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Federal Aviation
Administration
Airport Coronavirus Response Grant Program
Frequently Asked Questions
This document answers frequently asked questions (FAQs) stakeholders may have related to the
approximately $2 billion in grants for airports under the Coronavirus Response and Relief
Supplemental Appropriation Act, 2021 (CRRSA).
The Federal Aviation Administration (FAA) has additional information for airport sponsors
concerning COVID-19 available at www.faa.gov/airports.
The guidance here is not legally binding in its own right, and the FAA will not rely on it as a
separate basis for affirmative enforcement action or other administrative penalties. Conformity
with this guidance, as distinct from existing statutes, regulations, and grant assurances, is
voluntary only, and nonconformity will not affect existing rights and obligations.
In addition to these grants, the FAA is administering approximately $10 billion in grants for
airports under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. For
information on CARES Act funding, please visit https://www.faa.gov/airports/cares_act/.
For questions related to either the CARES or CRRSA programs, please email
This update questions Q-U2, Q-GA12, Q-GA13, Q-GA16, Q-GA17, Q-I1, Q-I2, Q-C1, and
Q-CR17.
These FAQs will be updated periodically.
Subjects Addressed Below
General Questions ........................................................................................................................... 2
Questions of Allocation of Funds ................................................................................................... 3
Questions on Use of Funds ............................................................................................................. 5
Questions on Grant Application and Agreement ............................................................................ 8
Questions on Invoicing and Payments .......................................................................................... 11
Questions on Grant Closeout ........................................................................................................ 13
Questions on Environmental Review ............................................................................................ 14
Questions on Administration under the State Block Grant Program ............................................ 15
Questions on Funding for Airports in the FAA Contract Tower Program ................................... 17
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Questions on Funding for Concession Relief ............................................................................... 17
Questions on Workforce Retention ............................................................................................... 22
General Questions
Q1: How does the Coronavirus Response and Relief Supplemental Appropriation
Act benefit airports and airport concessions?
A: On December 27, 2020, the President signed the Consolidated Appropriations Act,
2021. Division M of that Act is the Coronavirus Response and Relief Supplemental
Appropriation Act, 2021 (CRRSA). Title IV of CRRSA provides approximately $2
billion in economic relief to airports to prevent, prepare for, and respond to the
COVID-19 pandemic, including relief from rent and minimum annual guarantees
(MAG) for eligible airport concessions at primary airports.
Q2: Where is this funding coming from?
A: The funds are coming directly from the U.S. Treasury’s General Fund to prevent,
prepare for, and respond to the impacts of the COVID-19 pandemic. The FAA’s
Office of Airports will administer these grant funds to airport sponsors.
Q3: Who is eligible to receive funding under CRRSA?
A: CRRSA funds are available to most sponsors as defined in section 47102 of title 49,
United States Code (U.S.C.); that is, airport sponsors meeting statutory and policy
requirements under this section and identified in the FAA’s current National Plan of
Integrated Airport Systems (NPIAS).
A portion of the funds available under CRRSA is for the Small Community Air
Service Development Program (SCASDP), which is administered by the Office of the
Secretary of Transportation (OST). More information about SCASDP can be found
at https://www.transportation.gov/policy/aviation-policy/small-community-rural-air-
service/SCASDP.
Q4: Are any airport sponsors not eligible to receive funding under CRRSA?
A: CRRSA prohibits funding for any airport that was allocated more than four times its
annual operating expenses under the CARES Act (Public Law 116-136). The FAA
used airports’ reported fiscal year (FY) 2018 operating expenses to determine
allocations. This prohibition affects 31 airports, and their respective CRRSA
allocations will be zero when the FAA announces award allocations.
Q5: What is the period of availability for the FAA to obligate CRRSA funding?
A: Funds are available until September 30, 2021, and must be obligated by that date.
The FAA intends to award grants and obligate these funds on an expedited basis.
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Q6: Are airport sponsors in the Republic of the Marshall Islands, Federated States of
Micronesia, Republic of Palau, and Wake Island eligible for the Airport
Coronavirus Response Grant Program?
A: No. CRRSA states only sponsors of airports in categories defined in 49 U.S.C. 47102
are eligible. Eligible airports are included in the NPIAS. Airports in the Republic of
the Marshall Islands, Federated States of Micronesia, Republic of Palau, and Wake
Island are not included in the NPIAS. While these airport sponsors may be eligible
for some Airport Improvement Program (AIP) discretionary funding, they are not
eligible under CRRSA.
Q7: Are airports in U.S. territories eligible for the Airport Coronavirus Response
Grant Program?
A: Yes. CRRSA states only sponsors of airports in categories defined in 49 U.S.C.
47102 are eligible. Eligible airports are included in the NPIAS. Airports in U.S.
territories (American Samoa, Northern Mariana Islands, Puerto Rico, the U.S. Virgin
Islands, and Guam) are included in the NPIAS.
Q8: Can an airport sponsor use the Airport Coronavirus Response Grant Program
funding and funding from other Federal programs to pay for expenses related to
the COVID-19 pandemic?
A: A sponsor may use Airport Coronavirus Response Grant Program grants for airport
operating expenses that arise due to the COVID-19 pandemic. The FAA recognizes
that several sources of COVID-19 relief funds may be available to airport sponsors.
Airport sponsors may use other sources of funding consistent with the terms of those
programs. However, an airport sponsor may not invoice under its grant for expenses
that have been reimbursed under another program.
Questions on Allocation of Funds
Q-F1: How will this funding be allocated to airport sponsors?
A: CRRSA divides the $2 billion funding into four groups by a formula that results in
specific allocations to each eligible airport. The grants for these four groups are not
discretionary. The four groups (not including SCASDP, which is administered by
OST) are:
Primary Commercial Service Airports and Certain Cargo Airports share not
less than $1.75 billion based first on the statutory (AIP) primary and cargo
entitlement formulas. However, the $26-million limit under 49 U.S.C.
47114(c)(1)(C)(iii) and reduction for imposing passenger facility charges
under 49 U.S.C. 47114(f) do not apply to these allocations. After allocating
based on the statutory entitlement formulas, the remainder is then allocated
based on the number of enplanements the airport had in the most recent
calendar year (CY) of available enplanement data, which is the CY 2019, as a
percentage of total 2019 enplanements for all primary airports. Sponsors may
use these funds for costs related to operations, personnel, cleaning,
sanitization, janitorial services, combating the spread of pathogens at the
airport, and debt service payments.
