Industry Members Meet with FAA on Security Reimbursement, 300-Foot Rule

February, 2002

Members of the Parking Industry met with the Federal Aviation Administration in early January to discuss the issues and impacts of the FAA's proposed "procedures of reimbursement of Airports, On-Airport Parking Lots and Vendors of On-Airfield Direct Services" and on the continuation of the "300-foot" rule. The meeting was held under the auspices of the National Parking Association.
From the meeting, it was apparent that the FAA was not inclined to compensate for loss a revenues due to lower traffic, and that the 300-foot rule would stay in place for the foreseeable future.
Purpose of the meeting was to acquaint the parking industry with the provisions contained in the proposed reimbursement procedures. The intent of the process is to provide procedures for certain eligible operators and service providers to apply for the reimbursement of allowable costs incurred to comply with certain security requirements imposed by the FAA (or the new Transportation Security Administration) on or after September 11, 2001.
The delegation representing the industry was composed of a half dozen parking operators representing the majority of all U.S. airport parking managed by professional operators and four representatives of the NPA Parking Consultants Council. The operating companies included MarcParc, PMI, Central Parking, APCOA Standard, Republic, Ampco System and Parsons Transportation Group. PCC representatives included staff from the Consulting Engineers Group, Desman, HNTB and Walker Parking Consultants. The senior FAA representative was Barry Molar, Director of FAA Airport Financial Assistance programs.
Basically, the purpose of the act is "to compensate for added operating costs not passed back to the airport directly related to security issues." Specifically, loss of revenue and capital costs are not included; only direct costs such as:
* Extra staff to inspect vehicles, but not added management staff.
* Extra equipment needed for vehicle inspection.
* Cost of providing temporary barriers to restrict access.
* Costs of vehicle removal from the 300-foot zone.
* Costs of shuttle operations (for salaries, etc., but not equipment) if shuttle operation is a security issue and not for convenience.
It is apparent, however, that the loss of revenue from reduced enplanement levels will not be addressed in this legislation. This will require a new legislative effort and support from the airports. Since parking revenue is often the second largest total revenue source for most airports, this should be a logical approach.
The American Association of Airport Executives and Airports Council International have not been supportive of inclusion of parking revenue in any legislative efforts to date to address overall revenue loss. This again points to the fact that any significant change in this legislation will come only from new congressional action.
The second session involved the parking consultants council members and Raymond E. Gomez, Special Agent, Aviation Explosives Security, Office of Civil Aviation Security and his associate.
Primary attention was directed to the subject of the 300-foot rule. At this time there is no intention on the part of FAA to reduce or eliminate the 300-foot requirements. (Although preferred by some FAA staff, there is no plan to increase the limit to 400 feet unless a new airport security incident occurs to require such extension.)
The 300-foot rule appears to be in place for an indefinite period -- probably for a year at least and possibly for several years. As a general subject, relaxation is likely only as a response to the perception that the threat of terrorist activity is greatly reduced.
Related restrictions on drive-up parking on airport roadways are likely to be expanded as well, but this subject is not part of the current restrictions. In effect there are three options for use of the 300-foot zone for parking, depending upon the status of the facility (existing or planned).
For existing facilities, operators may inspect vehicles, including compacts and sedans, and use spaces within 300 feet. This will require approval of the airport. Or, the facility may be modified to an extent to be considered blast resistant. This will require certification via an engineering analysis that the facility meets blast resistance standards defined by the Corps of Engineers.
For new facilities including those under construction, the operator may relocate the facility at least 300 feet from the terminal (400 feet would be a more prudent decision), provide construction modifications to comply with blast resistant standards or plan to inspect all entering vehicles.
In any event, it would appear essential that any consideration of those options be based upon the results of a substantive cost-benefit analysis. In this context the term operator is interchangeable with the tenant airport. The airport parking facility population includes garages, lots, on-airport and off-airport facilities in anyway impacted by the 300-foot limitation. Particularly in the case of new facilities, the consideration of design/operations/security/economic issues might be better directed to consideration of a 400-foot limit in the event that future incidents may invoke the increased distance rule.
There is likely to be no change in the present status for some time. Any significant change will likely come only from congressional action, which, in turn, must be originated by those interests adversely affected by current regulations. At this time there does not appear to be any group or activity assuming any kind of leadership role in such an effort.

Thanks to Richard Beebe of the Consulting Engineers Group for his input in this article.