Regulatory Alert: FAA Releases Updated FAQ Guidance for CRRSAA and ARPA Grants

November 29, 2021

Last week the Federal Aviation Administration (FAA) released updated frequently asked questions (FAQ) documents that provide guidance for airport sponsors on how FAA administers the $2 billion in relief for airports and eligible concessionaires that was made available under the Coronavirus Response and Relief Supplemental Appropriation Act (CRRSAA), known as the 'Airport Coronavirus Response Grant Program' (ACRGP), and the $8 billion in Airport Rescue Grants that were made available through the American Rescue Plan Act (ARPA). Updates in both documents focus almost exclusively on concessionaire rent relief issues. 

Updated Guidance on CRRSAA Grants. The updated FAQ guidance document for CRRSAA grants includes several clarifying edits and new details for airports on administering concessionaire relief under the ACRGP, including revising the necessary contents for an airport concessionaire rent relief plan; whether to exclude a newly operating concessionaire from relief allocations; and how to handle a partially unexpended rent relief credit. In addition, FAA posted an updated sample ACRGP grants closeout report and concessions relief plan. 

You can view the updated FAQ guidance for ACRGP here. AAAE has also highlighted where FAA updated the FAQ document in this version here. For a summary of the entire FAA FAQ guidance for ACRGP, see our February 12 Airport Alert and April 9 Regulatory Alert. 

Updated Guidance on ARPA Grants. The updated FAQ guidance document for ARPA grants includes some clarifying edits and additional details for airports on administering concessionaire relief, including expanding on the definitions of 'eligible small airport concession' and 'eligible large airport concession'; providing a new definition for 'in-terminal airport concession'; revising the necessary contents for an airport concessionaire rent relief plan; and clarifying that master or prime concessionaires, developers, or lessees are eligible for rent relief. Like with CRRSAA grants, FAA posted an updated sample ARPA grants closeout report and concessions relief plan. 

You can view the updated FAQ guidance for ARPA here. AAAE has also highlighted where FAA updated the FAQ document in this version here. For a summary of the entire FAA FAQ guidance for ARPA, see our June 11 Regulatory Alert.