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Non-Primary Commercial Service and General Aviation Airports share not
less than $45 million (less the amount allocated for non-primary airports
participating in the FAA Contract Tower [FCT] Program) allocated based on
the categories (National, Regional, Local, and Basic) published in the most
current NPIAS, reflecting the percentage of the aggregate published eligible
development costs for each such category, and then dividing the allocated
funds evenly among the eligible airports in each category, rounded up to the
nearest thousand. Sponsors may use these funds for costs related to
operations, personnel, cleaning, sanitization, janitorial services, combating the
spread of pathogens at the airport, and debt service payments.
Non-Primary Airports Participating in the FCT Program share not less than $5
million of the $45 million available to non-primary airports. These funds are
divided equally among eligible airports. Sponsors may use these funds to
cover lawful expenses to support the FCT operations. More information on
the FCT Program is available at
https://www.faa.gov/about/office_org/headquarters_offices/ato/service_units/
mission_support/faa_contract_tower_program/.
Primary Commercial Service Airports share not less than $200 million
allocated based on the number of enplanements the airport had in CY 2019 as
a percentage of total CY 2019 enplanements for all primary airports.
Sponsors may use these funds to provide relief from rent and MAG to on-
airport car rental, on-airport parking, and in-terminal airport concessions.
Q-F2: How will the FAA handle unallocated funds remaining under the CARES Act?
A: There are some remaining funds under the CARES Act that the FAA did not allocate.
Additionally, a limited amount of allocated CARES Act funds were declined by
eligible airport sponsors. CRRSA requires these funds to be allocated to primary
airports based on the most recent calendar year of available data, which is CY 2019,
as described in Q-F1. The FAA intends to announce the final total of unallocated
CARES Act funds and the re-allocation totals in the near future. The FAA will work
with airport sponsors to make these additional funds available for expenditure.
Q-F3: How did the FAA use the NPIAS airport categorization to determine CRRSA
allocations for non-primary airport sponsors?
A: Under CRRSA, not less than $45 million was allocated to non-primary airports based
on the categories in the National Plan of Integrated Airport Systems (NPIAS) 2021-
2025, issued September 30, 2020, updated to reflect the current status for FY
2021. The FAA Order 5090.5, Formulation of the NPIAS and ACIP, defines the
criteria for each category or role.
Q-F4: Why do airports with a NPIAS category of Unclassified not receive an allocation
under CRRSA?
A: CRRSA allocates funds for non-primary airports based on the percentage of the
aggregate published eligible development costs for each category that is then divided
evenly among eligible airports in each category. As documented in the NPIAS 2021-
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2025, consistent with their role in the national airport system, unclassified airports
have no development needs identified through 2025.
Q-F5: Do airport sponsors have to contribute a local match for the Airport
Coronavirus Response Grant Program?
A: No. Grants under the Airport Coronavirus Response Grant Program are available at a
100% Federal share.
Q-F6: Will FY 2021 AIP or Supplemental Discretionary grants be made at a 100%
share?
A: No. CRRSA did not provide funding to increase the Federal share of FY 2021 AIP or
Supplemental Discretionary grants.
Questions on Use of Funds
Q-U1: How can an airport sponsor use Airport Coronavirus Response Grant Program
funds?
A: An airport sponsor may use these funds for costs related to operations, personnel,
cleaning, sanitization, janitorial services, combating the spread of pathogens at the
airport, and debt service payments. Grant recipients should follow the FAA’s Policy
and Procedures Concerning the Use of Airport Revenues (“Revenue Use Policy”), 64
Federal Register 7696 (64 FR 7696), as amended by 79 Federal Register 66282 (79
FR 66282). The Revenue Use Policy document provides guidance regarding
permitted and prohibited uses of airport revenue. In addition, while CRRSA limits
the use of funds to certain stated eligible costs, it states that funds may not be used for
any purpose not directly related to the airport. Grant recipients also should review the
Information for Airport Sponsors Considering COVID-19 Restrictions or
Accommodations for clarifying COVID-19 revenue use guidance.
Q-U2: Can Airport Coronavirus Response Grant Program funds be used to reimburse
operational expenses?
A: Yes. The FAA will reimburse sponsors for operational expenses directly related to
the airport incurred on or after January 20, 2020. Operational expenses are those
expenses necessary to operate, maintain, and manage an airport. They include
expenses such as payroll, utilities, service contracts, and items generally having a
limited useful life, including personal protective equipment and cleaning supplies.
Maintenance and repairs are limited to a project necessary to keep an asset in good
working order but do not add material value or appreciably prolong the life of the
asset.
Q-U3: Can Airport Coronavirus Response Grant Program funds be used to reimburse
debt service payments?
A: Yes. The FAA will reimburse sponsors for debt service payments directly related to
the airport that are due on or after December 27, 2020, which is the date of enactment
of CRRSA.
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Q-U4: Can Airport Coronavirus Response Grant Program funds be used to reimburse
monthly payments into a debt service reserve fund?
A: Yes. The FAA will reimburse sponsors for monthly payments into a debt service
reserve fund (also called a debt service sinking fund or similar name), which are
directly related to the airport, that are due on or after December 27, 2020, which is the
date of enactment of CRRSA. The airport sponsor must ensure that these payments
are restricted to only debt service payments. The airport sponsor will submit a
detailed invoice summary with its payment request. All documentation of the
payment and disbursements must be retained for three years after the grant is closed,
as required by 2 (Code of Federal Regulations) CFR § 200.334.
Q-U5: Can Airport Coronavirus Response Grant Program funds be used for new
airport development on the airport?
A: Yes. However, there are limitations on the type of development for which the
funding can be used. Any development-related costs must be associated with
combating the spread of pathogens at the airport. Examples of eligible development
would be replacing or upgrading a heating, ventilation, and air conditioning (HVAC)
system; reconfiguring the terminal to accommodate increased social distancing, or
reconfiguring terminal space or other facilities to accommodate health screening. A
sponsor seeking to use the funds for new airport development or construction should
contact its local Airports District Office or Airports Regional Office. That office will
ensure that such development is consistent with the requirements for airport
development. The Airports District Office or Airports Regional Office also will
assist the airport sponsor with executing a Development Addendum for its intended
project.
Q-U6: Can Airport Coronavirus Response Grant Program funds be used to prepay
long-term contracts (for example, shuttle-bus operators, janitorial services,
security services, fire and police services)?
A: Yes, provided the prepayment is a bona fide transaction where the airport sponsor
receives the benefit of the prepaid services and receives some value in exchange for
committing in advance.
Q-U7: Can Airport Coronavirus Response Grant Program funds be deposited in the
airport sponsor’s general reserve account (or invested for future use)?
