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

Abstract

1. Introduction

The Airport Compliance Manual is the FAA's operating guidance to its own staff on the obligations a sponsor accepts when it takes federal airport money. It is not a regulation and it creates no obligation of its own. It is nonetheless the document from which almost every airport rent argument is conducted, because it is where the agency states how it reads the statute, the grant assurances, and the published policies, and because it supplies the paragraph numbers that rate resolutions, lease forms, appraisal scopes of work, and Part 16 pleadings cite.

On 20 February 2026 the agency issued Order 5190.6C and cancelled Order 5190.6B, which had been in force since 30 September 2009 and had accumulated three consolidated changes. Commentary followed within days. Most of it, including some from sources practitioners rely on, describes as new in 5190.6C material that entered the manual years earlier.

That is not a pedantic complaint. A rent study or an expert report that dates a provision to February 2026 when it was adopted in September 2023 is wrong on a fact an opposing party can check in an afternoon, and it invites the inference that the author did not read the order. It also obscures the change that does matter for valuation, which almost no commentary has noticed.

This paper does four things. Section 2 establishes the order's provenance and its publication record, which is itself evidence about the order's legal weight. Section 3 sets out the allocation of provisions across the three changes and the new order, and identifies the provisions most often misdated. Section 4 states the paragraphs that govern rent and valuation work, with their text and their lineage. Sections 5 and 6 address the two changes that are genuinely new and genuinely consequential. Section 7 documents the resulting inconsistency in the surrounding guidance. Section 8 reports how the agency has applied the order in its first six months. Section 9 states a citation practice that survives review.

2. The Order and Its Publication Record

2.1 Issuance and Cancellation

The Foreword to 5190.6C carries an effective date of 20 February 2026 and states at paragraph 3 that the order cancels and replaces the Airport Compliance Manual, Order 5190.6B. It is signed by the Director, Airports Compliance and Management Analysis. Paragraph 4 records the predecessor's change history: Change 1 issued 3 December 2021, Change 2 issued 9 December 2022, Change 3 issued 15 September 2023.

Order 5190.6B was issued on 30 September 2009 and was effective on issuance, as the agency stated in a Federal Register notice of 13 October 2009 that opened a comment period running to 31 March 2010. It had itself cancelled Order 5190.6A of 2 October 1989.

The order runs to seven parts and twenty-three chapters, with eight appendices that are not organized as a numbered part. Part IV covers airports and aeronautical users, Part V financial responsibilities, Part VI land use, and Part VII releases and property reversions. Those four parts contain everything relevant to hangar rent and value.

2.2 There Was No Federal Register Notice and No Comment Period

This is the single most useful fact about 5190.6C and it appears in none of the commentary.

A Federal Register search for 5190.6C returns exactly one document, and it is a notice of 3 December 2021 announcing Change 1, which forecast that when the revision project was complete the new order would be numbered 5190.6C. Searches for 5190.6 and for the phrase Airport Compliance Manual published in or after 2025 return nothing. The order was issued with no notice, no docket, and no opportunity to comment.

The contrast with the predecessor is instructive. Order 5190.6B was announced in the Federal Register and carried a comment docket open for nearly six months. The agency treated the 2009 revision as a document the public had an interest in and the 2026 revision as internal housekeeping.

The Foreword says the same thing in its own words. It characterizes the edits and additions to the revised chapters as intended to provide accurate and useful guidance on airport compliance policy for FAA Airports staff, and not to adopt significant changes in compliance policy. The agency is describing a manual, not a rule, and its publication practice matches the description.

The practical consequence is that the binding obligations did not move in February. They sit in 49 U.S.C. 47107 and the grant assurances it authorizes, in 49 U.S.C. 47133 on revenue use, and in the notice-and-comment policies: the Policy Regarding Airport Rates and Charges at 78 FR 55330, the Revenue Use Policy at 64 FR 7696 as amended by 79 FR 66282, the hangar use policy at 81 FR 38906, and the land use changes policy at 88 FR 85474. None of those changed in or around February 2026. What changed is the agency's statement of how it reads them, and the numbers everything is cited to.

2.3 The Assurances Are Not in the Order

Appendix A of 5190.6C is one page of narrative plus a two-page table. Its entire narrative text states that a current copy of the Airport Sponsor Assurances is available on the FAA website. What follows is a statutory basis table listing assurances one through forty against their citations. The order does not reproduce the assurances.

That matters more than it sounds. The assurances were reissued in April 2025, adopted through a Federal Register notice of 25 April 2025, and that reissuance added Assurance 40 on access to leaded aviation gasoline under 49 U.S.C. 47107(a)(22), implementing section 770 of the 2024 reauthorization. The assurance text changed without any amendment to the manual, because the manual only points at it. A sponsor or an analyst who treats the manual as the repository of the assurances will be working from a document that cannot go stale, because it never contained the text in the first place.

3. What Is Actually New

3.1 The Allocation

The agency published a Summary of Updates alongside the order. Its opening line states the scope of the document, and it is a consolidated history rather than a statement of what changed in February. The Summary covers the updates made to 5190.6B in Changes 1, 2, and 3, together with the current updates to Chapters 6, 7, 8, 12, 13, 14, 15, 20, 21, 22, and the appendices.

That sentence is where the commentary went wrong. A reader who treats the Summary as a list of February 2026 changes will attribute five years of accumulated revisions to a single date. The FAA's own landing page states the allocation explicitly.

One qualification is required, and it cuts against the agency's own list. Chapter 17 demonstrably contains content implementing the 2024 reauthorization, which postdates Change 3 by eight months. The Foreword and the landing page both omit Chapter 17 from the 5190.6C list. The agency's chapter list understates what changed in Chapter 17, and a reader relying on the list alone will miss the carve-out discussed in Section 5.

