May
21, 2013
Mr. Rick Childers
City Administrator
City of St. Clair
#1 Paul Parks Drive
St. Clair, MO 63077
Re: St. Clair Regional Airport
March 26, 2013 Correspondence
Dear Mr. Childers:
Thank you for your March 26, 2013 letter. The corrective actions described in your letter demonstrate that the City has made significant progress in addressing the action items contained in my December 21, 2012 letters and Jim Johnson’s December 28, 2012 letter.
However, there are still a few items that must be addressed in order for the City’s corrective action plan to be accepted by MoDOT and the Federal Aviation Administration (FAA). The purpose of this letter is to outline the items which require additional action and to provide the City with guidance to ensure that its corrective action plan is accepted.
Routine Maintenance items
For item 1, “Grass and Weeds in Cracks on Runway and Apron”, the City’s
response suggests that pavement cracks are only sprayed once a year. However,
if weeds begin to grow out of pavement cracks after the annual spraying has
occurred, these weeds should be sprayed as needed. An acceptable corrective
action plan will include a commitment from the City to ongoing routine
maintenance of grass and weeds in cracks on pavement surfaces.
For Item 4, “Rotating Beacon Inoperative”, and Item 7, “Runway Lights Broken and Mounted Improperly”, ongoing routine maintenance must continue regardless of the status of negotiations on the City s closure request. An acceptable corrective action plan will include a commitment from the City to ongoing routine maintenance of the rotating beacon and the runway lighting system and will not condition that commitment on the outcome of closure discussions.
Compliance Plan Correspondence
For Item 3, which relates to main hangar storage, the actions proposed are acceptable and address the compliance issues raised, but additional information is
For Item 4, which relates to Air Evac’s lease, MoDOT and the FAA agree that
inclusion of a CPI indexing clause in the next Air Evac lease will help to
ensure that Air Evac’s monthly rental rate reflects current economic
conditions. MoDOT and the FAA also agree that different categories of tenants
can have different rental rates, so long as a consistent methodology is
utilized to establish fees for comparable aeronautical users of the airport.
Although the City’s letter indicates it will include a CPI indexing clause in its next lease agreement with Air Evac, the letter does not state whether the base monthly rental rate for Air Evac will increase from $300/month when the Air Evac lease is next negotiated. Without this information, MoDOT and the FAA cannot determine whether the City’s proposed corrective action plan for Item 4 is acceptable.
The City’s March 26 letter stated that its lease rates reflect a variety of factors that differentiate certain types of tenants from one another. The differences between Air Evac and the fixed wing tenants may substantiate different rental structures for businesses operating at the airport and for other fixed wing tenants, but without any type of documentation outlining the City’s rental structure for businesses
operating at the airport, MoDOT and the FAA cannot determine whether Air
Evac’s lease agreement is consistent with such rental structure.
In order to address the remaining questions relating to Item 4, any future Air
Evac leases should reflect a similar percentage increase in the base monthly
rate to the increases experienced by other tenants from 2007-2013 pursuant to
Title 49 United States Code Section 47107. In the alternative, the City should
provide its cost allocation methodology for its rental rates. This methodology
should be consistent with the FAA’s Rates and Charges Policy.
MoDOT is available to work with the City to address these remaining corrective action plan items and to identify steps the City can take to ensure future compliance. If you have any questions, please do not hesitate to contact me. As soon as a response is received on these remaining items, I will coordinate with the FAA to determine whether the City’s corrective action plan is acceptable.
Sincerely,
Amy Ludwig
Administrator of Aviation
cc: Mr. Jim Johnson, Federal Aviation Administration
Ms. Lynn Martin, Federal Aviation Administration
I think we need to send pictures to the FAA compliance office and let them see first hand what's going on at K39. MoDOT doesn't seem to be getting their point across to the people running the city.
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