A: No. The FAA would not be able to ensure a potential future use is a use consistent
with CRRSA requirements.
Q-U8: Is there a limit on using Airport Coronavirus Response Grant Program funds
for operational expenses?
A: No. An airport sponsor may use all of its awarded funds for allowable airport
operational expenses or debt service payments.
Q-U9: Can Airport Coronavirus Response Grant Program funds be used to reimburse
for a cost associated with an aeronautical service or product provided by the
airport sponsor?
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A: Yes, in certain circumstances. Airport Coronavirus Response Grant Program funds
are available to reimburse the costs associated with aeronautical products or services
offered by the airport sponsor but only when the sponsor certifies it is the only
provider of the same product or service at the airport. These services include aviation
fuels, equipment, parts, supplies, and facilities for aircraft storage or maintenance.
Costs associated with flight training or aviation training are not eligible for
reimbursement.
Q-U10: Can Airport Coronavirus Response Grant Program funds be used to reimburse
depreciation?
A: No. Depreciation is not an allowable expense under the Airport Coronavirus
Response Grant Program. Although depreciation is an allowable operating expense
by both the 2 CFR part 200 and the Revenue Use Policy, it does not impact cash flow
because the cash or donation was considered at the acquisition of the asset, and the
asset could have been financed by long-term debt, Federal grants, current funds, or
donation.
Q-U11: Can the Airport Coronavirus Response Grant Program funds be used to
reimburse charitable contributions or sponsorships?
A: No. Charitable contributions and sponsorships are not allowable expenses. All
reimbursements made under the Airport Coronavirus Response Grant Program must
comply with 2 CFR part 200, “Uniform Administrative, Cost Principles, and Audit
Requirements for Federal Awards.” Section 200.434, “Contributions and Donations,”
states that contributions and donations, including cash, property, and services, are
unallowable.
Q-U12: Can Airport Coronavirus Response Grant Program funds be used to reimburse
economic development efforts?
A: No. Under CRRSA, funds are available for costs related to operations, personnel,
cleaning, sanitization, janitorial services, combating the spread of pathogens at the
airport, and debt service payments. Economic development does not fall into these
categories of eligible costs.
Q-U13: Can Airport Coronavirus Response Grant Program funds be used to reimburse
smaller invoices for items such as groceries for snack rooms or meals for airport
personnel?
A: As long as the purchases are for purposes eligible under CRRSA (as described in Q-
U1) and comply with 2 CFR part 200, including the requirement to document the
costs adequately, small purchases are eligible for reimbursement. However, it can be
difficult to document that these items are directly related to airport use. Larger
invoices directly related to airport use are easier to review and approve.
Q-U14: Can Airport Coronavirus Response Grant Program funds be used to reimburse
debt service payments that are backed by an approved Passenger Facility
Charge (PFC) and paid with PFC funds?
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A: No. If PFC funds are available, the PFC funds must be used on any approved PFC
project. Airport Coronavirus Response Grant Program funds are not available to be
deposited into PFC accounts. In accordance with 14 CFR § 158.39, public agencies
cannot hold excess PFC funds in reserve for future use. In addition, the requirements
of 14 CFR part 158 apply to any new projects or changes in scope to existing
projects.
Q-U15: Can Airport Coronavirus Response Grant Program funds be used to reimburse
debt service payments that are backed by an approved PFC?
A: Yes. The airport sponsor may supplement with other airport revenue and submit a
request for payment under its grant. The invoice summary should show the amount
of debt service paid with PFC collections and the amount paid with non-PFC funds.
The airport sponsor can submit a request for payment under its grant at the same time
it submits an amendment to an approved PFC, which decreases the total collection or
deletes an approved project, to its local Airports District Office or Airports Regional
Office.
Q-U16: Can Airport Coronavirus Response Grant Program funds be used to reimburse
the defeasement of debt backed by an approved PFC?
A: Yes. The airport sponsor can defease the debt with non-PFC funds and submit a
request for payment under its grant. However, the airport sponsor must amend its
PFC approval in accordance with the requirements of 14 CFR § 158.37, to reflect the
change. A PFC amendment that decreases the total PFC revenue or deletes an
approved project does not require airline consultation or a public comment period.
An airport sponsor can submit a request for payment under its grant at the same time
it submits an amendment to an approved PFC to its local Airports District Office or
Airports Regional Office.
Questions on Grant Application and Agreement
Q-GA1: Is a grant application required to receive the Airport Coronavirus Response
Grant Program funds?
A: Yes. After Airport Coronavirus Response Grant Program awards are announced, the
FAA personnel will reach out to each airport sponsor to provide an opportunity to
apply for grants. An airport sponsor may contact its Airports District Office or
Airports Regional Office if it seeks specific guidance on its grant application.
Q-GA2: When will grant applications be available, and how long after filing a complete
application should an airport sponsor expect to receive a grant?
A: The FAA will provide these applications to airport sponsors through the local
Airports District Office or Airports Regional Office shortly after Airport Coronavirus
Response Grant Program awards are announced. The FAA anticipates providing a
grant agreement for execution within days of receiving a complete application.
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Q-GA3: Will the FAA use a standard grant application form or one specifically designed
for this program?
A: The FAA will use the SF-424, Application for Federal Assistance.
Q-GA4: Is there a deadline for submitting an application for an Airport Coronavirus
Response Grant Program grant?
A: Yes. The deadline to apply for a grant is June 30, 2021. After that date, the FAA will
reallocate any unobligated funds to primary airports based on CY 2019 enplanements
as indicated under CRRSA. (See Q-F1)
Q-GA5: If an airport sponsor owns or operates multiple airports, may Airport
Coronavirus Response Grant Program funds be pooled?
A: No. An airport sponsor will need to apply for a separate grant for each airport under
its control.
Q-GA6: Is there a deadline by which funds must be used?
A: Yes. The budget period for the Airport Coronavirus Response Grant Program is four
years. Pursuant to 2 CFR § 200.403(h), a sponsor may charge to the grant only
allowable costs incurred during the budget period.
Q-GA7: Will the FAA use a standard AIP grant agreement or one specifically designed
for the Airport Coronavirus Response Grant Program?
A: The FAA will provide a simplified Grant Agreement shortly after it receives an
application. This simplified agreement includes the requirements under CRRSA and
makes funds immediately available for expenses other than airport development,
including payroll, debt service, utility expenses, service contracts, and supplies.
Q-GA8: Does an Airport Coronavirus Response Grant Program grant agreement require
an airport sponsor to obligate itself to the standard set of FAA Airport Sponsor
Grant Assurances?