3.2 Provisions Commonly Misdated

The following entered the manual before February 2026 and are routinely described as new.

Illegal air charter. Paragraph 10.7 was added by Change 1 on 3 December 2021. It defines illegal air charters as unauthorized air charter operations, notes that such an operation can present as flight instruction or aircraft demonstration flights, and directs sponsors to raise concerns with the local Flight Standards District Office. The paragraph is emphatic that the agency does not want sponsors investigating suspected illegal aeronautical activity, because sponsors have neither the responsibility nor the expertise. It then lists lease and minimum standards language sponsors have used, including a requirement that the tenant supply a copy of its air operating certificate, which the paragraph states helps ensure the sponsor charges the appropriate rates and charges to the commercial operator. That last point is directly relevant to rate work, and it is four and a half years old.

Automotive gasoline and specialized aviation service operations. Paragraph 10.5.a treats as unreasonable a restriction preventing a fixed base operator from selling ethanol-free premium unleaded automotive fuel or ASTM 6227 standard aviation gasoline, or setting an unreasonable minimum tank size for the fuel type. Paragraph 10.5.f addresses specialized aviation service operations and states that published minimum standards may not apply to single-service or specialty operators and that sponsors are not required to permit such an operator to sell fuel. Both are Change 1, December 2021.

Self-service maintenance detail. Paragraphs 11.2, 11.3, and 11.4, covering the scope of the self-service right, maintenance on light sport and experimental aircraft, and when third-party contracting is permitted, are Change 1.

The Chapter 17 and Chapter 18 reorganization. The Summary states that sections of Chapter 17 were reordered and retitled in order to align with the Revenue Use Policy, and that a new introduction was added at 18.1 clarifying that the chapter summarizes the Policy Regarding Airport Rates and Charges at 78 FR 55330. Both are Change 3, September 2023. The renumbering is substantial and is treated in Section 4.

What is genuinely new in February 2026, for present purposes, is the Chapter 8 exclusive rights revisions, the Chapter 12 lease review revisions, the full replacement of Chapter 22, the community use carve-outs, and the appendix restructuring that split the former Appendix Z into a terms appendix and an acronyms appendix.

4. The Provisions Rent and Value Work Turns On

4.1 Paragraph 17.9: The Band for Aeronautical Use

Paragraph 17.9, titled Aeronautical Use Rates, is preceded by the statement that the FAA does not consider the self-sustaining requirement to require the sponsor to charge fair market value rates to aeronautical users. The paragraph then provides that fees for use of the airfield generally may not exceed the airport's capital and operating costs of providing the airfield, and that aeronautical fees for landside or non-movement area airfield facilities, giving hangars and aviation offices as the examples, may be at a fair market rate but are not required to be higher than a level that reflects the cost of services and facilities. The order states the conclusion in terms: those charges can be somewhere between cost and fair market value. The stated reason is that hangars and aviation offices are used exclusively by their leaseholders while airfield facilities are used in common.

The provision is not new. It is verbatim identical to paragraph 17.9 of Change 3, with a single editorial change dropping the phrase of this Order from a cross-reference. In the 2009 base text the same material was numbered 17.10.

The analytical point survives the dating correction and is worth stating plainly. A lawful aeronautical rate is a range, not a point. Sponsors misread the provision as a fair market value mandate and raise rates they were never required to raise. Tenants misread it as an entitlement to cost-based rent. Both readings are wrong, and a rent study that establishes both edges of the range is a more useful document in a negotiation than one that produces a single number.

4.2 Paragraph 17.11: The Standard for Non-Aeronautical Use

Paragraph 17.11, titled Fair Market Value, now reads: except as provided in 49 U.S.C. 47107(v), Community Use of Airport Land, fair market fees for use of the airport are the required minimum for non-aeronautical use of the airport. It goes on to provide that fair market pricing may be determined by reference to negotiated fees for similar uses of the airport or by appraisal of comparable properties, and instructs appraisers to account for airport-specific circumstances such as limits on the use of airport property and height restrictions when comparing on-airport with off-airport commercial non-aeronautical properties. It closes by stating that the market rate for non-aeronautical users should be different from, and usually higher than, the aeronautical rates.

The paragraph number and most of the text are Change 3 material; in 2009 the same provision was numbered 17.12. The opening clause is new, and Section 5 addresses it.

Paragraph 17.10, retitled Non-Aeronautical Use Rates, carries the residual subsidy discussion and cites the Santa Monica determination at Docket No. 16-03-11.

The classification question is what decides which of 17.9 and 17.11 applies, and it is unresolved in a way that should be disclosed in any report that turns on it. The agency proposed a Policy on the Definition of Aeronautical Activities at 88 FR 78448 on 15 November 2023, with the comment period extended at 88 FR 85719. It was never finalized. The Federal Register record contains the two 2023 notices and nothing since. Order 5190.6C retains the traditional definition in its terms appendix. Because the aeronautical and non-aeronautical classification is the switch that selects between a cost-to-market band and a market floor, an unresolved definition is an unresolved rate question, and a mixed-use hangar needs component-level analysis rather than one blended rate.

4.3 Paragraph 18.18(a): Consistent Methodology

Paragraph 18.18 is titled Prohibition on Unjust Discrimination. Subsection (a), Consistent Methodology, provides that the sponsor must apply a consistent methodology in establishing fees for comparable aeronautical users of the airport; that where the sponsor uses a cost-based methodology, aeronautical fees imposed on any user or group may not exceed the costs allocated to that user or group; and that a cost allocation methodology consistent with the Rates and Charges Policy must be adopted unless aeronautical users agree otherwise.

