Airport Certification Requirements Under FAA Part 139

To host scheduled airline flights on aircraft with more than nine passenger seats, or unscheduled flights on aircraft with 31 or more seats, a U.S. airport must hold an FAA Airport Operating Certificate issued under 14 CFR Part 139. Meeting the FAA Part 139 airport certification requirements means fitting one of four certificate classes, writing an Airport Certification Manual that spells out how the facility will comply with roughly 30 safety areas, passing an on-site FAA inspection, and then maintaining continuous compliance through annual inspections and manual updates. About 520 airports currently hold this certificate, from major hubs to small regional fields.¹

Which Airports Have to Be Certified

Federal law identifies three triggers. Any airport serving an air carrier with aircraft designed for 31 or more passenger seats needs a certificate, whether those flights are scheduled or charter. Airports outside Alaska that serve scheduled passenger flights on aircraft with 10 to 30 seats also need one. And the FAA Administrator can require a certificate at any other airport when safety concerns justify it.²

Alaska has a carve-out from the second trigger. Airports in Alaska serving only scheduled 10-to-30-seat operations are not required to hold a Part 139 certificate, in recognition of the state’s reliance on small aircraft for basic transportation.¹ Operating an airport without a required certificate is prohibited, and violations can lead to civil penalties under 49 U.S.C. 46301.

The Four Certificate Classes

Part 139 sorts certificates into four classes by the type of air carrier activity the airport is authorized to handle. The class determines how demanding the safety obligations will be, so classifying correctly at the outset matters.

Class I authorizes scheduled operations of large air carrier aircraft (31+ seats), and also permits unscheduled large carrier operations and scheduled small carrier operations. It is the most comprehensive category and carries the heaviest regulatory load.
Class II authorizes scheduled operations of small air carrier aircraft (10–30 seats) and unscheduled large carrier operations, but not scheduled large carrier flights.
Class III authorizes only scheduled small air carrier operations. No large carrier flights, scheduled or unscheduled.
Class IV authorizes only unscheduled large carrier operations, such as charters or seasonal service. No scheduled service.

The dividing lines are whether flights are scheduled or unscheduled and whether the aircraft is large (31+ seats) or small (10–30 seats).³ An airport that wants to move up a class must amend its certification manual and meet the additional requirements before the FAA approves the change.

The Airport Certification Manual

The Airport Certification Manual is the core of the process. It describes exactly how the airport will comply with every Part 139 safety requirement, and once the FAA approves it, every procedure in the manual becomes a legally binding commitment. The operator submits the manual together with FAA Form 5280-1 to apply for the certificate.⁴

The manual has to cover roughly 30 distinct elements, scaled to the airport’s class. These include maps identifying terrain features relevant to emergencies, a description of every movement area available to air carriers, runway and taxiway marking systems, pavement and safety area maintenance, lighting and signage upkeep, personnel training programs, and the airport’s emergency plan. It also addresses obstruction marking, navigational aid protection, ground vehicle control on the airfield, and airport condition reporting.⁵ The FAA publishes a sample template through its Part 139 guidance materials.¹

A handful of the manual’s elements drive most of the cost and most of the common inspection failures.

Aircraft Rescue and Firefighting

Aircraft rescue and firefighting, or ARFF, is where the money is. Part 139 assigns each airport an ARFF index from A through E, based on the length of the largest air carrier aircraft it serves and the frequency of departures. The index dictates the minimum number of firefighting vehicles, the types and quantities of extinguishing agents, and the operational readiness standards during air carrier operations.⁶

Index A requires a single vehicle carrying at least 500 pounds of dry chemical or clean agent. Index E requires three vehicles carrying a combined minimum of 6,000 gallons of water with aqueous film-forming foam plus a dedicated dry chemical vehicle.⁶ The jump from one vehicle to three, each costing over a million dollars, is where small airports often run into budget trouble.

Response times are rigid. The first ARFF vehicle must reach the midpoint of the farthest air-carrier-serving runway within three minutes of an alarm and immediately begin applying extinguishing agent. Any remaining required vehicles must arrive at the same point within four minutes. Every ARFF vehicle must have two-way radio communication with the control tower, other emergency vehicles, and fire stations. If a required vehicle becomes inoperative, the airport has to replace it immediately or notify the FAA Regional Airports Division Manager and every air carrier using the airport. If the required capability is not restored within 48 hours, further restrictions take effect.⁷

Self-Inspection Program

Every certified airport runs its own inspection program to catch safety problems between FAA visits. Inspections happen daily at a minimum. Additional inspections are required whenever unusual conditions arise, such as active construction or severe weather, and immediately after any accident or incident.⁸

The airport must have equipment for conducting inspections, reliable communication between airport staff and air carriers, and a reporting system that gets unsafe conditions corrected promptly. Inspection personnel receive training at least every 12 months covering airport familiarization, emergency plans, NOTAM procedures, and ground vehicle rules. Inspection records, including conditions found and corrective actions, are kept for at least 12 months.⁸

Wildlife Hazard Management

Certain triggering events require a formal wildlife hazard assessment, performed by a qualified wildlife damage management biologist. Triggers include a wildlife strike that causes substantial damage or an engine ingestion. The assessment identifies species, movement patterns, seasonal presence, and on-airport features that attract them.⁹

If the FAA determines a full wildlife hazard management plan is needed, the airport develops and implements one based on the assessment. The plan covers population management, habitat modification, land use changes, required wildlife control permits, and procedures for inspecting movement areas before air carrier operations begin. The airport reviews and updates the plan at least every 12 months.⁹

Snow and Ice Control

Airports in areas where winter weather occurs must maintain a snow and ice control plan covering prompt removal of snow, ice, and slush from all movement areas.¹⁰ The plan identifies the specific equipment used for clearing, the approved de-icing chemicals, and the priorities for which surfaces get cleared first during a storm. FAA inspectors know how long it takes to clear a 10,000-foot runway, and a plan whose timelines don’t match the equipment on hand won’t survive review.