A: Generally, no. If an airport sponsor uses its grant for operational expenses or debt
service payments, the standard FAA Airport Sponsor Grant Assurances do not apply.
These grants remain subject to audit, reporting, records retention, and other
requirements under 2 CFR part 200, like other Federal grant funding. Other Federal
statutes may also apply, such as 49 U.S.C. 40103(e), which prohibits the grant of an
exclusive right to conduct any type of aeronautical activity at an airport, and Title VI
of the Civil Rights Act, which prohibits discrimination on the basis of race, color, or
national origin. If an airport sponsor uses its grant for new airport development,
additional requirements apply (see Q-U5). Additionally, grant funds may be used
only for the capital and operating expenses of the airport. Examples of expenditures
that the FAA has found to be allowable are provided in the FAA Revenue Use Policy,
as clarified by Information for Airport Sponsors Considering COVID-19 Restrictions
or Accommodations. CRRSA does not, however, void assurances made in prior grant
agreements; therefore, a sponsor’s pre-existing grant assurances and Federal
obligations continue to apply.
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Q-GA9: How long do the grant assurances remain in effect for an Airport Coronavirus
Response Grant Program grant agreement?
A: The grant assurances remain in effect for four years from the date of acceptance of
the grant offer, which is consistent with the budget period.
Q-GA10: How does an airport sponsor use Airport Coronavirus Response Grant Program
funds for airport development?
A: Funding eligibility under CRRSA for airport development is limited (as discussed in
Q-U5). However, an airport sponsor seeking to use its grant funds for eligible near-
term airport development may amend its initial Grant Agreement and execute a
Development Addendum. This process ensures that a sponsor understands the
additional reviews and requirements involved (as discussed in Q-U5). An airport
sponsor should be able to complete airport development projects within the four-year
budget period of its initial grant. An airport sponsor should not delay or forgo the
expenditure of grant funds for ongoing airport operational expenses and debt service
payments, which are the primary purposes of funds under CRRSA.
Q-GA11: Should an airport sponsor request its full Airport Coronavirus Response Grant
Program award amount even if it intends to use a portion of those funds for
airport development?
A: Yes. An airport sponsor should include the full award amount in its grant application.
All funds would then be available immediately for operational expenses or debt
service payments. An airport sponsor can later request a Development Addendum
and use some of those funds for airport development.
Q-GA12: What information is required for a Development Addendum?
A: An airport sponsor seeking to use its grant funds for airport development should be
prepared to provide its local Airports District Office or Airports Regional Office with
the following information:
Application form (Application for Federal Assistance, SF-424) for the
proposed development project;
A description of the project;
Actual costs; and
Timeline for completion.
An airport sponsor should also complete the following steps for the airport
development project:
Complete any standards, airspace, and environmental reviews or approvals,
including airport geometry assessments, if applicable;
Complete any other approvals required for the development with the FAA and
other agencies;
Ensure the proposed development is consistent with the approved Airport
Layout Plan (ALP) and depicted on the ALP;
Initiate safety-risk and construction phasing reviews, if applicable; and
Bid the project to determine the amount to be amended from the initial Grant
Agreement and added to the Development Addendum.
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The FAA recognizes that some proposed development projects have completed many
or all of these steps, and those projects may be most suitable for a Development
Addendum. Grant agreements for these proposed development projects will include
additional requirements as described in Q-U5.
Q-GA13: Is a Development Addendum required for maintenance on existing airport
facilities (e.g., a terminal building)?
A: Examples of maintenance projects may include repairing roofing or replacing carpet
or lighting; these projects do not require a Development Addendum. However, the
FAA would issue a Development Addendum if an existing facility is improved or
expanded, provided the project is eligible under CRRSA.
Q-GA14: Do prevailing wage requirements apply to contract expenses reimbursed with
Airport Coronavirus Response Grant Program funds?
A: Grants under the Airport Coronavirus Response Grant Program are subject to the
requirements of 49 U.S.C. 47112(b). Therefore, any contract for more than $2,000
involving labor for airport construction or repair, carried out under a Grant
Agreement or Development Addendum, requires contractors to pay labor minimum
wage rates as determined by the Secretary of Labor under 40 U.S.C. 3141–3144,
3146, and 3147.
Q-GA15: Does the FAA’s Buy American requirement apply to the Airport Coronavirus
Response Grant Program?
A: Yes. Grants under the Airport Coronavirus Response Grant Program are subject to
the requirements of 49 U.S.C. 50101, and grant agreements and addendums include
Buy American requirements for all projects. The Buy American provision does not
apply to operational expenses (as defined in Question Q-U2) and debt service
payments.
Q-GA16: Are there annual financial reporting requirements associated with the Airport
Coronavirus Response Grant Program?
A: Yes. In accordance with 2 CFR § 200.328, an airport sponsor must annually submit
an SF-425, Federal Financial Report, for each open Grant Agreement or Development
Addendum. An airport sponsor should send this SF-425 report to
[email protected] by December 31 of each year, and the report should cover
the period from October 1 through September 30, consistent with the Federal fiscal
year. An airport sponsor with a Development Addendum must also annually submit
an SF-271, Outlay Report, and Request for Reimbursement for Construction
Program, by December 31 of each year. An airport sponsor should send this SF-271
report to the FAA grant manager.
Q-GA17: Are there any requirements related to mandating masks inside airports
associated with the Airport Coronavirus Response Grant Program?
A: Yes. Under Executive Order 13998, Promoting COVID-19 Safety in Domestic and
International Travel (Executive Order 13998), issued on January 21, 2021, the
Secretary of Transportation must require masks to be worn in compliance with the
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CDC Order in airports, consistent with applicable law. To accomplish this
requirement, and to achieve the legislative purposes of preventing and responding to
coronavirus disease 2019 (COVID-19), each Airport Coronavirus Response Grant
Program grant agreement will include a special condition that the airport sponsor
implements a policy requiring all persons wear a mask, in accordance with the CDC
Order and TSA Security Directive, as applicable, at all times while in all public areas
of the airport property, except to the extent exempted under those requirements. The
CDC and TSA requirements exempt certain categories of persons from the mask-
wearing mandate: a child under the age of two, a person with a disability who cannot
wear or safely wear a mask because of the disability, or a person for whom wearing a
mask would create a risk to workplace safety, health, or job duties. This special
condition is only in effect while Executive Order 13998 is operable. For Department
of Transportation guidance on masks, see
https://www.transit.dot.gov/TransitMaskUp.
