5190.6B Is Cancelled: What FAA Order 5190.6C Changes for Airport Rents and Hangar Value

FAA Order 5190.6C, the Airport Compliance Manual, took effect February 20, 2026, cancelling Order 5190.6B and the interim changes issued under it since 2009. The manual is the FAA's operating guidance to its own compliance staff on the obligations an airport sponsor accepts with federal grant money. It is not itself a regulation. In practice, though, it is the document everyone argues from: sponsors defending a rate schedule, tenants contesting one, lenders underwriting a leasehold, and counsel on both sides of a Part 16 docket. When the manual changes, the working vocabulary of airport rent and hangar value changes with it.

This article covers what is new, what held, and what to do about documents that still cite the cancelled order. The twenty authorities the manual sits among, from the grant assurances to Part 77, are mapped in our reference on the FAA regulations that govern airport rents and hangar value.

A new manual, not new obligations

The first thing to get right is what did not change. A sponsor's obligations do not come from the manual. They come from 49 U.S.C. § 47107 and the grant assurances it authorizes, from 49 U.S.C. § 47133 on revenue use, and from Federal Register policy: the Policy Regarding Airport Rates and Charges at 78 FR 55330, the Revenue Use Policy at 64 FR 7696 as amended, and the hangar use policy at 81 FR 38906. None of those moved in February. The assurances still require reasonable terms without unjust discrimination, a rate structure that keeps the airport as self-sustaining as possible, and airport revenue used for airport purposes.

What moved is the FAA's own statement of how it reads those obligations, the structure it reads them in, and the paragraph numbers everything gets cited to. That is a smaller change than a new regulation, and a larger one than it sounds, because citations are where compliance documents are tested first.

What is new in 5190.6C

By the FAA's own description and the early practitioner reviews, the new order does four things. It consolidates the interim revisions the agency issued in the years since 2009 into a single current text. It aligns the manual with statutory changes from the FAA Reauthorization Act of 2024. It carries revised guidance on subjects that generated the most friction under the old order, including reasonable minimum standards, exclusive rights, and self-service fueling, and it addresses illegal charter activity. And it makes revisions throughout the document rather than in one chapter, which is why the agency published a Summary of Updates alongside it. The current order and its chapters are published on the FAA's site.

For valuation work, the significance is less any single new sentence than the fact of currency itself. The manual now speaks as of 2026, with the 2024 reauthorization behind it. An analysis that quotes the 2009 text is quoting a document the FAA no longer stands behind.

The paragraphs valuation work turns on

Four provisions of the current order do most of the work in rent and value disputes, and they are the ones to have at hand.

Paragraph 17.9, the band. Aeronautical fees for hangars and aviation offices may be set at fair market rate but need not exceed cost. A lawful aeronautical rate can sit anywhere between cost and fair market value. Sponsors misread this as an FMV mandate and raise rates they did not have to raise. Tenants misread it as a discount entitlement. Both readings are wrong, and a rent study that names the band, rather than a single point, is worth more in a negotiation than one that does not.

Paragraph 17.11, the floor. For non-aeronautical use, fair market value is the minimum. The classification of the use decides which standard applies, which is why mixed-use hangars need component-level analysis rather than one blended rate.

Paragraph 18.18(a), consistency. Methodology must be consistent across comparable aeronautical users. A rate schedule built one way for one tenant and another way for a neighbor invites a complaint even when both numbers are individually defensible.

Chapter 22, land releases. The current order requires at least one independent appraisal before a land release, which is where sponsors disposing of airport property meet the manual most directly.

The CGL 2018-3 wrinkle

FAA Compliance Guidance Letter 2018-3, the agency's appraisal standards guidance for aeronautical property, remains in effect, and it cites 5190.6B internally because it predates the new order. That is not a defect in the guidance letter, but it is a trap for a report writer. The clean citation practice now is to cite CGL 2018-3 as the operative appraisal standard, cite Order 5190.6C as the current compliance manual, and state the succession from 5190.6B in the report itself. A report that shows it knows the order changed leaves opposing counsel nothing to discover.

Where a stale citation bites

Currency review is the first move a reviewing agency, a credit committee, or an opposing expert makes, because it is the cheapest. A document that rests on a cancelled order loses credibility before its substance is read. The sweep list for a sponsor or a tenant is short:

• Rate resolutions, fee schedules, and the board packets that adopted them.
• Rent study and appraisal templates, including the boilerplate regulatory section nobody has read in years.
• Lease forms and minimum standards documents that recite the manual.
• Anything filed or about to be filed in a Part 13 or Part 16 matter.
• Expert reports and litigation exhibits in pending disputes.

The fix is rarely a change in substance. It is re-citation to the current order, paragraph by paragraph, with the analysis checked against the new text along the way. Where a matter is active, the check matters as much as the citation, because the revisions run throughout the document.

What to do now

Sponsors should sweep their rate documentation before the next reset or the next complaint, not after. Tenants and their counsel should read any rate increase justified on 5190.6B for what else in the analysis is stale. And anyone commissioning a rent study or appraisal should ask one screening question: which order does the report cite? Since February 20, 2026, there is only one right answer. Our rent studies and hangar appraisals have cited the current order since its effective date, and the full regulatory frame they sit in is mapped, authority by authority, in the FAA regulations reference.

This article is general information for professionals working in aviation real estate. It is not legal advice, and the legal conclusion in any matter belongs to counsel.