The companion subsection is at least as useful and is rarely cited. Subsection (d), Allocation, requires sponsors to allocate rate-base costs to aeronautical users by a transparent, reasonable, and not unjustly discriminatory rate-setting methodology, to apply it consistently, and, when practical, to determine cost differences quantitatively. Subsections (b) and (c) address reasonable distinctions between signatory and non-signatory carriers and foreign air carriers respectively.

Paragraph 18.18 is Change 3 material. In the 2009 base text the same content was numbered 18.21, and 18.18 meant something entirely different, namely maintenance of a closed airport. A citation to 18.18 checked against a 2009 copy of the manual lands on an unrelated provision. That is the clearest illustration available of why an edition and a date belong in every citation to this order.

4.4 Chapter 12: What the Agency Looks For in a Lease

Chapter 12 was revised in February 2026 and it is the chapter most directly useful to anyone drafting, reviewing, or valuing an airport lease, because it states the agency's own review checklist.

The checklist sits at paragraph 12.3.b, Form of Lease or Agreement, in seven items: premises; rights and obligations; term of aeronautical lease; payment of fees to the sponsor; title; subordination; and assignment and subleasing. Two of the seven changed in 2026. Item (3) was retitled from Term to Term of Aeronautical Lease. Item (7) was retitled from Assignment and Subletting to Assignment and Subleasing. Separately, paragraph 12.3.a(1) gained a closing question asking whether the lease extends an exclusive right in any capacity.

The lease term guidance at 12.3.b(3) is the provision most often quoted out of the manual and it deserves quoting accurately. It asks whether the term exceeds a period reasonably necessary to amortize a tenant's investment and whether the lease provides multiple options with no increased compensation to the sponsor. It then states that most tenant ground leases of thirty to thirty-five years are sufficient to retire a tenant's initial financing and provide a reasonable return for the tenant's development of major facilities, and that leases exceeding fifty years may be considered a disposal of the property because the term likely exceeds the useful life of the structures erected on it. It directs that the Region or airports district office should not consent to proposed lease terms exceeding fifty years.

The rate adjustment hook is at 12.3.b(4), which asks whether rental of airport land or facilities has been assessed on a reasonable basis, giving appraisal as the example, and states that all leases for a term of more than five years should contain provisions for periodic adjustment of rates. The periodic adjustment sentence in item (4) is new in 5190.6C. It appears nowhere in Change 3.

Item (7) asks whether the sponsor has retained the right to approve in advance an assignment or sublease, and gives two examples: whether the sponsor could intervene if a dominant fixed base operator moved to acquire all competing operators on the field, or if an aeronautical tenant proposed to sublease aeronautical space to a non-aeronautical tenant. Both examples describe transactions that change the value of every other leasehold on the field.

Chapter 12 also dropped the sample responses to residential through-the-fence requests and to through-the-fence release requests that the old chapter contained.

4.5 Chapter 8: Exclusive Rights and Self-Service Fueling

Two Chapter 8 changes are genuinely new and both bear on what a leasehold is worth.

Paragraph 8.2, defining an exclusive right, gained a closing sentence stating that the prohibition on exclusive rights extends to all aeronautical activities.

Paragraph 8.7.b, on restrictions on self-service, now lists refueling among the activities an aircraft owner or operator may perform, and specifies the fueling sources: aviation gasoline, jet fuel, electric charging, and other fueling sources. Paragraph 8.7.b(2) adds that unreasonable restrictions may include preventing self-fueling or restricting the use of certain fuel types such as leaded or alternative fuels, and that alternative fueling sources accommodating new and emerging entrants are treated similarly to conventional fueling for self-service purposes. Section 770 of the 2024 reauthorization is behind the related provision protecting availability of 100LL at fields that offered it during calendar year 2022.

Paragraph 8.8.b, on single activity, adds language that will matter in competitive award disputes: a competitive offering such as a request for proposals does not absolve a sponsor from complying with its broader federal obligation on airport access and cannot be used to exclude others from some level of airport access on reasonable terms, without unjust discrimination and without granting an exclusive right.

4.6 Paragraph 22.21: The Appraisal Requirement and the Standard of Value

The appraisal requirement for land releases now has a stable number. Paragraph 22.21, Determining Fair Market Value for Sale or Disposal, subsection (a), Appraisals, provides that a release authorizing the sale or transfer of airport land shall not be granted unless the fair market value has been supported by at least one independent appraisal report acceptable to the FAA, and that appraisals shall be made by an independent and qualified real estate appraiser.

Two qualifications are essential and are routinely omitted when this provision is summarized.

First, the requirement is waivable. The order provides that the FAA may waive the appraisal if it determines that the approximate fair market or salvage value of the property released is less than twenty-five thousand dollars, or that it would be in the public interest to require public advertising and sale to the highest responsible bidder in lieu of appraisals. A statement that Chapter 22 requires an appraisal, without the waivers, is incomplete in a way that can matter to a sponsor deciding how to proceed on a small parcel.

Second, 5190.6C narrowed the waivers from three to two. Change 3 carried a middle ground permitting waiver where the property released was a utility system to be sold to a utility company that would accommodate continued airport use and operational requirements. That waiver was deleted. It is a real tightening, and it runs against the Foreword's characterization of the revision as making no significant changes in compliance policy.

Paragraph 22.21 also opens with the community use carve-out: except as provided in 49 U.S.C. 47107(v), a sale and disposal of airport property for less than its fair market value is inconsistent with the intent of the statute and shall not be authorized.

The paragraph also supplies the standard of value, which practitioners more often assume than cite. Paragraph 22.21 provides that “The value to be placed on land for which a release has been requested shall be based on the present appraised value (for its highest and best use) of the land itself and any federal improvements initially conveyed with the property.” Highest and best use, in an order whose own glossary defines fair market value as a highest-price rather than a most-probable-price concept, is a specific instruction, and Section 11 takes up what it means for the reconciliation.

