Regulatory Alert: FAA Releases Notice of Funding Opportunity for FY25 Airport Terminal Program Grants

FAA Releases Notice of Funding Opportunity for FY25 Airport Terminal Program Grants
July 1, 2024

On July 1, the Federal Aviation Administration (FAA) released the notice of funding opportunity (NOFO) that outlines how airports can apply for a share of approximately $1 billion in fiscal year 2025 (FY25) discretionary funds under the Airport Terminal Program (ATP), which was created by the Infrastructure and Investment and Jobs Act (IIJA), commonly known as the Bipartisan Infrastructure Law (BIL). The goal of the ATP is to make annual grants for terminal development projects that will improve airport infrastructure. In the NOFO released today, FAA outlines how airports can apply for the fourth year of ATP funding and how the agency will evaluate applications and proposed projects.
 
FAA has published the NOFO, the application form, and other ATP details on their BIL website here. Please note that the NOFO is slightly different from the NOFO that was released in previous years; however, the application form has not changed from last year. AAAE has created a separate version of the FY25 NOFO that highlights the changes FAA made from the FY24 NOFO. You can view that here.
 
The agency has set Wednesday, July 31, at 5 p.m. ET, as the deadline for submitting applications. FAA has previously indicated that the agency is targeting early fall 2024 for announcing projects that will be selected for funding.
 
Overview of the ATP. The NOFO provides an overview and detailed information regarding the ATP. Under the program, FAA is providing $5 billion ($1 billion annually) to airports via discretionary, competitive grants for eligible terminal projects. FAA has already announced over $2.9 billion in FY22, FY23, and FY24 ATP grants that are funding 298 projects. As a reminder, these are the key details of which airports should be aware:

•    Distribution by Hub Size: The $1 billion for FY25 ATP grants is subject to the following award allocation limitations: 55% for large hub airports; 15% for medium hub airports; 20% for small hub airports; and not less than 10% for nonhub and nonprimary airports.

•    Eligible Projects: Eligible projects for funding under the ATP include: (1) airport terminal development, including multimodal terminal development; (2) on-airport rail access projects; and (3) projects for relocating, reconstructing, repairing, or improving an airport-owned air traffic control (ATC) tower.

•    Project Considerations: FAA is required to consider projects that will increase capacity and passenger access, replace aging infrastructure, expand accessibility for persons with disabilities, improve airport access for historically disadvantaged populations, improve energy efficiency, improve airfield safety through terminal relocation, and encourage actual and potential competition.

•    Preferences and Priorities: FAA will provide preference to projects that complete a development objective and give priority to projects that have received partial awards.

•    Local Match: The federal cost share for ATP grants is 80% for large and medium hub airports; and 95% for the remainder of eligible airports.

Application Process. Applications for a FY25 ATP grant must be submitted to FAA using FAA Form 5100-144, “Bipartisan Infrastructure Law, Airport Terminal and Tower Project Information,” which can be found on the FAA’s ATP website. The application form requires airports to provide a brief project description, targeted timeframe dates, information about project status, and details about how the proposed project will satisfy the criteria that FAA must consider when selecting grants for funding.
 
Any questions regarding applications can be directed to your Regional Office or Airports District Office, or the FAA Office of Airports BIL Team at 9-ARP-BILAirports@faa.gov. The application form and NOFO both have instructions on how to submit to FAA for consideration. Applications must be submitted electronically by 5 p.m. ET on Wednesday, July 31.
 
ATP Grant Selection Criteria. In the NOFO, FAA outlines the criteria on how applications for a FY25 ATP grant will be rated. The agency made no changes to this process from previous years; the selection process and criteria will remain the same. These are the six factors that will be taken into consideration and used to evaluate submissions:

•    The project must meet the eligibility requirements under the ATP.

•    Timeliness of implementation, with priority given to those projects that can satisfy all requirements for a grant award by June 2025.

•    Favorable consideration will be given to eligible projects that advance specific objectives outlined above, such as increasing capacity and passenger access; replacing aging infrastructure; and expanding accessibility for persons with disabilities; among other things. The NOFO provides much more detail on each of these objectives.

•    ATC tower projects will be evaluated based on overall impact on the NAS, including age of facility, operational constraints, and nonstandard facilities.

•    FAA will provide a preference to projects that achieve a complete development objective, even if awards for the project must be phased, and prioritize projects that have received partial awards.

•    Applicants will also be evaluated on whether and how the project delivery and implementation (a) create good-paying jobs with the free and fair choice to join a union to the greatest extent possible, and (b) provide opportunities for all workers to be trained and placed in good-paying jobs directly related to the project.

FAA indicated that the agency will evaluate applications based on how well a proposed project meets these criteria, including project eligibility, justification, readiness, and the availability of matching funds.
 
Projects Advancing Administration Goals. For the fourth year, FAA emphasized again that the agency will consider projects that advance goals outlined in several key executive orders issued by President Biden, including how the project will address the challenges faced by individuals in underserved communities and rural areas; reduce greenhouse gas emissions and address climate change impacts; and promote a fair, open and competitive marketplace. As in previous years, these are factors airports should consider when proposing a specific project for FAA’s consideration.
 
Comparison of FY25 NOFO to FY24 NOFO. As in previous years, FAA made some changes to the FY25 ATP NOFO as compared to the NOFO for FY24 ATP grants. However, based on our review, there are only two notable changes. First, FAA provides a “summary of key information” at the beginning of the NOFO, which simply summarizes the entire funding opportunity. Second, under the ATP, FAA is required to consider projects that will, among other things, improve energy efficiency. One notable change in the NOFO is ensuring that airport applicants “estimate and commit to tracking the carbon dioxide reduction anticipated from [these] potential projects,” which was not a requirement that FAA had last year.
 
AAAE has created a separate version of the FY25 NOFO that highlights the changes FAA made from the FY24 NOFO. You can view that here.
 
What’s Next? Applications for FY25 ATP discretionary funding must be submitted electronically no later than 5 p.m. ET on Wednesday, July 31. FAA has previously indicated that the agency is targeting early fall 2024 for announcing projects that will be selected for funding.