Airport Improvement Program Handbook

Essential Aero, Inc., a U.S. manufacturer of autonomous airfield safety equipment, supports the Draft Order's recognition of FOD removal equipment as eligible airfield safety equipment. They request specific clarifications to ensure that self-propelled autonomous systems and airport-owned autonomous ground vehicles qualify for funding and equipment standards.

Thibaut Giret, a legal practitioner in the airport infrastructure industry, argues that the draft order creates compliance uncertainty for design-build projects due to structural conflicts with Buy American requirements and lacks clear definitions for "unique complexities." He proposes amending the order to include a staged certification mechanism and a non-exhaustive list of factors to better accommodate airport technology and systems programs.

The commenter argues that the Legacy Crosswind section in Appendix B, Table B-3.3 of the Airport Improvement Program Handbook is overly burdensome and exceeds the scope of 49 USC 47102(V). They specifically point out several requirements in the table that are either not in the regulation or directly conflict with existing regulatory language regarding wind coverage.