Statutory Authority and Regulatory Framework

The authority for airport certification resides in 49 U.S.C. § 44706, which directs the FAA Administrator to issue an airport operating certificate (AOC) to any person seeking to operate an airport that (1) serves an air carrier operating aircraft designed for at least 31 passenger seats, (2) serves any scheduled passenger operation of an air carrier operating aircraft designed for more than 9 but fewer than 31 passenger seats (except in Alaska), or (3) the Administrator otherwise requires to have a certificate.

The implementing regulation is 14 CFR Part 139, Certification of Airports. Part 139 was substantially revised by a final rule published February 10, 2004 (69 FR 6424), with safety enhancements added January 16, 2013 (78 FR 3311), and Safety Management System (SMS) requirements added February 23, 2023 (88 FR 11642).

Certification is voluntary in one direction: 49 USC § 44706(d) provides that a person need not obtain an airport operating certificate if they do not wish to operate an airport serving the specified air carrier operations. However, once an airport chooses to serve those operations, compliance with Part 139 is mandatory.

As of June 12, 2025, the FAA has certificated approximately 520 U.S. airports under Part 139. The FAA maintains the Part 139 Airport Certification Status List, updated every 28 days, which identifies each certificated airport by state, identifier, classification, ARFF index, and SMS trigger status.

Airport Classification

Part 139 defines four classes of certificated airports based on the type of air carrier operations served:

Class I airports carry the most extensive obligations across Subpart D. Each descending class carries fewer operational and safety requirements, calibrated to the frequency and type of operations served.

The Airport Certification Manual (ACM)

The Airport Certification Manual is the written document detailing how an airport operator will comply with Part 139 requirements. The ACM functions as the operating agreement between the airport and the FAA—it describes specific procedures, identifies responsible personnel, and maps facilities and equipment to each regulatory requirement.

Airport operators that previously held a Part 139 Limited AOC maintained a modified version known as Airport Certification Specifications (ACS). Under the revised Part 139, all ACS documents were required to be converted to full ACMs.

A new airport seeking certification follows a process that begins with contacting the appropriate FAA Regional Airports Division Office. The application (Form 5280-1) is submitted along with the draft ACM. The FAA conducts a review of the airport's layout, operations, and infrastructure, followed by an initial inspection. If the FAA finds that the applicant is "properly and adequately equipped and able to operate safely," the AOC is issued. The FAA will not issue an AOC solely for the purpose of marketing an airport to air carriers—written documentation that air carrier service will begin on a date certain is required.

Operational Requirements: Subpart D

Part 139 Subpart D (§§ 139.301–139.343) establishes the operational and safety requirements that certificate holders must meet. The scope of requirements varies by airport class, but Class I airports must comply with all provisions.

Aircraft Rescue and Firefighting (ARFF)

ARFF is one of the most operationally intensive Part 139 requirements, governing equipment, agents, staffing, training, and response times that airports must maintain during air carrier operations.

ARFF Index Determination (§ 139.315). Each certificated airport is assigned an ARFF Index based on (1) the length of air carrier aircraft serving the airport and (2) the average daily departures of those aircraft. Aircraft lengths are grouped into five Index categories:

If five or more average daily departures of air carrier aircraft fall within a single Index group, the longest aircraft with five or more daily departures determines the Index. If fewer than five average daily departures of the longest aircraft serve the airport, the required Index drops to the next lower group.

ARFF Equipment and Agents (§ 139.317). Each Index prescribes minimum vehicle counts and extinguishing agent quantities:

Vehicles with a water tank capacity of 500–2,000 gallons must have a turret discharge rate of at least 500 gallons per minute. Vehicles with a capacity of 2,000 gallons or more must have a turret discharge rate of at least 600 gallons per minute.

ARFF Response Time (§ 139.319). Within 3 minutes of alarm activation, at least one required ARFF vehicle must reach the midpoint of the farthest runway serving air carrier aircraft from its assigned post and begin application of extinguishing agent.

