---
name: faa-grant-assurances-check
description: >-
  Checks an airport sponsor purchase paid for by an FAA Airport Improvement Program grant against the airport
  grant assurances. Looks for qualifications-based selection of architectural, engineering and planning
  consultants, the Buy American preference of 49 USC 50101, Davis-Bacon wages, and the disadvantaged business
  enterprise program required by 49 CFR part 26.
---

# FAA AIP grant conditions check

## Who this applies to

The Airport Sponsor Assurances bind an airport sponsor once it accepts an Airport Improvement
Program grant, for the useful life of the facility, up to twenty years for a public sponsor, and
with no time limit on the exclusive-rights and airport-revenue assurances. The trigger is the
money, not the fact of being an airport: an airport spending its own revenue is in a different
regime, though some obligated-sponsor duties still attach. A planning project attracts only
fifteen of the forty assurances. If this document states no AIP or other FAA funding, say so in
one sentence, report which obligated-sponsor points below still apply, and do not present the
grant assurances as binding it.

## The assurance and provision text is in this Skill's own folder

The documents this check cites are bundled under `reference/`, so quote the
assurance or the required provision itself rather than only naming it. They are long, which is why
you should `grep` for the assurance number, the clause name or the section number and read the
region around the hit. Every file opens with a header naming its publisher, the address it came
from and which edition this copy is. Where the bundled copy and the publisher's current version
differ, the publisher's version governs and this copy is stale.

| File under `reference/`                                     | What it settles                                                                                                |
| ----------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------- |
| `faa-required-contract-provisions-for-aip-contracts.md`     | the provision-by-provision list a federally funded airport contract must carry, with the applicability of each |
| `faa-airport-sponsor-assurances.md`                         | the text of all 40 assurances, including 5, 30 and 34                                                          |
| `49-usc-47107-grant-assurance-statute.md`                   | the statute behind the assurances, including the 47107(a)(17) selection classes                                |
| `faa-ac-150-5100-14e-consultant-selection-and-contracts.md` | the qualifications-based selection procedure, contract format and allowable costs                              |
| `2-cfr-200-procurement-standards-317-to-327.md`             | the procurement standards that reach what the sponsor buys with the grant                                      |
| `2-cfr-1201-dot-adoption-and-317-reversal.md`               | that DOT money removes the state exception at 200.317                                                          |
| `49-cfr-26-51-and-26-55-dbe-contract-goal-pause.md`         | that a sponsor may neither set a DBE contract goal nor count DBE participation until its UCP has re-evaluated  |
| `dot-dbe-final-rule-2026-19688-amendatory-text.md`          | the deadline by which each UCP must finish that re-evaluation, in 26.111(c), which ends the pause              |

49 CFR parts 26 and 23, the DBE and ACDBE programs, are not bundled beyond 26.51, 26.55 and the
final rule's amendments, and the AIP Handbook is not bundled at all. Report a point that turns on
a DBE goal calculation or on a Handbook procedure as unchecked, and name the source, rather than
answering it from memory.

## Do this

1. Read the whole document. Identify the sponsor, the project, and any
   statement of AIP funding, grant number, federal share or Project Application Date.
2. Check these points and report each as found, not found, or not applicable, with the paragraph.
   Before you report a point, grep the bundled file named beside it, because the required wording
   is what decides whether the document satisfies it:
   - Qualifications-based selection is used for the classes 49 U.S.C. 47107(a)(17) names, which
     reach program management, construction management, planning and feasibility studies as well
     as architecture and engineering. Read the statute rather than assuming the list.
   - The advisory-circular vintage the document relies on is pinned to the Project Application
     Date under Assurance 34, not to today.
   - Buy American (49 U.S.C. 50101), Davis-Bacon wage requirements above $2,000, and the DBE
     program requirements under 49 CFR part 26 are addressed where the project's value reaches
     them. Take the applicability of each from `faa-required-contract-provisions-...` and quote
     the required text.
   - If the document sets a DBE contract goal or counts DBE participation toward one, read
     26.51(h) and 26.55(i) in `49-cfr-26-51-and-26-55-...`. They forbid both from the date they
     state until the sponsor's Unified Certification Program has finished re-evaluating its firms,
     and `dot-dbe-final-rule-...` gives the deadline for that at 26.111(c). A goal set inside that
     window is a finding unless the document says the sponsor's UCP has finished. The FAA contract
     provisions describe goals as live and never mention the pause, so they cannot show on their own
     that goal language is compliant.
   - The civil rights clauses that Assurance 30 requires appear, and they appear regardless of the
     funding source of this particular contract.
   - Section 889 covered telecommunications equipment is addressed.
   - The procurement method and the competition it provides satisfy 200.318 to 200.320, and the
     document does not claim the 200.317 state exception, which 1201.317 removes for FAA money.
   - The document does not cite AC 150/5100-15A, which was canceled on 5 March 2012 and superseded
     by 49 CFR parts 23 and 26; an old project file may still carry it.
3. Suggest an edit only where the fix is wording inside this document for one of the points above,
   such as an obsolete advisory-circular citation; otherwise describe the gap in one line.
4. End with one short paragraph headed "Not checked", naming what this check did not
   cover and why, in plain sentences.

## Sources

Every rule quoted above is carried in the bundled `reference/` folder, so this check does not
need to fetch anything. These are the editions it was built from, and the place to confirm a
point that matters:

- **FAA Required Contract Provisions for Airport Improvement Program and Obligated Sponsors**  
  https://www.faa.gov/airports/aip/procurement/federal_contract_provisions  
  the version published 2026-03-17
- **FAA Airport Sponsor Assurances, all 40 assurances**  
  https://www.faa.gov/airports/aip/grant_assurances  
  April 2025
- **49 U.S.C. 47107, project grant application approval conditioned on assurances**  
  https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title49-section47107&num=0&edition=prelim  
  current preliminary release of the United States Code
- **FAA Advisory Circular 150/5100-14E Change 1, consultant services for airport grant projects, chapters 1 to 4**  
  https://www.faa.gov/documentLibrary/media/Advisory_Circular/150-5100-14E-consolidated.pdf  
  Revision E, Change 1, 2015-09-25
- **2 CFR 200.317 to 200.327 and 2 CFR Part 1201, the procurement standards that reach AIP money**  
  https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200  
  eCFR as amended through 2026-09-01
- **49 CFR Part 26, disadvantaged business enterprises, which is named rather than carried here**  
  https://www.ecfr.gov/current/title-49/subtitle-A/part-26  
  consult the publisher
- **49 CFR Part 23, airport concession disadvantaged business enterprises, named rather than carried here**  
  https://www.ecfr.gov/current/title-49/subtitle-A/part-23  
  consult the publisher
- **FAA Order 5100.38D Change 1, the AIP Handbook, named rather than carried here**  
  https://www.faa.gov/airports/aip/aip_handbook  
  consult the publisher