One further point on citation stability. In Change 3 this material sat as an unnumbered subsection within the paragraph 22.17 area. Assigning it a number is new, and it means that for the first time an appraisal scope of work can cite the requirement to a paragraph rather than describing it.

5. The Community Use Carve-Out

Section 706 of the FAA Reauthorization Act of 2024 amended 49 U.S.C. 47107(v), Community Use of Airport Land, generally. The subsection existed before; section 706 rewrote it. Order 5190.6C implemented it by inserting an express exception in front of three separate valuation provisions and in the release processes.

Before February, paragraph 17.11 read simply that fair market fees for use of the airport are the required minimum for non-aeronautical use. It now opens with an exception. Paragraph 22.21 carries the same exception in front of the prohibition on disposal below fair market value. Paragraph 17.13 references the subsection in body text and again in a footnote. Paragraphs 22.9 and 22.12 carry it as well, in footnotes rather than body text. Paragraph 22.9 is not a release process: it is titled Process for FAA Approval of a Land Use Change on Federally Acquired Land and states that this “is not a release of obligations, but approval of the use.”

The scope of the carve-out has to be stated precisely, because it is far narrower than the words community use suggest and the limits are checkable in a minute by anyone on the other side. Subsection (v) reaches two things only. The first is an agreement with a local government for interim compatible recreational purposes below fair market value, available only where the agreement was “initially entered into before the publication of the Federal Aviation Administration’s Policy and Procedures Concerning the Use of Airport Revenue, dated February 16, 1999,” only where the property was “purchased using funds from a Federal grant for acquiring land issued prior to January 1, 1989,” only with a statement that no aeronautical need is foreseen for ten years, and only for a term of up to two years of preparation plus ten years of use. The second is a permanent restriction of property to compatible recreational and public park use without obtaining fair market value, available only on pre-1989 land-acquisition-grant property “continuously leased or licensed ... for recreational or public park uses since July 1, 2003.” Subsection (v)(5) adds that nothing in it “may be construed as permitting a diversion of airport revenue for the capital or operating costs associated with the community use of airport land.”

The order carries the pre-1989 limitation into its own text. Chapter 17, footnote 3: the FAA “will not find airport sponsors in non-compliance for certain interim or permanent compatible recreational and public park uses if the airport property was purchased using funds from a Federal grant for acquiring land issued prior to January 1, 1989 and other conditions set forth in 49 U.S.C. § 47107(v) are met.” Chapter 22 says the same in footnotes 7 and 13.

The consequence for valuation practice is direct. Fair market value is no longer an unqualified floor for non-aeronautical use of airport land, and below-market treatment of a qualifying community use is no longer, by itself, a revenue diversion problem. Qualifying is the operative word: this is a recreation-and-park exception on pre-1989 land-acquisition-grant property, not a general community use exception, and an opinion of value that treats it as general will not survive review. An opinion of value for a non-aeronautical use on airport land should now state whether the subsection is engaged, because the answer determines whether market rent is a floor or a reference point.

This is, on the evidence, the most consequential valuation change in the order, and it is the one the published commentary has missed. The February and March law firm alerts and the trade association coverage focused on electric charging, the expanded government aircraft definition, and the new homelessness provisions at paragraph 20.8. None addressed the carve-out. It is also the provision most likely to generate a dispute, because it creates a category of below-market use that a competing tenant has an obvious incentive to challenge and a sponsor has an obvious incentive to read broadly.

A caution belongs here. This paper establishes what the order says and where the statutory authority comes from. It does not attempt to predict how broadly the agency will construe a qualifying community use, because no determination construing the subsection has issued.

Section 706 is not the only below-market provision the 2024 Act added. Section 705 amended 49 U.S.C. 47107(t), Renewal of Certain Leases, and the order implements it at new paragraph 17.15.b, Military Nonaeronautical Units. It permits renewal of a covered lease at a nominal rate where the lease was originally entered into before 7 October 2016, is at a nominal rate, runs to a Federal or State government entity, and supports Air Force or Air National Guard aircraft or National Guard use of non-aeronautical land. It is narrow in the same way subsection (v) is narrow, and it has the same effect on a valuation: a lawful rent that is not a market rent. The two Part 16 determinations discussed in Section 8 do not reach it.

6. Chapter 22 Has No Crosswalk

The Summary of Updates states the position without qualification: due to statutory and policy updates, Chapter 22 is fully replaced, and as such a section renumbering and retitling chart is not provided.

The statutory driver is the 2024 reauthorization. The policy driver is the Policy Regarding Processing Land Use Changes on Federally Acquired or Federally Conveyed Airport Land at 88 FR 85474, published 8 December 2023, which paragraph 22.1 states the chapter implements. That policy postdates most regulatory reference lists in circulation and belongs in any list of the authorities governing airport land.

The absence of a crosswalk is the practical problem. A renumbering chart was published for Chapters 6, 7, 8, 14, 15, 17, 18, and 20, and it maps the 2009 numbering forward. It does not cover Chapter 22, and no equivalent exists. Every lease, release application, brief, appraisal scope of work, and expert report in existence that cites a 5190.6B Chapter 22 paragraph now cites a paragraph that cannot be traced to anything. The only remedy is to locate the corresponding provision in the new chapter by subject and re-cite it.

The new architecture is worth stating so that the search has a starting point. Chapter 22 is the longest in the order at fifty-five pages. Paragraphs 22.8 through 22.10 address land use changes. Paragraphs 22.12 through 22.16 address releases organized by land type. Paragraphs 22.17 through 22.21 are supplemental and cover public notice, release of the National Emergency Use Provision, reverter, cost-free land, and fair market value. Paragraph 22.22 addresses the letter of intent, 22.23 statutorily released obligations, and 22.24 requests for a change in use of personal property, structures, equipment and facilities, with 22.25 through 22.29 reserved.