Fuel Storage and Hazardous Materials

Every certified airport must establish fire and explosion protection standards for fuel storage and dispensing, including fuel farm and storage area safety, mobile fueling operations, and compliance with the local fire code. Airports that handle cargo must also maintain procedures for safely handling regulated hazardous materials intended for air transport.¹¹

Applying and Getting Inspected

The operator submits Form 5280-1 with two copies of the proposed Airport Certification Manual to the Regional Airports Division Office. The application must include documentation indicating when air carrier service will begin.¹²

The FAA reviews the application and manual for completeness and compliance. This is not a rubber-stamp review. The agency works with the operator to refine the manual and can require changes to procedures that fall short of regulatory standards.¹² Once the paperwork is satisfactory, an FAA inspector goes on site to verify that the physical facility and staffing match what the manual describes. That means walking the airfield, testing ARFF response times, evaluating runway surface conditions, checking lighting calibration, and interviewing personnel to confirm they understand the protocols.

If the facility passes, the FAA issues the Airport Operating Certificate and commercial operations can begin. If it does not, the inspector issues a letter of correction listing the specific deficiencies. There is no fixed correction period; the inspector and airport management agree on a reasonable date for resolving each issue.¹³ A follow-up inspection confirms the fixes before the certificate issues. No commercial air carrier service can start until every deficiency is resolved.

Keeping the Certificate

An Airport Operating Certificate does not expire. It remains in effect until the airport surrenders it or the FAA suspends or revokes it. Indefinite duration comes with a condition: the airport must maintain continuous Part 139 compliance, and the FAA checks.

Annual Inspections

Nearly 35 FAA Airport Certification Safety Inspectors handle certified airports, typically on a yearly cycle. The FAA can also perform unannounced inspections at any time.¹⁴ These follow the same pattern as the initial inspection: document review, physical walkthroughs, equipment checks, and personnel interviews. When violations turn up, the inspector issues a letter of correction and the airport and FAA agree on a correction timeline.¹³

Amending the Manual

Airports change. New runways get built, carriers change service patterns, equipment gets replaced. When any of these affect Part 139 compliance, the airport must amend its certification manual. The operator submits the proposed amendment in writing to the Regional Airports Division Manager at least 30 days before the intended effective date.¹⁵

The FAA can also initiate amendments when safety concerns warrant. In that case, the airport gets at least seven days to submit written objections, and the amendment takes effect no sooner than 30 days after the airport receives notice. If the FAA declares an emergency, it can impose an immediate amendment with no waiting period, though the airport can petition for reconsideration within 30 days.¹⁵

Enforcement

When an airport falls out of compliance, the FAA’s first move is typically an administrative action: a letter of correction or an agreement to fix specific problems by a set date. Continued violations can bring financial penalties for each day the violation persists.¹⁴ In the most serious cases, the FAA can suspend or revoke the certificate, which shuts down all air carrier operations at the facility.

The ARFF Exemption for Small Airports

Airports that enplane fewer than one-quarter of one percent of total national passengers annually can petition for an exemption from ARFF equipment requirements. The petition has to show that full compliance would be unreasonably costly or impractical, and it must include an itemized cost breakdown, current staffing levels, financial reports, enplanement data, and a history of air carrier service at the airport.¹⁶ It goes to both the Regional Airports Division Manager and the Federal Docket Management System, and it must be filed at least 120 days before the proposed effective date. The relief is narrow: it applies only to ARFF equipment, not to the rest of Part 139.

1
Federal Aviation Administration. Part 139 Airport Certification
2
Office of the Law Revision Counsel. 49 Code 44706 – Airport Operating Certificates
3
eCFR. 14 CFR 139.5 – Definitions
4
Federal Aviation Administration. Form FAA 5280-1 – Application for Airport Operating Certificate
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eCFR. 14 CFR 139.203 – Contents of Airport Certification Manual
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eCFR. 14 CFR 139.317 – Aircraft Rescue and Firefighting: Equipment and Agents
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eCFR. 14 CFR 139.319 – Aircraft Rescue and Firefighting: Operational Requirements
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eCFR. 14 CFR 139.327 – Self-Inspection Program
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eCFR. 14 CFR 139.337 – Wildlife Hazard Management
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eCFR. 14 CFR 139.313 – Snow and Ice Control
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eCFR. 14 CFR 139.321 – Handling and Storing of Hazardous Substances and Materials
12
Federal Aviation Administration. Certification Process – Part 139 Airport Certification
13
Federal Aviation Administration. Part 139 Inspections
14
Federal Aviation Administration. Part 139 Airport Certification – What Is Part 139
15
eCFR. 14 CFR 139.205 – Amendment of Airport Certification Manual
16
eCFR. 14 CFR 139.111 – Exemptions