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FAA Land Use Inspections: What They Check and How to Prepare

T

The Hangar Direct Team

hangardirect.com

complianceFAAairport operations

An FAA land use inspection is mostly a records exercise. Before anyone walks your ramp, the FAA compares your Airport Layout Plan, your Exhibit A property map, your parcel maps, and your list of leaseholds, looking for places where they disagree. Airports that can reconcile those documents before the letter arrives usually have a short inspection. Airports that cannot usually end up with a corrective action plan.

Land use inspections get less attention than Part 16 complaints, but they reach airports that nobody has complained about. They are also where non-aeronautical hangar use, old releases, and outdated property maps tend to surface together. Chapter 21 of FAA Order 5190.6C, dated February 20, 2026, streamlined the inspection guidance into a single sequence. This post walks through it from the airport's side of the table.

This is a general explainer, not legal advice. Your FAA Airports District Office and your airport attorney are the authorities on any specific situation.

Why the Program Exists

It started with a GAO report. Chapter 21 traces the program to GAO/RCED-99-109, "General Aviation Airports: Unauthorized Land Use Highlights Need for Improved Oversight and Enforcement," and Senate Report No. 106-55 (May 1999). The Senate report concluded that the FAA lacked internal controls over GA land use, "that self-certification is not sufficient, and that unauthorized land uses impact airport revenue and safety."

The minimums are modest. Under Section 21.2, the FAA Regions and ADOs must "conduct a minimum of two land use inspections annually per region for General Aviation (GA) airports." Section 21.3.b says the program targets "a minimum of 18 airports (two per FAA region per year)." The FAA's Office of Airport Compliance reports the results to Congress.

It ties into a list you do not want to be on. Under 49 U.S.C. § 47103(d), the FAA reports to Congress every two years with "a detailed statement of airports that are not in compliance with grant assurances or other requirements with respect to airport lands," and it does not need a final determination to include an airport. Under Section 21.4.e, noncompliant land uses go into that report "if those land uses remain unresolved at the end of the fiscal year."

How Airports Get Selected

Selection is deliberate. Section 21.4.a says "a random process in selecting airports is not considered to be efficient," and each Region builds its own process with the ADOs and state aviation agencies.

Who goes to the top of the list:

  • Known or suspected problems. "Preference should be given to selecting airports where it is known or suspected that the airport is not in compliance with one or more of the grant assurances, particularly where it appears that federally acquired or federally conveyed airport property has been disposed of, and/or is being used for non-aeronautical purposes, without FAA approval."
  • Headquarters requests. The Office of Airport Compliance may request an inspection when it "would directly benefit a current investigation or formal complaint."
  • Frequent release requests. "An excessive number of requests for airport property releases and/or a significant amount of released land may require additional oversight."
  • Size and activity. Larger airports with more federally acquired land, more based aircraft, and more operations offer "potential high return" for an inspection.

Information comes from "previous site inspections, complaints, and existing documents including the Airport Layout Plan (ALP) or Exhibit 'A'." In other words, a tenant complaint about a neighbor's hangar can put the whole airport on the list.

What Happens Before the Inspection

Section 21.4.b says the Region or ADO "should notify the airport of the upcoming inspection." The FAA then reviews its own files, and the chapter is specific about what it checks:

  • Obligating documents. Grants, surplus property deeds, nonsurplus conveyances, and any special conditions attached to them.
  • Land use maps. "The majority of the pre-inspection should focus on inconsistencies between the ALP, Exhibit 'A,' parcel maps, or any other land use document."
  • Self-certification. The FAA reviews these, but self-certification "is not a substitute for an actual land use inspection."
  • Grant-acquired and conveyed land. Is it "still being used for the purpose for which it was acquired"? This includes noise land.
  • Release documentation. Past releases, the conditions attached, fair market value, whether released land was sold and the deed recorded, and whether the proceeds were deposited into the airport account.
  • Planning documents. The master plan, Part 150 studies, and environmental documents.
  • Correspondence. This includes complaints.
  • Your leasehold list. "Obtain a list of leaseholds, both aeronautical and nonaeronautical, so they are known to the inspection team before the onsite inspection occurs." The FAA uses that list "to crosscheck the ALP and Exhibit 'A' for appropriate land uses."

That last item is where most airports feel the pressure. If the leasehold list comes from three spreadsheets and a filing cabinet, the inconsistencies the FAA is looking for are often inside your own records before they ever reach the maps.

What Happens On Site

The onsite visit "may last from a half a day to multiple days." Section 21.4.c lists what inspectors do:

  • Check construction against the ALP. They look at improvements under Form 7460-1 review or under construction. "No actual or proposed development or use of land and facilities should be contrary to the FAA-approved ALP."
  • Confirm actual use. "Confirm land uses to ensure the intended or approved use corresponds to the actual use," across aeronautical, industrial, agricultural, and recreation areas.
  • Compare property to the ALP. "The FAA must approve any non-aeronautical or mixed use of land purchased with federal funding or that was federally conveyed."
  • Review leases and financials. This includes appraisals and airport account records where depicted and actual uses do not match.
  • Check released land. Is it used in line with the release and its special conditions?

The Findings That Come Up Most

Section 21.4.d lists the usual problems. For hangar operators, these are the ones to read twice.