Two provisions in the new chapter change outcomes rather than numbering, and neither has been widely noticed.

Paragraph 22.8 moves the threshold question. Under the heading FAA Land Use Approval Authority on Sponsor Acquired Land: “Under Pub. L. 118-63, Section 743(b)(2), the FAA retains ALP approval authority on sponsor acquired land when the land use change materially impacts the safe and efficient operation of aircraft at, to, or from the airport; adversely affects the safety of people or property on the ground as a result of aircraft operations; or adversely affects the value of prior Federal investments to a significant extent.” That sentence decides whether FAA approval is required at all for a land use change on sponsor-acquired land, which is the first question in most non-aeronautical development on an airport. It is also the only place in the body of the order, other than section 770, where a section number from the 2024 Act appears.

Paragraph 22.12 states the release standard and closes a door practitioners regularly try: “In no case shall a release be granted unless the FAA determines that sale of the land will not adversely affect the development, improvement, operation, or maintenance of the airport. Any release must not be in excess of the present and foreseeable needs of the airport. The nonaviation interest of the sponsor or the local community – such as making land available for economic development – does not constitute an airport benefit that can be considered in justifying a release and disposal.” Economic development is not an airport benefit. A highest and best use conclusion that rests on a release the sponsor expects to obtain on economic development grounds is resting on nothing. A guide to releases appears as Table 22.1.

Two vocabulary changes compound the problem. The former Appendix Z was split into a terms appendix and an acronyms appendix, so a citation to Appendix Z now points at nothing. And several defined terms were removed, including long term lease, concurrent land use, interim use, and aviation use of real property. A document that uses long term lease as a defined term of the manual is using a term the manual no longer defines.

7. The Guidance Layer Is Now Inconsistent

Compliance Guidance Letter 2018-3, Appraisal Standards for the Sale and Disposal of Federally Obligated Airport Property, is the agency's statement of the appraisal process and report documentation standards for establishing fair market value for the sale, exchange, or leasing of federally obligated property. It states that sponsors have a federal obligation to establish fair market value for property proposed for disposal and that, with limited exceptions, lease rates on non-aeronautical airport property must be based on fair market value. It governs scope of work, appraiser selection including independence and state certification, report content, and the valuation process; it requires conformity to USPAP; and it expressly rejects a restricted appraisal report as inappropriate. It was developed in response to Department of Transportation Inspector General audit findings.

A date discrepancy needs handling. The memorandum is dated 27 August 2018 and its own footnote states that it becomes effective 10 September 2018, the revision date. The agency's guidance letter index lists it under a November 2018 date. Cite the document's own dates and note the index entry, or a reader checking the index will conclude the citation is wrong.

The substantive problem is that the letter remains in force and every internal cross-reference in it now points at something that does not exist. It cites Appendix Z for the definition of fair market value, and Appendix Z was split in two. It cites Chapter 17 for the self-sustaining principle, and Chapter 17 was renumbered so that the fair market value provision moved from 17.12 to 17.11. It cites paragraph 22.5 on requests for concurrent use of aeronautical property, and Chapter 22 was replaced with no crosswalk. The letter has not been reissued, amended, or withdrawn since 5190.6C took effect.

The gap runs in both directions. Order 5190.6C never cites the guidance letter. The abbreviation for compliance guidance letter appears twice in the entire order, once in the acronym appendix and once in a footnote to an unrelated letter on informal complaints. The order contains no reference to USPAP and no appraisal methodology standards of any kind. The appraisal standards governing a paragraph 22.21(a) appraisal therefore live entirely in a guidance letter that the order does not acknowledge and that points back at a cancelled order.

The problem is not confined to that one letter. Several guidance letters that remain listed as current cite 5190.6B, including the letters on unpaved landing areas, on release and permanent closure of federally obligated airports, on transfer of federally obligated airports, and on parachute operations. Two current letters, on land use inspections and on public notice for a change in use of aeronautical property, still cite Order 5190.6A, which was cancelled in 2009. The guidance letter library as a whole has not been conformed.

The right inference is not that the guidance is unreliable. It is that the manual layer is administrative, that obligations sit in the statute, the assurances, and the published policies, and that a document tracing an obligation back to a manual paragraph is tracing it to the wrong place. A report that states the obligation, cites the statute or the policy, and then cites the manual paragraph as the agency's reading of it is stable against the next renumbering. A report that cites the manual alone is not.

8. Early Application

Two Part 16 determinations issued in the six months after the effective date apply the new order, and both are useful for what they say about its weight.

The first, a Director's Determination of 13 March 2026 in Docket 16-24-05, arose from a complaint filed in May 2024 against a territorial ports authority. It cites 5190.6C four times and it applies the lease term provision directly. The determination introduces the order as providing FAA internal guidance for reviewing lease agreements and quotes paragraph 12.3(b)(3) on the sufficiency of thirty to thirty-five year ground leases. Quoting an earlier determination, it states that the thirty to thirty-five year term outlined in the order is a best practice recommendation left to the discretion of the airport sponsor. It found no violation of the grant assurances at issue.

That characterization is the strongest available support for the proposition that the manual states the agency's reading rather than an independent obligation, and it comes from the agency itself, within three weeks of the effective date, in an adjudication.