Questions on Invoicing and Payments
Q-I1: How will an airport sponsor submit payment requests for Airport Coronavirus
Response Grants for payment requests other than for concession relief?
A: The FAA uses the U.S. Department of Transportation Delphi eInvoicing system for
payment requests. Payment processes for concession relief grants are discussed
starting at Q-CR1 below. The FAA reviews all CARES Act Airport Grant payment
requests manually. Although the FAA previously allowed airport sponsors to submit
only a detailed invoice summary with its payment request, following a recent FAA
program risk assessment, the FAA now requires supporting documentation (see Q-I2)
for all expenses except payroll and debt service expenses. This supporting
documentation is required for all payment requests submitted after January 17, 2023,
the date of this publication. The invoice summary should include enough detail to
permit the FAA to verify compliance with the FAA’s Revenue Use Policy and, at a
minimum, the following information:
Grant Number
Airport Name
Airport City
Airport Location Identifier
Services Rendered Dates
Invoice Paid Date
Vendor Name
Billed Amount
Payment Request Amount
Short summary of expenses billed, including, for example:
o Payroll
o Utilities (electric, water, phone)
o Service contracts (include type of work)
o Goods Purchase (include a list of all items purchased)
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o Debt Service Payment (identify whether this is a semi-annual bond
payment or monthly payment into a debt service reserve fund)
o Other (explanation of costs and how they are eligible and related to the
airport)
For payroll and debt service expenses, sponsors must be prepared to submit any
supporting documentation, upon request, during the review process. In addition,
airport sponsors must retain all invoices and other supporting documentation for three
years after the grant is closed, as required by 2 CFR § 200.334.
Q-I2: What type of documentation does the FAA require with an invoice summary?
A: Examples of supporting documentation include, but are not limited to, the following:
Invoices (demonstrating that the goods or services provided directly relate to
the airport);
Bills (demonstrating that the goods or services provided directly relate to the
airport);
Payroll reports from the payroll system of record;
General ledger reports and subsidiary ledger reports for services provided by
the sponsor;
Current and approved indirect cost rate agreement; or
Most recently approved local or statewide cost allocation plan.
All supporting documentation should include a date demonstrating that payment was
paid on or after January 20, 2020, for operating expenses, or on or after December 27,
2020, for debt service payments. A sponsor must retain all supporting documentation
for three years after the grant is closed, as required by 2 CFR § 200.334.
Q-I3: Can an airport sponsor request 100 percent of the available Airport
Coronavirus Response Grant Program funds and use the funds to pay expenses
over the next several months?
A: No. An airport sponsor must submit payment requests for incurred expenses only.
Requesting funds for reimbursement prior to incurring the invoiced expense is not
consistent with the FAA’s Payment Policy and will result in an improper payment
that may have to be repaid.
Q-I4: Should airport sponsors submit separate payment requests for expenses related
to the FCT operations?
A: Yes. Separate payment requests should be submitted for the FAA FCT operations
expenses to ensure these payments are processed against the correct funds.
Additional information regarding the FCT funding is provided in Q-CT2 and Q-CT3.
Questions on Grant Closeout
Q-C1: What are the procedures for closing out an Airport Coronavirus Response
Grant for non-development expenses?
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A: An airport sponsor will submit a signed closeout report via the U.S. Department of
Transportation Delphi eInvoicing system. The report summarizes the categories of
expenses covered under the grant and the associated amounts and certifies all:
Expenses were incurred in accordance with the FAA’s Revenue Use Policy,
the CRRSA Act, and 2 CFR part 200;
Relief from rent and MAG for concessions, if applicable, was provided on or
after December 27, 2020;
Operational expenses, if applicable, reimbursed were paid on or after
January 20, 2020;
Debt service payments, if applicable, reimbursed were due on or after
December 27, 2020;
Terms and conditions of the Airport Coronavirus Response Grant and
subsequent addenda were complied with;
Expenses requested for reimbursement that were included in an approved PFC
application were reimbursed only after a PFC amendment was submitted to
the FAA and approved;
Payment requests did not include costs (e.g., payroll, utilities, rent, or support
services) that were reimbursed under or included as part of an Airport
Improvement Program (AIP) grant as indirect costs; and
Payment requests did not include costs (e.g., payroll, utilities, rent, or support
services) that were reimbursed under or included as part of an AIP grant as
administrative or force account costs.
An airport sponsor will submit a signed closeout report and a completed Standard
Form 425, Federal Financial Report, with its final payment request. The FAA will
review these documents prior to processing the final reimbursement. A sample
Airport Coronavirus Response Grant Program Closeout Report is available.
Q-C2: Will an airport sponsor be notified that its Airport Coronavirus Response Grant
is closed?
A: An airport sponsor will receive a grant closeout letter from the FAA stating the grant
has been closed. After the grant is closed, it remains subject to audit. The airport
sponsor must retain grant documentation for three years after the grant is closed, as
required by 2 CFR § 200.334.
Questions on Environmental Review
Q-E1: Are there any environmental review requirements associated with non-
construction grants for airport operating expenses and debt service payments?
A: No. These types of grants have no potential to impact the environment and are not
subject to National Environmental Policy Act (NEPA) review.
Q-E2: Are there any environmental review requirements associated with projects
funded under a Development Addendum?
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A: Yes. The FAA will conduct an environmental review as necessary, consistent with
the requirements of the Council on Environmental Quality (CEQ) regulations in 40
CFR parts 1500 through 1508 and the FAA’s NEPA implementation procedures. An
airport sponsor should contact its Airports District Office or Airports Regional Office
to determine the appropriate scope and level of environmental analysis.
Questions on Administration under the State Block Grant Program
Q-SB1: What is the State Block Grant Program (SBGP)?
A: In 1987, Congress authorized the FAA to use State block grants to provide AIP funds
to airport sponsors. Through the SBGP, the FAA provides funds directly to States
that participate in the program. In turn, SBGP participants fund and oversee AIP
projects for non-primary commercial service, reliever, and general aviation airports.
The program currently includes the following 10 States: Georgia, Illinois, Michigan,
Missouri, New Hampshire, North Carolina, Pennsylvania, Tennessee, Texas, and
Wisconsin.
Q-SB2: How will the FAA Administer CRRSA funding for States participating in the
SBGP?
A: The FAA Airport Improvement Program Branch (APP-520) will use its existing
relationships with the States participating in the SBGP for the administration of the
Airport Coronavirus Response Grant Program. These participants have relationships
with airport sponsors within their States and currently provide grant management and
internal controls. Leveraging this infrastructure will facilitate efficient and expedient
distribution of funds.
