In the first two comments, St. Clair All the Way refers to
MIRMA. “The man there said that since the city does direct personnel to work at
the airport for maintenance, it's fair and reasonable that the city charge back
a percentage to the airport. The man said if the city did not have an airport,
its rate would decrease.”
“MIRMA has said since St. Clair has no payroll specifically
directed to the airport, it can be difficult to determine what percentage
directly would go toward the airport, but 5 percent is a reasonable amount.
That is from MIRMA, not the city.”
In the next two comments St. Clair All the Way adds this.
“Since the city is now following the recommendations of MoDOT
and the FAA, there's no beef anymore with the city there either. Your beef is
with MoDOT and the FAA.” And later states “since the city is following
the advice of MIRMA, MoDOT and the FAA, your beef now is with MIRMA, MoDOT and
the FAA.”
It appears that St. Clair All the Way has information from
the Feds on this issue.
The following is from Joe Pestka at MoDOT
September 23, 2010
The Honorable Ron Blum. Mayor
City of St. Clair
#1 Paul Parks Drive
St. Clair, MO 63077
Dear Mayor Blum:
Re: St. Clair Regional Airport
Informal Complaint Review
In late 2009
and early 2010, our office
received an informal complaint from a
tenant at the St. Clair
Regional Airport. The informal complaint concentrated on four areas. These areas included:
• Insurance
costs for the airport
• Potential
revenue diversion from the airport
• Potential
revenue collection for a sewer lift station located at the airport
• Land use
compatibility around the airport
In early 2010, our office
requested information from the complainant and the City of St. Clair concerning
these four issues. Our office has reviewed the information that was provided
and is offering the following assessment.
Insurance costs for the airport.
Based on a review of information
provided by the City and the complainant, insurance for the airport is provided
through the Missouri intergovernmental Risk Management Association (MIRMA).
MIRMA provides a listing of municipalities that own airports and have separated
those into airports that sell fuel and
those that do not sell fuel. MIRMA also publishes an “Airport Premises Renewal Hinder” that provides information on those municipalities with airports.
In reviewing information provided
by the complainant, the City has presumably charged for insurance for some
years and sonic years has not. Our office would recommend that the City of St.
Clair have further discussions with other municipalities
that have airports that do not sell fuel and determine how those municipalities
establish their insurance costs for the airport. This will allow the City to develop an annual reasonable
cost for airport insurance that is consistent in terms of actual cost compared
to value received. This will also enhance the airport budget planning
process.
Potential revenue diversion from
the airport
On March 27. 2008, the City of St. Clair submitted a Sponsor Questionnaire
— Airport Compliance Status to our
office that stated all revenue produced on the airport was not applied toward
the operation, maintenance, and development of the airport. If this is the
case, this may result in a violation of the Revenue Use Policy and grant
assurance 25, Airport Revenues. The City should identify any funds that may
have been used for purposes other than the operation, maintenance and
development of the airport. Please
submit detailed information to our office and include an itemized listing of
all revenues and expenses, with all applicable documentation to support your
conclusions. As you are aware, per Federal Aviation Administration (FAA)
grunt requirements, the City, under contract with the Federal government, has
agreed to use airport generated funding for the operation, maintenance and
development of the airport.
Potential Revenue Collection for
the Sewer Lift Station
The airport must receive fair
market value for non-aeronautical facilities located at an airport. In
reviewing the information provided by the City, I could not find or determine
the rental amount for the sewer lift station. If this area is not collecting
rent for the airport, the City must do so by establishing an annual fair market
value rental charge for the sewer lift station and deposit those funds into the
airport’s operating account. The determination of fair market value can be
accomplished through a professional assessment.
Airport
Sustainability
The
MoDOT Aviation
Section is participating with other
aviation industry representatives in the preparation of a guidebook to assist political subdivisions in the development
of a General Aviation Airport Business Plan. A business plan can
assist airport owners in the short and long
term sustainability of the airport and can allow the airport to respond accordingly in financially challenging times. Once the study is completed, our office will forward you a copy.
Based on information provided by the City for their 2009 revenue and expenses for the airport, it is
possible for the airport to sustain itself if management and
operational practices were executed in accordance with Federal Aviation Administration guidelines and
circulars and in compliance with federal grant obligations. Our office
is available to assist the City with any questions
related to the airport and can
provide FAA documents related to
compliance with Federal grant ass assurances.
Our office will await the
submittal of the
requested information in this Letter.
Please feel free to contact our office if you should have any questions.
Here you have MoDOT telling the city that
the airport would be selfsustaining if the city was following the rules.
The city’s
response to the MIRMA issue is as follows, “FAA is fully aware of what we
charge them and we have not received any complaints from them.” This statement was made more than a year
after the MoDOT letter.
This really does not sound like MoDOT and
the FAA signed off on the insurance plan.
Just because they have not heard
from the FAA does not make it legal.