The second, a Director's Determination of 25 March 2026 in Docket 16-24-04, involved an aviation museum and a municipal airport operator. It cites 5190.6C nine times and the cancelled order four. It applies the terms appendix definition of aeronautical activity and holds that the agency does not include aviation museums within that definition, while separately finding that the operator could not deny the complainant the ability to fly to, land at, and park its aircraft at the field under the access assurances even absent executed lease terms. It cites paragraph 14.3 for the proposition that a sponsor's ability to deny aeronautical access is limited primarily to reasonable safety or efficiency justifications, and that the FAA must be involved in and approve such denials. A footnote in that determination records the 20 February 2026 issuance and the replacement of Change 3.

The classification holding is the one to carry forward. The definition of aeronautical activity decides which rate standard applies, the proposed policy that would have expanded it was never finalized, and the agency applied the traditional definition to exclude a use that many practitioners would have assumed qualified.

Part 13 informal determinations are not published in a searchable public docket, so nothing can be said about how the order has been applied there.

Paragraph 14.3 deserves separate notice for a reason unrelated to that case. It now provides that the agency's airports organization, not the sponsor, is the authority to approve, disapprove, and determine the reasonableness of aeronautical restrictions under Grant Assurance 22. That is a shift in who decides, and like the deleted appraisal waiver it runs against the Foreword's framing.

9. What the Agency Does With It

Sections 2 through 8 describe the order as a document. This section reports what the FAA has actually done with it in adjudication, because a compliance manual has no force of its own and the only evidence of its operative meaning is the use the agency makes of it.

9.1 An airport hangar appraisal held not credible

On 3 December 2025, eleven weeks before the new order took effect, the Director of the Office of Airport Compliance issued a determination that is the closest thing in the administrative record to an FAA review of appraisal work on hangars.

The complaint concerned hangar rental rates at five Los Angeles County airports. The Director found the County “currently in violation of Grant Assurance 24, Fee and Rental Structure, and Grant Assurance 25, Airport Revenues, as outlined in the FAA’s Revenue Use Policy by charging rental rates below FMV for nonaeronautical use of hangars and increasing those rates incrementally,” while finding no violation as to the proposed aeronautical rates.

The sentence that matters to appraisal practice is this one: “The Director finds that the appraisal is not credible due to the use of questionable comparable properties and the arbitrary reduction in the rate.” The Director also found that phasing the non-aeronautical hangar rates in over time constituted revenue diversion, and ordered the County within thirty days to “Commission a new appraisal for FMV nonaeronautical hangar rates with a Scope of Work acceptable to the Director or establish an alternative methodology,” and then to apply the resulting rates immediately rather than incrementally.

The methodological dispute is worth stating precisely, because it is the kind of adjustment an appraiser makes routinely. The County’s appraisal used off-airport self-storage units ranging from twenty to three hundred sixty square feet as comparables for hangars of eight hundred fifty-six square feet and larger, then took a forty-five percent downward adjustment: thirty percent for hangars larger than two hundred fifty square feet and fifteen percent for condition. The Director rejected the comparables and the adjustment together.

Three things follow for anyone appraising airport property.

The credibility finding is a USPAP word applied by an agency whose own order never uses it. Section 7 notes that USPAP appears nowhere in the four hundred thirty-three pages of the order and that the USPAP requirement lives only in a 2018 guidance letter. The Director nonetheless assessed the report on credibility grounds, which is where the requirement actually bites.

The scope of work is reviewable. The corrective action does not order a particular value. It orders a scope of work acceptable to the Director, which places the FAA in the position of an intended user with a view on methodology.

The determination also confirms a numbering point Section 3 makes from the documents. It cites “FAA Order 5190.6B, paragraph 17.11, Fair Market Value” and quotes the hangars-and-aviation-offices sentence from paragraph 17.9. That is independent agency confirmation, in an adjudication decided before the new order issued, that both paragraphs carried those numbers under 5190.6B Change 3.

Two further holdings in the same determination bear on scope of work. On the appraisal guidance letter: “CGL 2018-3 is a non-binding document that is not applicable to month-to-month leases,” and where a sale or long-term lease does not reach contract within a year of the report, a new report is required. On deference to a sponsor’s rate study: “The Director reviewed the study and found that the methodology used to develop the rates is clearly defined and does not appear to be unreasonable. The Complainants may disagree with some of the assumptions and adjustments, but the overall methodology is transparent and does not appear to be discriminatory.” Transparency of method, not agreement on inputs, is the standard the sponsor had to meet.

9.2 The complete adjudicative record, 2025 to date

Thirteen Part 16 determinations carry a decision date between 1 January 2025 and the date of this paper. All thirteen are Director’s Determinations; no Final Agency Decision is posted for any of them. Two post-date the new order.

The thinness of that record is the finding. Two determinations, both within six weeks of the effective date, are the entire body of agency practice under the new order. Anyone citing 5190.6C for a proposition about how the FAA will treat a rate or a lease term is citing a document, not a pattern.

10. The Rate Differentiation Grid

Chapter 9 governs unjust discrimination between aeronautical users. It is unchanged in substance in 2026, which is why commentary on the new order passes over it, and it is nonetheless the closest thing the FAA has published to a sanctioned adjustment framework for airport rent comparables.

Paragraph 9.5.d sets out the permitted grounds for charging two tenants differently: “The FAA may consider factors such as minimum investment requirements, demand, location, capital investment risk, ownership of facilities, time remaining on contract terms, and condition of facilities as reasons that may justify differing rates.” It then constrains them: the varying rates “must be justified by the differing circumstances and should not arbitrarily confer an advantage on one category of operator over another.”

That sentence is an adjustment grid. Seven named factors, an agency that will consider them, and a requirement that each be justified rather than asserted. An appraiser adjusting a comparable airport rent for remaining lease term, for who owns the improvements, or for location on the field is applying distinctions the regulator has already recognised as lawful grounds for a rate difference.

