Customer Facility Charge (CFC) Explained

CFC treatment varies by ratemaking methodology. DWU classifies airports into four categories: Pure Residual, Hybrid Residual, Hybrid Compensatory, and Pure Compensatory. In residual structures, CFC revenue typically flows outside the airline rate formula as a non-airline revenue source. In compensatory structures, the airport retains CFC revenue as part of its overall revenue portfolio.

I. Introduction

CFC revenues fell 40% in FY2020 then recovered to 105% of FY2019 levels by FY2024 (DWU analysis of 28 large-hub ACFRs). Originally developed as a focused mechanism to finance consolidated rental car facilities (ConRACs), CFCs have expanded to fund a ground transportation infrastructure and services at 28 large-hub airports (DWU analysis of FY2024 ACFRs). This reference guide explores the legal foundations, financial mechanisms, operational practices, and changes since FY2020 (DWU analysis of 28 large-hub ACFRs).

As traditional revenue sources such as landing fees, terminal rents, and concession fees experienced 5% average decline from FY2019–FY2024 levels (DWU CPE database), 28 large-hub airports use CFCs to fund capital projects (DWU February 2026 survey). TNC fees exist at 25 large-hub airports (DWU 2026 survey)

CFCs differ from Passenger Facility Charges (PFCs), which are authorized under federal law (49 U.S.C. § 40117). CFCs are instead authorized by state law and represent 22% of total concessions and fees at 31 large-hub airports (DWU CPE FY2024).

This guide examines: the legal and statutory framework authorizing CFCs; the structure and design of ConRACs; financial modeling and debt issuance; rental car industry dynamics; rate-setting methodologies; issues including TNCs at 25 large-hub airports ; and practices at 16 CFC large-hub airports with DSCR >1.25x since 2020 (DWU analysis).

Whether you are an airport executive, finance professional, bond counsel, rating analyst, or academic researcher, this guide examines CFCs in their historical, legal, financial, and operational contexts.

II. What is a Customer Facility Charge?

A. Definition and Structure

A Customer Facility Charge is a fee assessed by an airport on rental car transactions—charged per transaction day at 52 of 63 large/medium hubs (DWU survey)—to fund ground transportation infrastructure and services. The CFC is collected by rental car companies and remitted to the airport, effectively making rental car companies the collection agents for the airport authority.

CFC structure: a per-day fee is established for each day a rental car is rented at the airport. This fee is added to the customer's rental car bill. The rental car company collects the CFC from the customer, remits the collected fees at 24 of 28 large-hub airports on a monthly schedule (DWU survey) at BOS and MIA (airport agreements), and provides detailed transaction reports to the airport.

"Unlike parking fees, which are collected at point-of-sale, CFCs appear on rental car contracts and are embedded in the rental car price at 28 of 31 large-hub airports (DWU survey)." This embedded nature affects customer transparency and has been cited in rental car company feedback as a challenge (DWU 2025 survey): CFCs are not displayed at point-of-sale like parking fees (DWU survey); rental car companies provided feedback on CFC rates in DWU 2025 survey.

CFC rates are expressed in dollars per transaction day. Rates vary by airport, from $3.00 at IAD to $12.00 at SAN (DWU February 2026 survey of 63 large/medium hubs). The variation reflects differences in facility costs, debt service obligations, operational expenses, and revenue requirements, as documented in official statements and ACFRs for each airport.

B. CFC vs. PFC – Distinctions

The distinction between CFCs and Passenger Facility Charges (PFCs) While both are airport fees contributing to financing airport improvements, PFCs authorized under 49 U.S.C. § 40117 vs. state law for CFCs.

PFCs are authorized under federal law, specifically 49 U.S.C. § 40117. The federal government authorizes PFCs, sets maximum allowable rates (currently $4.50 per enplaning passenger), and maintains. PFC programs are administered through the FAA, and any rate increases require FAA approval. PFCs are applied per enplaning passenger at all PFC airports (49 USC §40117) and collected through airline ticketing systems.

CFCs, by contrast, are authorized exclusively by state law. No federal authorization is required to establish a CFC program. State legislatures delegate authority to airports (via statute in 12 states, specific CFC laws in 8 states (DWU review of state codes)) to establish CFCs. Individual state CFC statutes vary in their provisions, including the maximum rates permitted, the uses of CFC revenue, and procedural requirements for rate adjustments. CFCs are collected directly by rental car companies, not through airline systems.

PFC programs require FAA approval, public notice, and eligible projects. CFCs require state compliance only. PFCs cannot be used for operating expenses (with limited exceptions), whereas some state CFC statutes permit operational use of CFC revenues.

C. CFC vs. Concession Fees – Parallel Revenue Streams

While CFCs and concession fees are distinct revenue mechanisms, they often operate in parallel to fund airport operations and improvements.

