FAA Releases Notice of Funding Opportunity for FY22 AIP Discretionary Grants
The Federal Aviation Administration (FAA) released a notice of funding opportunity (NOFO) that outlines the process for airports to apply for and receive a share of approximately $1.5 billion in fiscal year 2022 (FY22) discretionary grants under the Airport Improvement Program (AIP). In the NOFO released on April 19, FAA provides an overview of AIP discretionary funding, the process to submit an application, how the agency will evaluate proposed projects for funding, the Administration's goals, how grants will be issued, and key deadlines. This NOFO applies to AIP discretionary funds only, not the supplemental discretionary funding approved last month. 
FAA indicates that the agency will award these annually appropriated discretionary funds through the FAA's long-standing competitive grant process. However, FAA noted in the NOFO that they are seeking to fund projects that reduce greenhouse gas emissions and are designed to address climate change impacts. FAA also outlined many other goals and initiatives that they are trying to ensure are being met with these discretionary funds. Airports are advised to work with their local FAA office and review the NOFO before submitting discretionary grant applications.
FAA is encouraging airports to submit applications as soon as possible, but no later than June 30, 2022. FAA's NOFO will be published in the Federal Register tomorrow. However, you can view an advanced copy of the notice here. 
Application Process. For the FY22 AIP discretionary grant application process, FAA directs airports to work with their Regional Office (RO) or Airport District Office (ADO) to obtain an application and for additional information on how to complete the process. However, FAA indicates that for FY22, the agency will consider eligible projects that “further the Administration's goals of safety, environmental stewardship, including climate change and sustainability, equity, creation of good jobs and infrastructure investment.“ Thus, FAA advises that “[a]pplications should briefly describe how the proposed project meets at least one of these goals.“ 
Grant Selection Process. In the NOFO, FAA explained the process on how they will review and select projects for discretionary grants. The agency will continue to use the annual Airport Capital Improvement Plan (ACIP) process to identify, plan, and prioritize airport planning and development projects for AIP funding. This includes using the National Priority Rating (NPR), a quantitative measure that is used to score and prioritize projects according to FAA goals and objectives. These goals are focused on safety, security, system capacity, environment, and access. 
However, in addition to the traditional ACIP process, FAA also noted that the agency will consider (a) the “extent to which the project incorporates considerations of climate change and sustainability, to the extent possible within the program“; and (b) the “extent to which the project proactively addresses racial equity and barriers to opportunity, to the extent possible within the program.“
Why Issue a NOFO for AIP Discretionary Grants? This is the first time that FAA has issued a NOFO for AIP discretionary grants. Traditionally FAA identified eligible airports in its National Plan of Integrated Airport Systems (NPIAS) and compiled and prioritized a list of potentially eligible projects through the ACIP process. However, in 2020, the previous administration finalized guidance and a rule that requires all federal agencies to issue a notice of funding opportunity for any discretionary or competitive grants. This is the first fiscal year FAA has had to comply with the new requirements. 
What About Supplemental Discretionary Funds? In the FY22 omnibus spending bill, which President Biden signed last month to fund the federal government through the current fiscal year, Congress included almost $554.2 million in supplemental discretionary funding for airport development projects (in addition to the normal AIP funding). Of that amount, approximately $279.2 million is reserved for earmarks, which are officially known as “Community Project Funding“ requests. FAA is expected to issue a separate NOFO outlining how airports can apply for a share of the remaining amount of supplemental discretionary funding—about $275 million—in the May or June timeframe. 
What's Next? Key Deadlines and Timeline. FAA has requested that any airport that wishes to be considered for AIP discretionary funding should submit applications that meet NOFO requirements as soon as possible, but no later than June 30, 2022, to their local FAA RO/ADO. FAA has already begun to review requests for discretionary funding and will continue to do so on a rolling basis. The agency anticipates awarding grants beginning this month and will continue to announce additional awards several times throughout the fiscal year, but no later than September 30, 2022.