.6C sets forth policies and procedures for the FAA Airport Compliance Program. It provides basic guidance for FAA personnel in interpreting and administering the various continuing commitments airport owners make to the United States as a condition for the grant of federal funds or the conveyance of federal property for airport purposes. The Order discusses the obligations set forth in the standard airport sponsor assurances, addresses the application of the assurances in the operation of public-use airports, and facilitates interpretation of the assurances by FAA personnel.
Order 5190.6C cancels and replaces 5190.6B. Version C incorporates Changes 1 through 3 to 5190.6B discussed below and updates the following chapters:
Chapter 6, Rights and Powers and Good Title
Chapter 7, Airport Operations and Maintenance
Chapter 8, Exclusive Rights
Chapter 12, Review of Aeronautical Lease Agreements
Chapter 13, Airport Noise and Access Restrictions
Chapter 14, Restrictions Based on Safety and Efficiency Procedures and Organization
Chapter 15, Permitted and Prohibited Uses of Airport Revenue
Chapter 20, Compatible Land Use
Chapter 21, Land Use Compliance Inspection
Chapter 22, Land Use Changes and Releases of Federally Acquired and Federally Conveyed Land
Appendix G, Explanation of Terms
These updates address the following:
Public comments offered on the 2009 update.
FAA Reauthorization Act of 2024.
Updated statutory and regulatory citation references.
Policy changes adopted by the agency since 2009 to remain current with Federal statutes.
The Airport Compliance Manual sets forth policies and procedures for the FAA Airport Compliance Program. It provides basic guidance for FAA personnel in interpreting and administering the various continuing commitments airport owners make to the United States as a condition for the grant of federal funds or the conveyance of federal property for airport purposes. The Order discusses the obligations set forth in the standard airport sponsor assurances, addresses the application of the assurances in the operation of public-use airports, and facilitates interpretation of the assurances by FAA personnel.
The Office of Airport Compliance and Management Analysis undertook a review of the Order and published changes to the Airport Compliance Manual, 5190.6B:
Change 1 to Order 5190.6B was issued on December 3, 2021, and updated Chapter 1, Scope and Authority; Chapter 9, Unjust Discrimination between Aeronautical Users; Chapter 10, Reasonable Commercial Minimum Standards; Chapter 11, Self-Service; and Chapter 23, Reversions of Airport Property.
Change 2 to Order 5190.6B was issued on December 9, 2022, and updated Chapter 2, Compliance Program; Chapter 3, Federal Obligations from Property Conveyances; Chapter 4, Federal Grant Obligations and Responsibilities; and Chapter 5, Compliant Resolution.
Change 3 to Order 5190.6B was issued September 15, 2023, and updated Chapter 16, Resolution of Unlawful Revenue Diversion ; Chapter 17, Self-Sustainability; Chapter 18, Airport Rates and Charges; and Chapter 19, Airport Financial Reports.
See Also
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Section
Title
Page
1.1
Purpose
1-1
1.2
Audience
1-1
1.3
Where Can I Find This Order?
1-1
1.4
Cancellation
1-1
1.5
Introduction
1-1
1.6
Scope
1-2
1.7
Background
1-2
1.8
Compliance Program Background
1-5
1.9
Sources of Airport Sponsor Federal Obligations
1-5
1.10
FAA Authority to Administer the Compliance Program
1-7
Section
Title
Page
2.1
Introduction
2-1
2.2
Background
2-1
2.3
Determining if an Airport is Federally Obligated
2-1
2.4
Objectives of the Compliance Program
2-2
2.5
Program Elements
2-3
2.6
Priorities and Emphasis
2-4
2.7
Responsibilities
2-4
2.8
Analyzing Compliance Status
2-5
2.9
Compliance Determination
2-6
2.10
Grants Watch List
2-7
Section
Title
Page
3.1
Introduction
3-1
3.2
Background
3-2
3.3
The War Assets Administration (WAA)
3-2
3.4
Nonairport Property
3-3
3.5
The Use of Property for Revenue Production
3-3
3.6
Highest and Best Use and Suitability for Airport Use
3-4
3.7
Types of Conveyance Instruments for Surplus Property
3-5
3.8
Sponsor Federal Obligations for Surplus Property
3-5
3.9
Duration of Surplus Property Federal Obligations
3-7
3.10