Non-aeronautical use of hangars. "The most common improper and noncompliant land uses are situations where nonaeronautical leaseholds are located on designated aeronautical use land without FAA consent or approval." The first example given: "using hangars to store vehicles or other unrelated items." The chapter cites the FAA's 2016 hangar use policy (81 Fed. Reg. 38906), which we cover in our hangar use policy post. If you have a legitimate path for interim non-aeronautical use, this post covers it. An undocumented arrangement is not that path.

Outdated Exhibit A. "An outdated ALP or Exhibit 'A' may be an indicator of unauthorized land uses." Where the ALP and Exhibit A disagree, "Exhibit 'A' takes precedence since it is part of the grant agreement establishing the obligation." When there is a conflict, inspectors review the Exhibit A "from all grants within the 20 years prior to the inspection" to see whether the sponsor changed the description of obligated property, "possibly without FAA being aware."

Missing release documents. Airports have told the FAA that land was released, or their ALP shows it as released, "yet no release documents can be found." Without the document there is no way to confirm the release or its conditions.

ALP depiction is not approval. "Approval of an ALP showing future nonaeronautical land use does not constitute FAA approval for that nonaeronautical use when it may actually occur. The ALP is a planning document only."

Residential hangars. A favorable airspace determination "does not by itself satisfy land use compliance requirements." The chapter's example: "a hangar on the airport might not pose an airspace issue, but if that hangar is intended to be used as a residential hangar, it would still represent a compliance problem as an incompatible land use."

The chapter also flags farm leases that run longer or cheaper than the FAA approved, golf courses, shooting ranges, and public roads built through airport property without approval.

Corrective Action and How Long It Stays Open

The FAA sends a letter. Under Section 21.4.e, the airport receives "a letter stating the results of the inspection, including all land use discrepancies." The letter includes "detailed information on how the airport can return to compliance" and "a timeline for completion."

Typical asks. "The letter could be as simple as requesting an updated ALP within 120 days or requesting the airport to submit a formal request for a land release to correct a land use situation within 30 days." At the other end, it can require removing an obstruction. Inspectors also note other grant assurance problems they see, such as revenue use or exclusive rights issues.

It stays open until the FAA closes it. Under Section 21.4.f, "If a corrective action is required, the land use inspection will remain open until the Region or ADO finds the sponsor has completed the corrective action in a manner that is satisfactory to the FAA." The Region forwards the report to headquarters within 30 days of the inspection.

A Real Example of a Slow Response

The Fulton County Office of the County Auditor's July 2025 audit of Fulton County Executive Airport shows how a land use question drags on. According to the audit:

  • The inquiry. On May 23, 2022, the FAA sent the County a Letter of Inquiry about whether it "may have converted approximately 340-355 acres" of AIP-funded aeronautical land "to nonaeronautical use, without requesting the required release of obligations."
  • The second response. After providing some information, the department responded further on March 31, 2023, "refuting some of the allegations, although no efforts were made since that date to ensure the inquiry was resolved."
  • The follow-up. On March 27, 2025, the FAA followed up to say "the issue remained unresolved and pertinent documentation was still needed."
  • The extension. The County was given an extension to May 28, 2025, and responded by that date.

This was a letter of inquiry rather than a Chapter 21 inspection, but the takeaway is the same. The FAA's question was about documents. The audit notes that while some information was provided, "other information could not be located."

Section 743 Changed the ALP Side, Not the Inspection Side

The FAA Reauthorization Act of 2024 revised the 2018 law limiting FAA authority over airport land not acquired with federal help. Kaplan Kirsch's summary says Section 743 "clarifies that FAA retains jurisdiction over any property that was acquired with federal assistance," and for projects outside the FAA's ALP approval authority, the FAA "has 45 days to assert jurisdiction" after a sponsor gives notice. That makes it more important, not less, to know which parcels are federally acquired or conveyed. The inspection still turns on your Exhibit A.

What This Means Practically: Inspection Prep Checklist

Do this before any letter arrives:

  • Build one leasehold list. Include every leasehold, aeronautical and nonaeronautical, with tenant, parcel or building ID, stated use, actual use, lease dates, and rent.
  • Lay it against the maps. Overlay the list on your current ALP and on the Exhibit A from each grant in the last 20 years. Flag every parcel where the documents disagree.
  • Find every release document. If the ALP shows released land, have the release letter, its conditions, the appraisal, the recorded deed, and proof the proceeds went to the airport account.
  • Walk the hangars. Note anything other than aircraft and aeronautical items, and match it to your hangar use policy and any FAA-approved interim use.
  • Confirm current FAA approval for every non-aero use. Check that each lease's term and rent match what the FAA approved. An ALP depiction is not approval.
  • Adopt a written hangar inspection policy. Then keep the inspection records. Our hangar inspection program guide covers how to set one up.
  • Track every FAA letter. Give each inquiry an owner and a response deadline, and follow up until the FAA confirms it is closed.
  • Update the ALP if it is stale. The FAA's typical request is 120 days, and that goes faster if you have already started.

Most of this checklist is keeping a current leasehold list that matches what is actually inside each building. That is the record Hangar Direct maintains at platform.hangardirect.com.

Sources

Hand the inspector a leasehold list in minutes

The first thing a land use inspection asks for is every leasehold, aeronautical and nonaeronautical, matched to your maps. Book a walkthrough and see how airports keep that list current.

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