By: Nancy S. Williams Date:March 4, 2010 Federal Aviation Administration Eligibility of Safety, Security and Snow Removal Equipment Under AIP

By: Nancy S. Williams

Date: March 4, 2010

Federal AviationAdministrationEligibility of Safety,

Security and Snow Removal Equipment Under AIP

2Federal AviationAdministration

Eligibility of Safety, Security and Snow Removal EquipmentMarch 4, 2010

AIP is a “Permissive” ProgramAs the US Supreme Court states,

“ … the expenditure of public funds is proper only when authorized by Congress, not that public funds may be expended unless prohibited by Congress” United States v. MacCollom, 426 U.S. 317, 321 (1976).

Two Things to Remember:

• Unless specifically allowed by statute, we can’t do it, and

• Good ideas don’t make things eligible



General Guidelines for Equipment Procurement (Continued)

• Must follow FAA Technical Specifications• Equipment is for on-airport use only for the

intended purpose• Equipment storage buildings are simply to

protect the AIP investment, not to provide training rooms, operational space, etc.



General Guidelines for Equipment Procurement

• ARFF Equipment - ONLY what is required by the Airport Index

• Security Equipment ONLY what is required by rule or regulation

• Snow Removal Equipment – limited to the equipment required to remove snow in Priority 1 area according to the approved snow removal plan. For GA airports, limited to a single SRE carrier vehicle



ADMINISTRATIVE EQUIPMENT• Eligibility for AIP – very limited and only by

special legislation– Interactive (ARFF) Training Systems

• Not Eligible for AIP– Other Administrative Costs

• Preparing and maintaining your ACM• Maintaining Training Records• Record Keeping Software • Software Updates • Other training costs



ARFF EQUIPMENT• ARFF equipment is eligible if it is required

by index• When new vehicle or a replacement vehicle

is needed, the FAA must know:• If a replacement, what vehicle is being replaced• If new, what size/type of equipment is required• ARFF Vehicle replacement or acquisition must have

a signed hard-copy Part 139 Inspector recommendation

• Airport should maintain a list of ARFF equipment, listing AIP grant under which it was obtained and VIN #



ARFF EQUIPMENT (Continued)

• Protective Clothing is eligible based on the following criteria:• 1 suit for each full time aircraft fire-fighter (not all

firefighters)• 1 suit for each less than full-time position, but no

more than 2 for lightweight vehicles and 5 for larger vehicles.

• Replacement of protective clothing is eligible if required as a result of a 139 inspection



ARFF EQUIPMENT

• NOT ELIGIBLE• Passenger vehicles or trucks – Not even the Fire

Marshal’s Suburban, even if it is used to respond to an incident

• Ambulances or Mass Casualty Vehicles• Aircraft removal equipment



ARFF EQUIPMENT

• Equipment that goes in the vehicle • Should not be purchased as part of the Vehicle RFP,

it must be a separate contract• ARFF protective suits are also a separate RFP

• UPCOMING NEWS FLASH!• The ARFF specification program is in testing now

and will be rolled out soon. (by the end of the month)



Part 139 Inspections Discrepancies/Recommendations

• If there is a discrepancy that will require an AIP action, notify the project engineer

• A recommendation is just that and does not necessarily trigger an AIP action

• Project Engineer is required to have justification beyond a recommendation on an inspection report



NIMS TRAINING

Homeland Security Presidential Directive 5 (HSPD-5) signed 2/2003Requires developing and implementing a

National Response Plan and the National Incident Management System (NIMS)

NIMS is a consistent nationwide approach for federal, state, territorial, tribal, and local governments to work together to prepare for, prevent, respond to, and recover from domestic incidents regardless of cause, size or complexity.

Valuable and Important, but not AIP!



NIMS COMPLIANCE –

Some website information is confusing - “Federal guidelines indicate that any jurisdiction (state, local, tribal) which receives federal preparedness program funds* … is required to be NIMS compliant by September 30, 2006 in order to be eligible for FFY 07 grant funds.”

New York State website

But, not AIP grants – again, this is not an AIP requirement – despite what other websites may say



Frequently Misunderstood –FSD Recommendations

TSA FSD Order was rewritten The revision clarify that there are only about

5 AIP-eligible security projects• Perimeter Security Fencing for 139 Airports – 7’ with

3 strands of wire (Wildlife fencing is another matter!)• CCTV as part of a 1542 Part 207 access control

plan• Fingerprinting equipment for criminal history record

check for SIDA access




5 generally eligible projects – continued• EDS modifications – technically eligible, but can’t

spend any money on it• Vehicle Barriers with extra justification




Generally NOT eligible• Vehicles for Perimeter Patrols – airports requesting

perimeter patrol vehicles must show that the vehicles are “delta” above pre-9/11 requirements

• Operations Vehicles• Command and Control Center Vehicles (can now be

funded through DHS grants)• Portions of Command and control centers that do

not support major incident handling




FSD Recommendations MUST BE SPECIFIC• May not simply say, “concur with Airport’s plan”• Must be submitted IN WRITING to both FAA and to

TSA HQ• Must provide supporting documentation for any

project beyond the 5 unquestionable eligible projects.



FSD RecommendationsAn FSD recommendation must indicate that

the work is required under 1542:

“…the purpose of this letter is to advise you that the TSA supports the (project) which would mitigate the most burdensome portions of the Security Directive…(Project) will greatly enhance the security posture of this airport as well as its ability to meet the requirements of 49 CFR Part 1542.”



FSD Recommendations (cont’d)

“While I am not in a position to directly endorse or promote the (airport name and project), any initiatives to enhance security at (airport) are of great interest to me.”



Security Work in Terminals

• Only in public areas• Follows the same eligibility rules as any

other terminal project



SNOW EQUIPMENT

• Snow Removal Plan– Must be approved (element of the ACM)– Priority 1 is that area that must be cleared in the first

30 minutes – access to main runway, limited apron areas

– All equipment needed to meet the Priority 1 clearing is not necessarily going to be funded

– Review Priority 1 areas carefully



SNOW REMOVAL EQUIPMENT



www.faa.gov/airports/aip/procurement/



Equipment Procurement

AIP participation in the procurement of equipment is limited to approved items.

Operational equipment is not eligible under the AIP, Operational equipment may be available thru the GSAXcess surplus property program.

Documents

By: Nancy S. Williams Date:March 4, 2010 Federal Aviation Administration Eligibility of Safety, Security and Snow Removal Equipment Under AIP