Review of Specific Federal Surplus Property Obligations
3-8
3.11
Nonsurplus Federal Land Conveyances
3-9
3.12
Land Conveyance Federal Obligations
3-9
3.13
Bureau of Land Management
3-10
3.14
Federal Obligations Imposed by Other Government Agencies
3-10
3.15
Duration of Nonsurplus Federal Obligations
3-10
3.16
Reversion Provisions
3-10
3.17
Airport Sponsor Compliance
3-11
3.18
The AP-4 Land Agreements
3-11
3.19
Base Conversion and Surplus Property
3-12
3.20
Joint Use and Federal Use of Obligated Airports
3-13
Section
Title
Page
4.1
Introduction
4-1
4.2
Sponsor Federal Obligations Under Various Grant Agreements
4-1
4.3
The Duration of Federal Grant Obligations
4-3
4.4
The Useful Life of Grant Funded Projects
4-5
4.5
Airport Sponsor Compliance
4-6
4.6
Federal Obligations under the Basic Grant Assurance Requirements
4-6
Section
Title
Page
5.1
Introduction
5-1
5.2
Background
5-1
5.3
The Basics
5-2
5.4
Part 13: Resolution through Informal Discussions
5-5
5.5
Part 13: Informal Review Process
5-6
5.6
Part 13: Stale Complaint
5-12
5.7
FAA Initiated Informal Letter of Investigation
5-12
5.8
Part 16: Formal Complaint
5-12
Section
Title
Page
6.1
Introduction
6-1
6.2
Responsibilities
6-1
6.3
Controlling Grant Assurances
6-1
6.4
Airport Governance Structures
6-3
6.5
Rights and Powers
6-4
6.6
Good Title
6-6
6.7
Airport Sponsor Transfers
6-8
6.8
Airport Management and Development Arrangements
6-16
6.9
Airport Investment Partnership Program
6-19
6.10
Partnership Outside of the Airport Investment Partnership Program
6-21
Section
Title
Page
7.1
Introduction
7-1
7.2
Roles and Responsibilities
7-1
7.3
Controlling Grant Assurances and Federal Guidance
7-1
7.4
Federal Government Use during a National Emergency or War
7-4
7.5
Airport Maintenance Federal Obligations
7-5
7.6
Maintenance Procedures
7-6
7.7
Airport Pavement Maintenance Requirement
7-7
7.8
Major Pavement Repairs
7-9
7.9
Unpaved Landing Areas
7-10
7.10
Airport Operations Requirements
7-10
7.11
Local Rules and Procedures
7-13
7.12
Hazards and Mitigation
7-14
7.13
Use of Airports by Federal Government Aircraft
7-20
7.14
Land for Federal Facilities
7-22
7.15
Airport Layout Plan (ALP)
7-24
7.16
Exhibit “A” (Property Inventory Map) and Airport Property Map
7-25
7.17
Temporary Closing of an Airport
7-26
7.18
Access by Intercity Buses
7-30
Section
Title
Page
8.1
Introduction
8-1
8.2
Definition of an Exclusive Right
8-1
8.3
Legislative and Statutory History
8-1
8.4
Development of the Exclusive Rights Prohibition into FAA Policy
8-4
8.5
Airports Having a Single Aeronautical Service Provider
8-6
8.6
Denying Requests by Qualified Providers
8-6
8.7
Exclusive Rights Violations
8-7
8.8
Exceptions to the General Rule
8-10
8.9
UNICOM
8-13
8.10
Implementation of Policy
8-14
8.11
Military and Special Purpose Airports
8-14
Section
Title
Page
9.1
Introduction
9-1
9.2
Rental Fees and Charges: General
9-2
9.3
Types of Charges for Use of Airport Facilities
9-4
9.4
Airport Tenant and Concessionaire Charges to Airport Users
9-4
9.5
Terms and Conditions Applied to Tenants Offering Aeronautical Services
9-5
9.6
Fixed-Base Operations and Other Aeronautical Services
9-6
9.7
Availability of Leased Space
9-8
9.8
Air Carrier Airport Access
9-12
9.9
Civil Rights
9-13
9.10
FAA Policy on Granting Preferential Treatment Based on Residency
9-13
Section
Title
Page
10.1
Introduction
10-1
10.2
FAA Recognition of Minimum Standards
10-1
10.3
Use of Minimum Standards to Protect an Exclusive Right
10-2
10.4
Benefits of Minimum Standards
10-2
10.5
Developing and Applying Minimum Standards
10-2
10.6
Flying Clubs
10-5
10.7
Illegal Air Charters
10-7
Section
Title
Page
11.1
General
11-1
11.2
Restrictions on Self-servicing Aircraft
11-1
11.3
Permitted Activities
11-2
11.4
Contracting to a Third Party
11-3
11.5
Restricted Service Activities
11-3
11.6
Reasonable Rules and Regulations
11-4
11.7
Restrictions Based on Safety and Location
11-5
11.8
Activities Not Classified as Self-service
11-5
11.9
Sponsor Self-service Prerogatives
11-5
11.10
Fractional Aircraft Ownership Programs
11-6
11.11
Air Carriers
11-7
Section
Title
Page
12.1
Introduction
12-1
12.2
Background
12-1
12.3
Review of Agreements
12-2
12.4
FAA Review of Leases
12-4
12.5
Agreements Covering Aeronautical Services to the Public
12-4
12.6