Q-SB3: Will the FAA Regional and Airport District Offices remain the points of contact
for the Airport Coronavirus Response Grant Program?
A: Yes. States participating in the SBGP should continue to work with their local
Airports District Office or Airports Regional Office throughout implementation and
administration.
Q-SB4: Do Airport Coronavirus Response Grant Program funding allocations work
differently for the SBGP?
A: No. The FAA will calculate each airport sponsor’s allocation based on formulas in
CRRSA. The FAA will announce these award amounts along with all awards under
the Airport Coronavirus Response Grant Program.
Q-SB5: How much CRRSA funding may States participating in the SBGP distribute?
A: CRRSA provides specific allocations to each airport sponsor. The FAA will
aggregate the amounts announced for each airport sponsor into respective State
awards.
Q-SB6: How may States participating in the SBGP allocate the Airport Coronavirus
Response Grant Program funds?
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A: States participating in the SBGP must make sub-awards to each airport sponsor based
on that sponsor’s allocation under CRRSA. The FAA expects States to make these
sub-awards on an expedited basis and for airport sponsors to spend funds quickly to
reduce the adverse impacts of the current pandemic. States must follow 2 CFR part
200 requirements for grant awards and sub-awards. Funds not expended within the
four-year budget period are subject to recovery by the FAA.
Q-SB7: What application and grant agreement will be used for sub-grants?
A: States participating in the SBGP will use a streamlined application and grant
agreement process similar to what the FAA is using for all grants under the Airport
Coronavirus Response Grant Program. The FAA will provide States with template
documents after these grants are announced.
Q-SB8: What if my State legislature needs to approve the acceptance of CRRSA
funding?
A: The FAA recommends that States participating in the SBGP use their usual State
processes to approve, accept, and administer Federal funds.
Q-SB9: Can grants under the Airport Coronavirus Response Grant Program be sub-
awarded to airport sponsors that had previously opted out of the SBGP?
A: No. States participating in the SBGP do not have to make sub-awards to airport
sponsors that opted out in FY 2021 or do not participate in the SBGP. The FAA will
administer grants for those airport sponsors.
Q-SB10: What are the reporting requirements for the Airport Coronavirus Response
Grant Program?
A: States participating in the SBGP will continue the current practice of providing sub-
award reporting information on grants to the FAA upon request.
Q-SB11: Will grants under the Airport Coronavirus Response Grant Program require
end-of-fiscal-year reporting like other AIP funding?
A: Yes. Airport Coronavirus Response Grant Program funds will be included in the
Annual Report of Federal Funding at the end of FY 2021.
Q-SB12: How will payment requests be submitted for the Airport Coronavirus Response
Grant Program?
A: The FAA will use the existing U.S. Department of Transportation Delphi eInvoicing
system for payment requests. States participating in the SBGP will continue the
current practice of retaining all underlying payment request documentation and
complete records.
Q-SB13: Will the FAA audit the Airport Coronavirus Response Grant Program
administered by States participating in the SBGP?
A: Yes. The FAA will include audits of grants under the Airport Coronavirus Response
Grant Program in its annual audit process.
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Q-SB14: What documentation is needed for SBGP Airport Coronavirus Response Grant
Program drawdown requests?
A: States participating in the SBGP should provide the same documentation outlined in
Q-I1 and Q-I2. States participating in the SBGP must ensure invoices contain only
eligible items under CRRSA, as detailed throughout this document.
Questions on Funding for Airports in the FAA Contract Tower Program
Q-CT1: What is the FAA Contract Tower Program (FCT)?
A: Contract towers are air traffic control towers that are staffed by employees of private
companies rather than by FAA employees. The FCT Program was established in
1982 to allow the agency to contract out the operation of certain towers. The FAA
admits airports into this program after an eligibility review. More information about
the FCT Program is available at
https://www.faa.gov/about/office_org/headquarters_offices/ato/service_units/mission
_support/faa_contract_tower_program/.
Q-CT2: How can airport sponsors that participate in the FCT Program use the funds
they receive?
A: Under CRRSA, airport sponsors of non-primary airports that participate in the FCT
Program may use these funds to cover any lawful costs associated with supporting
their FCT operations (such as payroll, utilities, service contracts, and items generally
having a limited useful life, including personal protective equipment and cleaning
supplies).
Q- CT3: Can airport sponsors that participate in the FCT Program use other CRRSA
funds for costs related to contract tower operations?
A: Yes. Airport sponsors may use other CRRSA funding to support contract tower
operations, personnel, cleaning, sanitization, janitorial services, combating the spread
of pathogens, and debt service payments. However, they cannot use the funding
received specifically for contract towers for any other purpose.
Questions on Funding for Concession Relief
Q-CR1: How does an airport sponsor claim its allocation available to provide relief to
airport concessions?
A: An airport sponsor seeking to use CRRSA funds to provide relief from rent and MAG
obligations to eligible airport concessions may apply for that allocation in an
application for an Airport Coronavirus Response Grant Program grant
agreement. The FAA will transmit a concession relief grant application for each
primary airport receiving Airport Coronavirus Response Grant Program grants. An
airport sponsor wishing to decline its Airport Coronavirus Response Grant Program
concession relief grant(s) should not submit application(s) but rather notify its ADO
of its intent to decline.
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Q-CR2: How do airport sponsors provide relief to airport concessions?
A: If an airport sponsor accepts its CRRSA allocation for concession relief, the sponsor
must provide relief from rent and MAG to on-airport car rental, on-airport parking,
and in-terminal airport concessions (as defined in 49 CFR part 23) (collectively,
“concessions”). CRRSA requires an airport sponsor to take a concession relief grant
to provide such relief on a proportional basis, described at Q-CR15, until the sponsor
has provided relief equaling the total allocation amount. The airport sponsor may
retain up to 2 percent of the allocation amount for relief administration. Only relief
associated with rent due for concession occupancy or commercial use after December
27, 2020 (the date CRRSA was enacted) is eligible for grant payment.
Q-CR3: What if State laws, local laws, or applicable trust indentures prohibit an airport
sponsor from providing relief from rent and MAG to airport concessions?
A: If an airport sponsor is prohibited from providing relief from rent and MAG, it should
decline the allocated funds before executing an Airport Coronavirus Response Grant
Program concession relief grant agreement.
Q-CR4: How does an airport sponsor allocate concession relief funds among its
concessions?