Airport Emergency Plan (§ 139.325)

Each certificate holder must develop and maintain an Airport Emergency Plan (AEP) with procedures for response to nine categories of emergencies:

1. Aircraft incidents and accidents
2. Bomb incidents
3. Structural fires
4. Fires at fuel farms or fuel storage areas
5. Natural disasters
6. Hazardous materials/dangerous goods incidents
7. Sabotage, hijacking, and other unlawful interference with operations
8. Failure of power for movement area lighting
9. Water rescue situations, as appropriate

The AEP must include a communications network, medical services provisions, inventories of vehicles and facilities for transporting injured and uninjured persons, crowd control provisions, and procedures for disabled aircraft removal.

Exercise requirements:

• Class I airports: Full-scale AEP exercise at least once every 36 consecutive calendar months.
• All classes: AEP review with all coordinating parties at least once every 12 consecutive calendar months.

The FAA has issued CertAlert 22-02 (June 27, 2022) reemphasizing guidance that exercises involve all parties with interest in the AEP and that exercise design follow HSEEP-compliant methodology.

Daily Self-Inspection (§ 139.327)

Each certificate holder must maintain a self-inspection program requiring, at minimum, a daily inspection of the Airport Operations Area (AOA). The FAA's AC 150/5200-18D (September 27, 2022) provides that "the Part 139 requirement to inspect daily does not mean that only one self-inspection is required each day." Larger airports conduct multiple inspections daily. If the airport serves air carriers during hours of darkness, a nighttime inspection is also required.

The self-inspection program comprises four components:

• Regularly scheduled (daily) inspections of physical facilities, including lighting inspections at night
• Continuous surveillance of activities and conditions
• Periodic inspections of activities and facilities (weekly, monthly, or quarterly)
• Special inspections triggered by complaints, unusual conditions, or unusual events

Deficiencies must be logged with the date and time corrective measures were taken.

Wildlife Hazard Management (§ 139.337)

Part 139 requires certificate holders to take immediate action to alleviate wildlife hazards whenever detected. A formal Wildlife Hazard Assessment (WHA) is triggered when any of the following events occurs on or near the airport:

1. An air carrier aircraft experiences multiple wildlife strikes
2. An air carrier aircraft experiences substantial damage from striking wildlife
3. An air carrier aircraft experiences an engine ingestion of wildlife
4. Wildlife of a size or in numbers capable of causing any of the above events is observed to have access to any airport flight pattern or aircraft movement area

The WHA must be conducted by a qualified wildlife damage management biologist and must identify species, locations, movements, attractant features, hazards, and recommended actions. If the FAA determines that a Wildlife Hazard Management Plan (WHMP) is needed, the airport operator must develop and implement the plan, which is then incorporated into the ACM and reviewed annually.

Additional Subpart D Requirements

Beyond the provisions detailed above, Subpart D addresses personnel training and recordkeeping, surface maintenance (runways, taxiways, aprons), safety area condition standards, marking and lighting, snow and ice control, HAZMAT handling, ground vehicle operations, obstruction identification, NAVAID protection, public protection measures, and airport condition reporting.

Safety Management Systems (Subpart E)

On February 23, 2023, the FAA published a final rule (88 FR 11642) adding Subpart E to Part 139, requiring certain airport certificate holders to develop, implement, maintain, and adhere to an Airport Safety Management System (SMS).

The rule does not apply to all 520 Part 139 airports. Under § 139.401(a), an airport must implement SMS if it meets at least one of three triggering criteria:

1. Hub trigger: Classified as a large, medium, or small hub based on passenger data from the FAA Air Carrier Activity Information System (ACAIS)
2. Operations trigger: Has a 3-year rolling average of 100,000 or more total annual operations (sum of all arrivals and departures)
3. International trigger: Classified as a port of entry, designated international airport, landing rights airport, or user fee airport

Based on these criteria, over 200 of the busiest U.S. commercial airports are required to implement SMS.