Two of the seven deserve emphasis because practice tends to drop them. Time remaining on contract terms is a term-structure adjustment, and it is the only place in federal airport policy where remaining lease term is named as an economic differentiator. Ownership of facilities is elaborated at paragraph 9.6.a: “If one FBO rents office and/or hangar space from the sponsor and another leases land from the sponsor and builds its own facilities, the sponsor would have justification for applying different rental rates and fee structures. Even though the operators offer the same services to the public, the cost and value of the facilities are different due to circumstance.” Paragraph 9.2.c gives the reason in cash-flow terms: “an FBO leasing a sponsor-owned aeronautical facility may pay more in rent than an FBO that builds and finances its own facility. In the first case, the FBO is not servicing debt while in the second case, the FBO is servicing debt.”

Paragraph 9.5.e adds an escalation expectation that bears directly on how a long lease should be modelled: “Ground leases with terms of five (5) or more years should contain a provision for periodic adjustments based on a recognized index to reflect inflation and other changing economic conditions (e.g., change in the Consumer Price Index, an appraisal, etc.). This will facilitate parity between new and established lessees.” A lease without one is not merely unusual; it departs from what the agency expects, and the departure is a valuation fact.

Three further provisions in the chapter bound what a sponsor may do, and each has a value consequence. Paragraph 9.6.b permits a location premium outright. Paragraph 9.7.b provides that “When adequate facilities are otherwise available for lease, Grant Assurance 22, Economic Nondiscrimination, does not compel sponsors to lease vacant property to entities seeking to construct facilities for private aeronautical use,” which is the answer to a tenant who assumes a right to build. And paragraph 9.10 forbids residency preference in hangar assignment in terms: such practices “are unreasonable and unjustly discriminatory, and can result in the granting of an exclusive right contrary to Grant Assurance 22, Economic Nondiscrimination, and Grant Assurance 23, Exclusive Rights,” and local tax payment “does not justify preferential treatment, differential rates, or other unjustly discriminatory practices.”

11. The Definition the Order Supplies

Appendix G carries the order’s glossary, and it was revised in 2026. It contains a definition of fair market value that no commentary on the new order appears to have quoted, and it is the definition an appraiser working to an FAA scope of work is working to.

Appendix G, at G-5: “Fair Market Value (FMV) – The highest price estimated in terms of money that a property will bring if exposed for sale in the open market allowing a reasonable time to find a purchaser or tenant who buys or rents with knowledge of all the uses to which it is adapted and for which it is capable of being used. It is also frequently referred to as the price at which a willing seller would sell and a willing buyer buy, neither being under abnormal pressure. FMV will fluctuate based on the economic conditions of the area.”

Three features of that definition differ from the market value definition an appraiser ordinarily applies, and the differences are not cosmetic.

It is a highest-price definition rather than a most-probable-price definition. The standard federal financial-institutions definition and the Appraisal Institute’s market value definition both rest on the most probable price. Highest price and most probable price are different points on the same distribution, and an appraiser reconciling to the FAA’s wording should say which one the assignment calls for.

It covers sale and rental in one sentence. The definition speaks of a purchaser or tenant who buys or rents, so the same words govern a land sale under a release and a ground rent under a lease. That is convenient for the agency and imprecise for the analyst, because exposure time and the meaning of open market are not the same for a fee sale and for a ground lease on a federally obligated field where the pool of eligible tenants is limited by the aeronautical use requirement.

It has no exposure period, no financing assumption and no cash-equivalency provision. Reasonable time to find a purchaser or tenant is the whole of it.

The practical consequence is a scope-of-work item rather than a dispute. An appraisal prepared for an FAA purpose should state the FAA definition, state the market value definition the report otherwise applies, and reconcile them explicitly. The determination discussed in Section 9 turned on credibility, and an unreconciled definitional mismatch is exactly the kind of gap a reviewer reaches for.

Appendix G also added defined terms the order now uses throughout: Aeronautical Use, Non-Aeronautical Use, Airport Purpose, Mixed Use, Federally Acquired Land, Federally Conveyed Land, Release of Federal Obligations, and Residential Through-the-Fence. Two are worth quoting because they draw the line the rate architecture in Section 4 depends on. Non-aeronautical use is “All other uses that are not considered aeronautical or airport purpose. This includes any aviation-related uses that do not need to be located at an airport.” Airport purpose is “Uses of land that are (1) directly related to the actual operation or the foreseeable aeronautical development of a public airport and (2) whose nonaeronautical components do not conflict with existing or foreseeable aeronautical needs/demands.” The classification decides whether the cost-to-market band of paragraph 17.9 applies or the fair market value floor of paragraph 17.11 does, and after the Los Angeles determination the classification is a finding a sponsor can be held to.

12. Reversion Means Two Different Things

Chapter 23 is titled Reversions of Airport Property, and it is not about what a hangar valuation means by reversion. The distinction is worth stating plainly because the same word carries two doctrines and conflating them produces a serious error.

Chapter 23 concerns title returning to the United States. Paragraph 23.1: “The term reversion generally refers to the process by which title to real property is returned to the original conveyor of land (e.g., the U.S.) if a specific event occurs. The right of reversion is based upon a reversionary clause contained in the instrument of conveyance or deed from the U.S. ... Reversionary clauses are typically found in surplus (49 U.S.C. §§ 47151-47153) and non-surplus (49 U.S.C. § 47125) property conveyances. In some cases (typically involving non-surplus property), reversion is automatic under the terms of the reversionary clause. In these cases, the FAA does not have discretion.”

