Yes. Priority will not be given to such projects and selection for competitive IIJA funds is not guaranteed. AIP discretionary funded projects that are removed from the FAA’s ACIP and not selected for IIJA funding will likely be delayed until funding (AIP, IIJA, PFC, etc.) is available. Replacement AIP discretionary projects will not be considered.

No. AIG Allocated funds have expanded availability for projects considered lower priority under AIP. Airports are still required to meet basic planning guidelines for AIG funds such as project justification, project consistency with the master plans, appropriate project scope, and project documentation on an approved Airport Layout Plan (ALP). Additional guidelines with specific examples will be developed and included in future IIJA guidance and AIP guidance. If an ADO has concerns about the types of projects being funded with AIG and an airport’s requested discretionary project, then it should reach out to the IIJA Team and APP for further discussions.

Yes. AIG Allocated funds have expanded availability for projects considered lower priority under AIP. Airports are still required to meet basic planning guidelines for AIG funds such as project justification, project consistency with the master plans, appropriate project scope, and project documentation on an approved ALP. Additional guidelines with specific examples will be developed and included in future IIJA guidance and AIP guidance. If an ADO has concerns about the types of projects being funded with AIG and an airport’s requested discretionary project, then it should reach out to the IIJA Team and APP for further discussions.

No. Sponsors can receive an FCT, AFR, or ATP grant while saving AIG Allocated funds for a larger project. The use of AIG Allocated funding will be taken into consideration when making FCT, AFR, and ATP funding decisions. 

Yes. Section 723(a) of the FAA Reauthorization Act of 2024 (P.L. 118-63) amended 49 U.S.C. §47142 by revising the section heading to “Alternative Project Delivery” instead of “Design-Build Contracting” and expanding the allowable contract types from solely design-build to include progressive design-build and integrated project delivery methods, collectively referred to as “Covered Project Delivery Contracts.” See Section 3-43 and Table U-9 of the AIP Handbook. See Q-U24 for more information pertaining to cost reimbursement.

In general, a guaranteed maximum price (GMP) is required to receive a grant when using an alternative project delivery method for procurement. This fulfills the NOFO requirement to meet all statutory and administrative criteria related to timely implementation. 

An airport has options in this scenario. In addition to waiting to accumulate AIG allocations; a sponsor can phase the project so that annual grants can be issued using available IIJA funds; use AIP funds for a defined project phase; or construct the project and request reimbursement with future allocations, at the sponsor’s risk.

No. Funding will not be available ahead of the FY in which it is allocated. AIG allocations can be used for phased projects, saved for up to four years to use on a larger project, or the sponsor can construct a project and request reimbursement with future allocations at the sponsor’s risk.

Yes, provided the replacement airport has been approved by FAA and has an airport identification code assigned. 

No. Title 49 USC 40117(a)(3)(G) (incorporated into IIJA-eligibility) requires airports to be located in a nonattainment area or maintenance area for this type of equipment.

No. FAA owned ATCT are the responsibility of ATO, not ARP. Use of ARP IIJA funding to replace a FAA owned ATCT would be supplementing ATO’s appropriated funds, which is impermissible.

For either AIG Allocated or ATP funds, the shell of the CBP facilities is eligible. The USDA inspection facilities are only eligible for AIG Allocated or ATP funds if they are required in the terminal for screening passengers or their baggage, for example, in Hawaii where all passenger baggage (checked and carry-on) is screened by the USDA.  

    According to 49 U.S.C. §40117(a)(3)(I), if a Federal agency workspace element must relocate on airport property due to terminal development or renovation, replacing existing workspace elements is considered eligible for AIG Allocated grants. For instance, if renovating an airport terminal requires replacing CBP facilities, those facilities qualify for funding under AIG Allocated or ATP.
 

Yes. Eligibility calculations similar to those done under PFC will be required for AIG Allocated and ATP terminal grants.

Yes. The process for making eligibility calculations is outlined in PFC Update 75-21 (86 FR 48793, August 31, 2021).

Yes. Not less than 10% of the annual ATP funding is available for non-hub and non-primary airports. Instructions for applying for these funds will be outlined in a NOFO, which will be issued annually for FY 2022-2026. Projects will be selected by FAA based on sponsor’s information submitted in response to the criteria as outlined in the NOFO.

No. The $30M cap under 49 U.S.C. §47119(f) only applies to AIP funds and is not incorporated into IIJA legislation.

No. The $200,000 cap under 49 U.S.C. 47119(b)(2) applies to AIP funds and is not incorporated into IIJA legislation.

Access roads servicing exclusively airport traffic that leads directly to or from an airport passenger terminal building and walkways that lead directly to or from an airport passenger terminal building are considered terminal development. These projects will be evaluated as terminal development projects as outlined in the annual NOFO. Sponsors should consider use of AIG Allocated funds for eligible, standalone access road improvements.

The IIJA provides authority to use geographical and economic hiring preferences, including local hiring preferences, for construction jobs, subject to any applicable State and local laws, policies, and procedures. Sponsors and subrecipients may use labor and employment practices described in 2 CFR 200.318(l)(1) if consistent with U.S. law, applicable Federal financial assistance programs, and other requirements of 2 CFR Part 200.

The IIJA grants are federal financial assistance; therefore, the Airport Infrastructure Program and the Airport Terminal Program make Federal Awards to non-Federal entities. These programs are subject to 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR § 200.101). In addition, IIJA requires use of the project grant authority required under 49 USC 47104 which further federalizes the funds.