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Saturday, March 16, 2013

This post is to reply to St. Clair All the Way.



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.



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