Reversion of tenant improvements to the sponsor at the end of a ground lease, which is what a hangar leasehold valuation turns on, is nowhere in Chapter 23. It appears as a lease review question at paragraph 12.3.b(5): “Does the title to tenant facilities vest in the airport sponsor at the expiration of the lease? Do any lease extension or option provisions provide for added facility rent once the title of facilities vests in the airport sponsor?”

Three provisions of Chapter 23 nonetheless bear on value and have not been used in this literature.

The federal right is unilateral. Paragraph 23.3: “The reversion may be exercised at the option of the United States – with or without the cooperation of the grantee – against all or part of the property in question.” A sponsor’s own title is contingent in a way a private landlord’s is not, and that contingency sits above every leasehold on the field.

It is treated as a taking for procedural purposes. Paragraph 23.15: “Since a property reversion requires a process similar to a physical taking of property, the federal agency must post or mark the property to indicate that it is now the property of the United States.”

And it has defeated a competing condemnation. Chapter 23 records that when a water district moved to condemn wells at Half Moon Bay, the district court held the district’s action sufficient to trigger the federal right of reverter, that “title to the wells had passed to the United States through the exercise of that reversion right, and that the wells therefore could not be condemned by a local or state government agency.” The reverter is also close to non-negotiable: paragraph 22.19 states that “This reverter clause is an important remedy intended to be reserved to the United States Government and will not normally be released. Region/ADOs may not grant such a release.”

13. Citation Practice

The following practice survives review and adjudication.

Cite the obligation to its source, not to the manual. Rate obligations belong to 49 U.S.C. 47107 and the assurances; revenue use to 49 U.S.C. 47133 and the Revenue Use Policy at 64 FR 7696 as amended; rates and charges methodology to the policy at 78 FR 55330; hangar use to 81 FR 38906; land use changes to 88 FR 85474. Cite the manual paragraph after the source, as the agency's reading.

Give every manual citation an edition and a date. Paragraph 17.9 means one thing in the 2009 text, another in Change 3, and the Change 3 thing in 5190.6C. Paragraph 18.18 means something entirely unrelated in the 2009 text. A bare paragraph number is ambiguous across editions and there is no way for a reader to resolve it.

Do not date a provision to February 2026 without checking the allocation. Table 1 gives the chapter-level allocation. For a chapter revised before 2026, the Section Renumbering and Retitling Chart maps the 2009 numbering forward, with the caution that it bottoms out at the 2009 text rather than at Change 3, and that it does not cover Chapter 22.

Treat Chapter 22 citations as broken until re-verified. No crosswalk exists. Locate the provision by subject in the new chapter.

Sweep the documents that recite the manual. Rate resolutions and the board packets that adopted them; rent study and appraisal templates, including the regulatory boilerplate; lease forms and minimum standards documents; anything filed or about to be filed in a Part 13 or Part 16 matter; and expert reports in pending disputes. The correction is usually re-citation rather than a change in substance, but where a matter is active the substance should be checked against the new text, because the revisions run through eleven chapters rather than one, counting the chapter the agency’s list omits.

Update the vocabulary. Long term lease, concurrent land use, interim use, and aviation use of real property are no longer defined terms. Assignment and subletting is now assignment and subleasing.

14. Limitations

This paper is a reading of a published order and of the documents the agency published with it. It is not legal advice, and the legal effect of any provision in a particular matter belongs to counsel.

The allocation in Table 1 comes from the agency's own landing page and Summary of Updates, corroborated for Chapters 17 and 18 against the archived Change 3 text. It is reliable at the chapter level. It is not reliable at the paragraph level for chapters the agency lists as revised in 2026, because the Summary does not always distinguish which sentences within a revised chapter moved when. Where a specific sentence matters, it should be compared against the Change 3 text directly.

Chapter 17 is a known exception to the agency's own list, as Section 3.1 notes. There may be others. The list is the agency's characterization, not an audit.

The community use carve-out is stated here as the order states it. No agency determination construing 49 U.S.C. 47107(v) has issued, and the scope of a qualifying community use is therefore open.

Part 13 determinations are not publicly searchable. The two Part 16 determinations reported in Section 8 are what the public docket contains as of the date of this paper; they are not necessarily all of the agency's application of the order.

No position is taken here on whether the order should have gone through notice and comment. The observation is that it did not, that its predecessor did, and that the difference is evidence about how the agency itself characterizes the document.

15. Conclusion

Order 5190.6C consolidated five years of accumulated revision into a single current text, aligned the manual with the 2024 reauthorization, and rewrote Chapter 22 from the ground up. It did not change what a sponsor owes. The Foreword says so, the absence of any Federal Register notice or comment period says so, and an adjudication issued three weeks after the effective date says so in terms, describing the order as internal guidance and one of its best-known numbers as a recommendation left to sponsor discretion.

Three things follow for valuation work. The first is a correction: the paragraphs most often cited as new to 5190.6C in rent disputes are not new, and a document that dates them to February 2026 is wrong on a checkable fact. The second is a substantive change that has gone almost unremarked: fair market value is no longer an unqualified floor for non-aeronautical use or for disposal, because the community use provision amended by section 706 of the 2024 reauthorization now qualifies both. The third is a housekeeping problem with real consequences: Chapter 22 citations are unmappable, the appraisal standards letter points at three things that no longer exist, and the guidance letter library has not been conformed.

The durable lesson is about where obligations live. They live in the statute, the assurances, and the policies published for comment. The manual states how the agency reads them, and the manual's numbers move. A citation practice that names the source first and the manual paragraph second survives the next renumbering. One that does not will need doing again.

This paper is general information for professionals working in aviation real estate and airport compliance. It is not legal advice and does not create an engagement. The legal conclusion in any matter belongs to counsel.

References

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Airport Compliance Program, 86 Fed. Reg. (Dec. 3, 2021) (notice announcing Change 1 to Order 5190.6B).

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