Agreements Involving an Entire Airport
12-5
12.7
Agreements Granting “Through-the-Fence” Access
12-6
Section
Title
Page
13.1
Introduction
13-1
13.2
Responsibilities
13-1
13.3
Future Noise Policy
13-1
13.4
Background
13-1
13.5
Applicable Law and Regulation
13-3
13.6
Applicable Grant Assurances
13-4
13.7
Overview of the Noise-Related Responsibilities of the Federal Government
13-4
13.8
CFR part 36, Noise Standards for Aircraft Type and Airworthiness Certification
13-5
13.9
The Aircraft Noise Compatibility Planning Program
13-6
13.10
Compliance Review
13-8
13.11
Mandatory Headquarters Review
13-8
13.12
Balanced Approach to Noise Mitigation
13-8
13.13
Cumulative Noise Metric
13-10
13.14
General Noise Assessment
13-10
13.15
Residential Development
13-11
13.16
Impact on Other Airports and Communities
13-12
13.17
The Concept of Unjust Discrimination
13-12
13.18
Part 161 Restrictions Impacting Stage 2 or Stage 3 Aircraft
13-13
13.19
Undue Burden on Interstate Commerce
13-14
13.20
Use of Complaint Data
13-15
13.21
Use of Advisory Circular (AC) 36-3H
13-16
Section
Title
Page
14.1
Introduction
14-1
14.2
Applicable Law
14-1
14.3
Restricting Aeronautical Activities
14-2
14.4
Minimum Standards and Airport Regulations
14-3
14.5
Agency Determinations on Safety and System Efficiency
14-5
14.6
FAA Review of an Airport Sponsor’s Safety and Efficiency Justification
14-5
14.7
Reasonable Accommodation
14-6
14.8
Restrictions on Touch-and-Go Operations
14-8
14.9
Restrictions on Banner Towing, Powered Parachutes, Gliders, Light Sport Aircraft, Parachute Operations, and Ultralights
14-8
14.10
Unpaved Landing Areas
14-8
Section
Title
Page
15.1
Introduction
15-1
15.2
Responsibilities
15-1
15.3
Statutory Requirements
15-1
15.4
Applicable Grant Assurances
15-3
15.5
Applicable FAA Policy
15-3
15.6
Airport Revenue Defined
15-3
15.7
Applicability of Airport Revenue Requirements
15-6
15.8
Federal Financial Assistance
15-6
15.9
Permitted Uses of Airport Revenue
15-7
15.10
Allocation of Indirect Costs
15-11
15.11
Standard for Documentation for Reimbursement to Government Entities
15-11
15.12
Prohibited Uses of Airport Revenue
15-12
15.13
Air Carrier Incentive Program (ACIP)
15-15
15.14
Airport Investment Partnership Program (AIPP)
15-16
15.15
Mineral Rights Revenue Exemption
15-17
15.16
Grandfathering from Prohibitions on Use of Airport Revenue
15-18
15.17
Oversight of Grandfathered Sponsors/Airports
15-19
Section
Title
Page
16.1
Background
16-1
16.2
FAA Authorization
16-1
16.3
Section 47133 and Grant Assurance 25, Airport Revenues
16-3
16.4
Agency Policy
16-3
16.5
Responsibilities
16-3
16.6
Detection of Airport Revenue Diversion
16-4
16.7
Investigation of a Complaint of Unlawful Revenue Diversion
16-5
16.8
Investigation without a Complaint
16-6
16.9
Administrative Sanctions
16-6
16.10
Civil Penalties and Interest
16-7
16.11
Compliance with Reporting and Audit Requirements
16-8
16.12
Statute of Limitations on Recovery of Funds
16-8
Section
Title
Page
17.1
Introduction
17-1
17.2
Statutory Requirements
17-1
17.3
Related Grant Assurance and FAA Policies
17-1
17.4
Self-Sustaining Principle
17-2
17.5
Airport Circumstances
17-2
17.6
Long-Term Approach
17-2
17.7
New Agreements
17-2
17.8
Revenue Surpluses
17-2
17.9
Aeronautical Use Rates
17-3
17.10
Nonaeronautical Use Rates
17-3
17.11
Fair Market Value
17-4
17.12
Exceptions to the Self-Sustaining Rule: General
17-4
17.13
Exceptions to the Self-Sustaining Rule: Providing Property for Public Community Purposes
17-4
17.14
Exception to the Self-Sustaining Rule: Use of Property by Not-for-Profit Aviation Organizations
17-7
17.15
Exception to the Self-Sustaining Rule: Military Units
17-7
17.16
Exception to the Self-Sustaining Rule: Transit Projects
17-8
17.17
Exception to the Self-Sustaining Rule: Private Transit Systems
17-8
Section
Title
Page
18.1
Introduction
18-1
18.2
Background
18-1
18.3
Responsibilities
18-3
18.4
Definitions
18-3
18.5
Key Concepts
18-5
18.6
Fair and Reasonable
18-6
18.7
Permitted Airfield Costs
18-7
18.8
Environmental Costs
18-8
18.9
Noise
18-8
18.10
Insurance
18-8
18.11
Causation
18-8
18.12
Facilities under Construction
18-8
18.13
Costs of Another Airport
18-9
18.14
Airport System
18-9
18.15
Costs Related to Closing an Airport while Building a Replacement Airport.