An airport qualifying exclusively under trigger (3) with no tenants required to maintain an SMS under any jurisdiction is eligible for a waiver from the SMS requirement, subject to FAA approval and biennial revalidation.

The Part 139 SMS comprises four components, mirroring the ICAO Annex 19 framework:

1. Safety Policy: Establishes management's commitment to safety, defines acceptable levels of safety performance, and assigns safety responsibilities
2. Safety Risk Management: Processes for hazard identification, risk analysis, and risk assessment
3. Safety Assurance: Processes for monitoring and measuring safety performance, managing change, and continuous improvement
4. Safety Promotion: Training and communication programs to create a safety culture

The implementation timeline ranges from four to five and a half years depending on the airport's classification and the applicable triggering criteria. The Part 139 Airport Certification Status List identifies each airport's SMS trigger and whether a waiver has been granted.

FAA Inspection Process

The FAA employs a limited inspection workforce to conduct annual certification inspections of Part 139 airports. The FAA may also conduct unannounced inspections.

A Part 139 certification inspection evaluates compliance across all applicable Subpart D requirements—ARFF readiness, pavement conditions, marking and lighting, wildlife management, the AEP, self-inspection records, ground vehicle training, NOTAM procedures, and fueling operations, among others.

As a reference point for inspection outcomes: William P. Hobby Airport (HOU) and Ellington Airport (EFD), both operated by the Houston Airport System, received zero discrepancies in their 2025 Part 139 inspections. Ellington Airport received zero discrepancies in its annual inspection in each of the years from 2005 through 2025.

Financial and Operational Dimensions

Part 139 certification carries ongoing operating cost obligations. While 14 CFR Part 139 does not prescribe specific budget levels, the operational mandates translate into recurring expense categories:

• ARFF staffing: ARFF capability must be available during all air carrier operations. For airports with scheduled service from early morning through late evening, this means continuous staffing coverage across shifts. Staffing levels correspond to the number of ARFF vehicles required by the airport's Index.
• ARFF vehicles and equipment: ARFF vehicles carry capital costs (acquisition) and operating costs (maintenance, agent replenishment, training). The 2013 safety enhancements eliminated an older vehicle exception, requiring certificate holders to phase out vehicles that did not meet current performance standards.
• Daily inspection personnel: The self-inspection requirement, including nighttime inspections, requires trained operations staff on a daily basis.
• Wildlife management: Airports with an active WHMP incur costs for wildlife biologist services, habitat modification, and active deterrence measures.
• Emergency exercises: Full-scale exercises every 36 months (Class I) and annual AEP reviews involve coordination costs with external agencies.
• Recordkeeping and training: Part 139 requires documented training programs for ARFF, inspection, and ground vehicle operations personnel, with recordkeeping systems for inspections, discrepancies, and corrective actions.

For airports that are not yet certificated, the decision to pursue Part 139 certification involves weighing these recurring costs against the ability to attract commercial air service and, for airports in the National Plan of Integrated Airport Systems (NPIAS), eligibility for Airport Improvement Program (AIP) grant funding.

Key Regulatory Contacts

The FAA's Airport Safety and Operations Division (AAS-300) within the Office of Airports is the primary federal authority for Part 139 matters. As of 2025, key contacts published by the FAA are:

Sources and Further Reading

• 49 USC § 44706, Airport Operating Certificates
• 14 CFR Part 139, Certification of Airports
• FAA, Part 139 Airport Certification (main page)
• FAA, Part 139 Airport Certification Status List
• FAA, Classes of Airports
• FAA, Airport Safety Management System Final Rule (88 FR 11642, February 23, 2023)
• FAA AC 150/5200-18D, Airport Safety Self-Inspection (September 27, 2022)
• FAA CertAlert 22-02, Airport Emergency Exercise Coordination (June 27, 2022)