Regulatory Alert: FAA Releases Guidance on AIP Changes from the 2024 FAA Reauthorization Act

FAA Releases Guidance on AIP Changes from the 2024 FAA Reauthorization Act
April 8, 2025

Yesterday, the Federal Aviation Administration (FAA) released two “Reauthorization Program Guidance Letters” (R-PGL) that implement or provide guidance to field offices on how to interpret changes to the Airport Improvement Program (AIP) made by Congress through the FAA Reauthorization Act of 2024. Most of the provisions from the law addressed by the R-PGLs focus on changes made to AIP project eligibility, the Voluntary Airport Low Emissions (VALE) Program, and the Airport Zero Emission Vehicle (ZEV) Program.

You can view the R-PGL 25-01, “Runway Projects,” and R-PGL 25-02, “AIP Discretionary Set Aside.”

Overview of FAA Reauthorization Act. In May 2024, Congress passed a multi-year bipartisan and bicameral FAA reauthorization bill that increases AIP funding levels to $4 billion annually, authorizes $200 million annually for resilience and runway safety projects, and authorizes $350 million over a five-year period to help airports transition to fluorine-free firefighting (F3) agents. AAAE developed a comprehensive summary and guide to the FAA reauthorization law, which includes an overview of all relevant provisions, deadlines that Congress has established for FAA to comply, and status of implementation. We keep this document updated as FAA and other agencies implement the law. You can access AAAE’s summary here.

Summary of FAA’s R-PGLs. FAA’s two R-PGLs provide implementation details on each of the following changes, among others, that Congress made to the AIP through the FAA reauthorization law:

AIP Project Eligibility Changes: Congress made a variety of changes to the types of projects that are AIP eligible. R-PGL 25-01 addresses the eligibility of secondary runways at nonhub airports and reconstruction and rehabilitation of existing crosswind runways. R-PGL 25-02 addresses the eligibility of improvements to meet electrical power demands, such as smart glass and renewable energy generation and storage infrastructure, and certain airport-owned unleaded avgas and hydrogen fueling systems.
General Aviation Airport Runway Extension Pilot Program: Congress required FAA to establish a new program that provides AIP funding to GA airports to increase their usable runway length capability. FAA must issue grants to no more than two airports per fiscal year through this program. In R-PGL 25-01, the agency noted that they will be formally soliciting applications for this program at a later date, but the letter outlined what type of data airport sponsors should be prepared to provide in their application.
VALE Program: Congress removed the requirement for an airport to be located in an EPA air quality nonattainment or maintenance area in order to be eligible for a grant under the VALE Program. In addition, airports are no longer required to receive an “Airport Emission Reduction Credit” (AERC) from their state air quality agency in order to be eligible for a grant. R-PGL 25-02 implements these changes and provides guidance to field offices.
Airport ZEV and Infrastructure Pilot Program: Congress directed FAA to include additional selection criterion for projects proposed for funding under the Airport ZEV Program. The agency must also give priority consideration to applicants that provide a “long-term management plan” for eligible vehicles and equipment. R-PGL 25-02 implements these changes and provides guidance to field offices.