18-9
18.16
Project Costs
18-9
18.17
Passenger Facility Charge (PFC) Projects
18-10
18.18
Prohibition on Unjust Discrimination
18-10
18.19
Self-Sustaining Rate Structure
18-11
18.20
Local Negotiation and Resolution
18-11
18.21
Complaints
18-12
Section
Title
Page
19.1
Introduction
19-1
19.2
Statutory Authority
19-1
19.3
Grant Assurance 26, Reports and Inspections
19-3
19.4
Applicability
19-3
19.5
Annual Financial Reports
19-3
19.6
Procedures for Evaluating the Airport Owners/Sponsors Financial Reporting Program
19-5
19.7
Single Audit Reports
19-5
Section
Title
Page
20.1
Background
20-1
20.2
Responsibilities
20-1
20.3
Controlling Grant Assurances and Additional Resources
20-2
20.4
Compatible Land Use
20-3
20.5
Zoning and Land Use Planning
20-4
20.6
Minimizing Incompatible Land Use
20-5
20.7
Residential Use of Land on or Near Airport Property
20-6
20.8
Homelessness On and Adjacent to Federally Obligated Airports
20-10
Section
Title
Page
21.1
Introduction
21-1
21.2
Responsibilities
21-1
21.3
Authority
21-1
21.4
Elements of the Land Use Inspection
21-3
Section
Title
Page
22.1
Introduction
22-1
22.2
Responsibilities
22-2
22.3
Applicable Law
22-3
22.4
Applicable Grant Assurances
22-3
22.5
Federal Obligations Imposed with the ALP and Exhibit “A”
22-3
22.6
FAA Policy Regarding Processing Land Use Changes on Federally Acquired or Federally Conveyed Land
22-4
22.7
Explanation of Terms
22-4
22.8
FAA Land Use Approval Authority on Sponsor Acquired Land
22-9
22.9
Process for FAA Approval of a Land Use Change on Federally Acquired Land
22-10
22.10
Process for FAA Consent to a Land Use Change on Federally Conveyed Land
22-13
22.11
Release of the Exclusive Rights Federal Obligation
22-16
22.12
Process for FAA Release of Federally Acquired Land for Sale, Conveyance, or Exchange
22-16
22.13
Process for FAA Release of Federally Conveyed Land for Sale, Conveyance or Exchange
22-24
22.14
Release of Entire Airport
22-31
22.15
Sale, Exchange, or Land Use Change of Land Acquired with Passenger Facility Charge (PFC) Funds
22-33
22.16
Disposal of Land Acquired for Noise Compatibility Purposes
22-34
22.17
Procedures for Public Notice
22-34
22.18
Release of National Emergency Use Provision (NEUP)
22-36
22.19
Release of Reverter Clause
22-37
22.20
Release from Federal Obligation to Furnish Land without Charge
22-37
22.21
Determining Fair Market Value for Sale or Disposal
22-37
22.22
FAA Consent by Letter of Intent to Release – Basis for Use
22-38
22.23
Statutorily Released Obligations
22-39
22.24
Procedures for Requests for Change in Use of Personal Property, Structures, Equipment and Facilities
22-39
Section
Title
Page
23.1
Introduction
23-1
23.2
General
23-2
23.3
Authority to Revert a Property Interest
23-2
23.4
Instruments of Conveyance
23-2
23.5
Voluntary Return of Property to the U.S. Government
23-3
23.6
Involuntary Reversion
23-3
23.7
Identifying the Federal Agency to Receive the Property
23-4
23.8
Determination of Default
23-4
23.9
Perform and Document the FAA’s Environmental Due Diligence
23-4
23.10
Notice of Intent to Revert Property
23-5
23.11
Voluntary Reconveyance to Correct a Default
23-5
23.12
Notice of Reverter of Property and Revestment of Title and Property Interest in the U.S.
23-7
23.13
Recording Notice of Reverter of Property and Revestment of Title and Property Interest in the U.S.
23-7
23.14
Certificate of Inspection and Possession
23-8
23.15
Possession, Posting, or Marking of Property
23-8
23.16
Reversion Case Studies
23-8
23.17
through 23.21 Reserved
23-9
Last updated: Friday, February 20, 2026