A: An airport sponsor must provide this relief to each airport concession in an amount
that reflects each eligible airport concession’s proportional share of the total amount
of rent and MAG of all eligible airport concessions at the airport. This is a set of
ratios of each eligible concession’s contribution to the total amount of rent and MAG
income remitted to the airport by all members of the eligible population of remitting
concessions. An airport sponsor must account for proportionality on 100% of the
grant allocation, but it may reserve up to 2% of the allocation to administer the relief.
An airport sponsor does not have to demonstrate proportionality for grant relief
provided beyond 100% of the grant allocation. Eligible concessions must be subject
to a valid agreement to remit rent or MAG at the specific airport after December 27,
2020, and remain a going concern (an entity that is either providing minimum
acceptable services or is otherwise ready, able, and available to provide ongoing
minimum acceptable services as agreed to with the sponsor). Guidance on planning
each airport’s associated concession relief grant payment request is provided at Q-
CR15 below.
Q-CR5: Are there other requirements for an airport sponsor to provide relief to its
concessions?
A: Airport sponsors must prioritize relief from rent and MAG to minority-owned
businesses to the extent permissible under CRRSA. Prioritization should include
timely, individual consultation with each Airport Concession Disadvantaged Business
Enterprise (ACDBE) and reasonable consideration with regard to the timing or
structure of prorated relief. Consultation with ACDBEs should reach the airport
minority-owned businesses.
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Q-CR6: Can an airport sponsor recover its administrative expenses for providing rent or
MAG relief to airport concessions?
A: Yes. An airport sponsor may retain up to 2 percent of its allocation for relief
administration.
Q-CR7: Are there requirements for an airport concession to obtain rent or MAG relief
from an airport sponsor?
A: Yes. An airport concession must certify to the airport sponsor that it has not received
a second draw or assistance for a covered loan under section 7(a)(37) of the Small
Business Act (15 U.S.C. 636(a)(37)) that has been applied toward rent or MAG.
Additionally, an airport concession receiving relief from an airport sponsor may not
apply for a covered loan under 15 U.S.C. 636(a)(37). Airport sponsors should collect
these certifications and retain them for their records in the same manner that they
retain invoices associated with its general Airport Coronavirus Response Grants. A
sample Airport Concession Certification is available.
If an airport sponsor becomes aware that a concession is ineligible for concessions
relief under an Airport Coronavirus Response Grant, the airport sponsor is
responsible for addressing any improper relief benefit. Federal funds may not be
expended contrary to CRRSA requirements. The airport sponsor must notify the
FAA at [email protected] as soon as practicable after becoming aware of the
improper relief benefit. It also must allocate an amount equal to the improper relief
benefit among remaining eligible airport concessions in an amount that reflects each
eligible airport concession’s proportional share of the total amount of rent and MAG
of all eligible airport concessions at the airport, and it must re-submit the information
submitted for its payment request (see Q-CR15) showing the allocation correction.
The airport sponsor also may require re-payment of the improper relief benefit.
Q-CR8: Can an airport sponsor mix its Airport Coronavirus Response Grant Program
allocations across its primary airports receiving a concession relief allocation?
A: No. Each airport sponsor receiving Airport Coronavirus Response Grant Program
allocations for concession relief must use such funds designated for concession relief
at each primary airport in a manner consistent with the conditions and requirements
of CRRSA.
Q-CR9: Can an airport sponsor mix its Airport Coronavirus Response Grant concession
relief allocation with its general Airport Coronavirus Response Grant
allocation?
A: No. Each airport sponsor receiving Airport Coronavirus Response Grant Program
allocations for concession relief must use such funds to forgive rent from concessions
and may retain up to 2 percent for relief administration. Conversely, it must submit
costs for reimbursement from its Airport Coronavirus Response Grant general
allocation.
Q-CR10: How can an airport sponsor determine a baseline time period upon which to
calculate proportionality for rent relief amongst eligible concessions?
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A: Once an airport sponsor has determined its population of eligible concessions, it
should calculate each concession’s appropriate proportional share using an
appropriate baseline time period. The baseline time period should be relevant to the
expected duration of relief to be provided, but in no case should the baseline time
period be after the first quarter of 2020.
Q-CR11: Can an airport sponsor apply some adjustments to its proration of rent relief
due to special circumstances?
A: Yes. There are certain circumstances justifying adjustments to the rent relief
proration. For example, these include:
Only concessions paying rent at each airport for occupancy or commercial-
service activity after December 27, 2020, can receive CRRSA relief. As such,
a concession that is no longer a going concern at the airport should not be
included in the proration calculation or in the total rent income baseline unless
a new entity has replaced a departed entity with a similar location and activity.
If a current concession operating and paying rent at the airport replaced a
concession operating in the baseline time period in a like manner, the relief
proportion should be applied to the new concession.
If a current concession operating and paying rent at the airport replaced a
concession operating in the baseline time period in a like manner, but with
differing lease rates or square footage, the sponsor may make reasonable
adjustments to its proportional ratios to reflect the difference.
If a concession is replaced in a similar location but as a different service or on
significantly differing business terms, the sponsor should explain reasonable
adjustments it makes for such circumstances when requesting reimbursement.
Sponsors should make short comments relevant to simple adjustments per the
examples above. More complex adjustments for multi-factor circumstances, such as
a change in tenant, a change in rate, a change in use type, etc., may require more
explanation. See Q-CR15 for examples of reimbursement request comments.
Q-CR12: Can an airport sponsor apply some requirements upon concessions and accept
Airport Coronavirus Response Grant Program grants for concession relief?
A: Yes. Sponsors may include some valuable considerations in exchange for rent relief,
even if that rent relief is to be funded by Airport Coronavirus Response Grant
Program concession relief grants, provided these considerations are equitably applied
to all concessions at the airport. For example:
Sponsors may require certifications that each eligible concession remains a
going concern and be fully ready, able, and available to provide relevant
services, regardless of operating levels of service.
Sponsors may include phased re-opening schedules and expect cooperation
with regard to varying levels of service during periods of changing demand.
Sponsors may provide rent relief to a concession that is in arrears for rent if
the concession is providing minimum acceptable services or demonstrating
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that it is ready, able, and available to provide minimum acceptable services,
and the airport sponsor elects to provide forbearance.
Sponsors should not request concession relief reimbursement for concessions that are
not a going concern. Sponsors should not impose or induce lease terms unrelated to
those valuable and necessary considerations to enhance the coordination of operations
during the pandemic and recovery. Sponsors should not compel new lease
agreements or extensions to leases beyond the duration of occupancy correlated to the
amount of rent relief provided.
Q-CR13: Can an airport sponsor receive an Airport Coronavirus Grant Program grant
payment to cover concession rent relief that it decided to provide before
December 27, 2020?
Yes, but only to the extent that such relief covers forgiven payments of rent or MAG
for periods of occupancy and/or commercial use after December 27, 2020, and only
to the extent that the relief among concessions at each airport is proportional.
Q-CR14: Should an airport sponsor consult with its concession stakeholders on its relief
program?
Yes, the sponsor should consult with its concession community, generally, to gather
suggestions, and preview its plan. In addition, it should conduct one-on-one
consultations with ACDBEs. The sponsor cannot alter the proportionality of relief
provided but may adjust the timing or format of relief.
Q-CR15: How can an airport sponsor plan its concession relief program in order to hasten
the FAA’s approval of Airport Coronavirus Response Grant Relief concession
relief grant payments?
A: The FAA will use the existing U.S. Department of Transportation Delphi eInvoicing
system for concession relief payment requests. The FAA will review payment
requests manually. Sponsors should identify:
Each concession name, including business legal name and trade (or doing
business as) name;
Whether concession is eligible for rent relief;
ACDBE concessions;
a one-on-one consultation date (see Q-CR-14);
the date of consultation with remaining eligible concessions (see Q-CR-14);
the baseline time period used to calculate proportional share (see Q-CR10);
any consideration received in exchange for relief (see Q-CR12);
date of airport concession certification (see Q-CR7);
any concession that certified taking a Paycheck Protection Program (PPP)
second draw loan, and whether that PPP second draw loan was used for rent
or MAG, if applicable (see Q-CR7); and
any special circumstances or adjustments made to the allocation (see Q-
CR11).
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A payment request should include the information identified above and the
administration fee retained by the sponsor, not to exceed 2% of the allocation. A
sample Airport Concessions Relief Plan is available.
An airport sponsor may submit a payment request for the full or partial amount on the
concessions rent relief grant. The plan should demonstrate that the total amount of
rent relief provided by the sponsor equals the grant amount or more. When
requesting the full grant amount, an airport sponsor also should include a signed SF-
425, Federal Financial Report, and signed closeout report. A sample Airport
Coronavirus Response Grant Program Closeout Report is available. Sponsors must
be prepared to submit additional documentation, upon request, during the review
process, as well as retain all supporting documentation for three years after the grant
is closed, as required by 2 CFR § 200.334.
Q-CR16: Can an airport sponsor exclude a newly operating concession from the relief
allocation?
A: An airport sponsor may exclude from the rent relief allocation any concession that
began operations at the airport after January XX, 2023, the date this guidance was
published. The FAA presumes new entrants have negotiated terms that account for
the COVID-19 pandemic.
Q-CR17: How does an airport sponsor handle unexpended rent relief credit?
A: The FAA acknowledges, in limited circumstances, an eligible concession may receive
the benefit of only a portion, or no portion, of its proportional allocation (e.g., the
concession ceases operations at the airport before the full rent relief allocation is
credited or ceased operations before any rent relief is credited). The sponsor must
allocate proportionally any remaining funds among other eligible concessions. In
these circumstances, the sponsor should update its airport concessions rent relief plan
explaining the changed circumstances and adjusted allocations and submit it to the
FAA at [email protected] as soon as practicable.
Questions on Workforce Retention
Q-WF1: Are there specific workforce retention requirements for accepting Airport
Coronavirus Response Grant Program funds?
A: Yes. A sponsor of a small, medium, or large hub airport must continue to employ,
through February 15, 2021, at least 90% of the number of individuals employed (after
making adjustments for retirements or voluntary employee separations) as of March
27, 2020. This requirement is an extension of the workforce retention requirement
under the CARES Act. Airport sponsors must certify compliance with the CARES
Act and CRRSA workforce retention requirements at the time of grant execution.
The workforce retention requirement does not apply to non-hub or non-primary
airports.
Q-WF2: When do small, medium, and large hub airport sponsors report their respective
compliance with the employee retention requirement?
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A: Provided an airport sponsor is current with its workforce retention reporting under the
CARES Act, it must report only employment totals as of February 15, 2021, by no
later than March 1, 2021.
Q-WF3: Where should CRRSA workforce retention reports be submitted?
A: CRRSA workforce retention reports should be submitted to
[email protected]. Please include “Workforce Retention Report” and your
airport’s city, State, and airport location identifier in the email subject line.
Q-WF4: What information must be included in a workforce retention report and
certification?
A: That report and certification should include the number of full-time equivalent (FTE)
employees working at the airport as of March 27, 2020, as the baseline comparison.
Airport sponsors do not need to count contractors providing services other than
airport management, tenants, or concessionaires. Airport sponsors may make
adjustments for employees who perform duties at both the airport and other facilities
operated by the airport sponsor. Airport sponsors also may make adjustments for
retirements or voluntary employee separations when calculating the workforce
retention percentage. If an airport sponsor has unique circumstances (such as using
seasonal employees or contractors for airport management or operations), it should
report that information in as much detail as possible in the initial report so any
subsequent retention reporting can be substantiated.
Q-WF5: What format is required for CRRSA workforce retention reports?
A: There is no particular format for reporting baseline and quarterly workforce retention
counts. Airport sponsor personnel with appropriate knowledge or authority, such as
the human resources director, chief financial officer, or payroll officer, should
validate the information.
Q-WF6: Are payroll records or any other documentation required for workforce
retention reports?
A: Airport sponsors do not need to submit payroll records. However, airport sponsors
must retain all supporting documentation for three years after the grant is closed, as
required by 2 CFR § 200.334.
Q-WF7: Are waivers from the CRRSA workforce retention requirement available?
A: The Secretary of Transportation may waive the workforce retention requirement if the
Secretary determines that the sponsor is experiencing economic hardship as a direct
result of the requirement or that the requirement reduces aviation safety or security.
To request a waiver of the CRRSA workforce retention requirement, an airport
sponsor should send a waiver request to [email protected]ov no less than 30 days
before the quarterly report due date. The waiver request should come from a person
authorized to sign AIP grants and include how the workforce retention requirement
causes direct economic hardship on the airport or reduces aviation safety or security.
The airport sponsor should include any additional documentation that supports its
request. The FAA will respond expeditiously.
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Q-WF8: What are the consequences of failing to meet workforce retention reporting
requirements?
A: If a sponsor of a small, medium, or large hub airport does not meet the workforce
retention reporting requirements under either the CARES Act or CRRSA,
reimbursements for grants under the Airport Coronavirus Response Grant Program
may be suspended. The FAA will continue to work with the sponsor to meet these
reporting requirements, but continued non-compliance may result in the termination
of the grant and recovery of reimbursements.