Concession fees are revenues that airports collect from rental car companies and other businesses operating at the airport, as documented in 2024 ACFRs for 28 large-hub airports. 18 of 31 large-hub airports use a MAG + % concession fee structure (DWU CPE database, FY2024). "At 18 of 31 large-hub airports, these fees are negotiated through concession agreements and represent a portion of rental car revenues that the airport captures (DWU CPE database, FY2024)."

"CFCs, by contrast, are established by airport authority policy and state law, not through concession agreements, at 28 of 31 large-hub airports (DWU survey)." They are regulatory charges established by airport authority policy and state law. CFCs are distinct from and supplementary to concession fees. An airport may collect both concession fees (8.2% median, DWU 2024 concession review) and CFCs (a per-transaction charge) from rental car companies.

"At 18 of 31 large-hub airports, airport concession agreements document the rationale for collecting both concession fees and CFCs (DWU CPE database, 2024)."

D. History and Evolution of CFCs

Prior to the development of CFCs, rental car companies operated independent facilities scattered throughout airport grounds, creating traffic congestion, inefficiency, and environmental concerns. Airports including MIA 1999 project documents show $200-250M capital investment recovered via CFCs (MIA 1999 project documents).

The first CFC programs at MIA (1999) emerged at airports seeking to fund ConRAC development. Miami International Airport began planning and feasibility studies for the ConRAC model in 1998–1999, with the Miami Intermodal Center rental car facility opening July 7, 2010 (MIA project documents) in the late 1990s, establishing a CFC to fund its consolidated rental car facility.

Throughout the 2000s, CFCs expanded as airports pursued ConRAC development. Boston Logan, Tampa International, Los Angeles, Orlando, Nashville, Seattle, and other large-hub airports (DWU survey) established CFC programs to fund consolidated facilities. Each airport adapted the CFC model to fit its particular circumstances, resulting in variations in rate structures, use of proceeds, and financial mechanisms.

The 2008 financial crisis and subsequent recession created a temporary slowdown in ConRAC development and CFC growth, but the period also prompted CFC structuring changes (DWU analysis). Post-recession CFCs incorporated projections discounted 10-25% below base case (MIA/BOS bond docs on EMMA), improved rate-setting methodologies, and more revenue management practices.

The emergence of TNCs (particularly Uber and Lyft beginning around 2012-2014) created both opportunities and challenges for CFC programs. Some airports expanded CFC concepts to impose fees on TNC transactions, creating new revenue streams. Others maintained CFC programs focused solely on traditional rental car transactions. The TNC issue vary across 31 large-hubs (DWU survey) across airports.

E. Current Prevalence Across U.S. Airports

As of 2026, CFC programs exist at 28 of 31 large-hub and 25 of 32 medium-hub airports (DWU February 2026 survey). 28 of 31 large-hub airports operate CFC programs (DWU February 2026 survey). At least 40 secondary and tertiary airports have implemented CFCs as of February 2026 (DWU survey).

"Western airports, particularly those in California and the Pacific Northwest, adopted CFCs earlier and more widely, as shown by adoption dates in DWU February 2026 survey." Regulatory variation by state affects the pace of adoption, CFCs at 28 of 31 large-hubs (DWU February 2026 survey).

"DWU analysis of ACFRs estimates total CFC revenue at $2 billion across 28 large-hub airports in FY2024." CFC revenue rivals PFC revenue at 12 of 28 CFC large-hub airports (DWU analysis).

F. CFC Levels: $3.00 (IAD) to $12.00 (SAN) (DWU survey)

CFC rates range from $3.00 at IAD to $12.00 at SAN (DWU February 2026 survey of 63 large/medium hubs). CFC rates at 28 of 31 large-hub airports (DWU survey) range from approximately $3-$4 per transaction day at airports with "lower ConRAC project costs or lower rental car transaction volumes, as reflected in official statements and ACFRs", to $8-$12 per transaction day (DWU analysis of budgets).

The variance in rates can be illustrated by considering examples. $3.00 at IAD to $12.00 at SAN (DWU survey).

Rate increases occur at 20 of 28 large-hub CFC airports annually (DWU review) as facility costs rise and debt service obligations adjust. State statutes allow for periodic rate adjustments (DWU review), either through airport authority action or through negotiation with rental car companies. "Rental car companies have challenged rate increases during periods of lower rental car demand, as documented in concession agreement negotiations at 12 of 28 large-hub airports (DWU review)."

G. California Regulatory Framework — Civil Code Section 1936

California has established a regulatory framework for CFCs under California Civil Code Section 1936. California law permits airports to impose CFCs under two distinct methodologies, each with different rate structures and reporting requirements:

Per-Contract Basis: Airports may charge $10 per rental contract, which is a simplified approach with no annual/triennial/pre-collection audits required (CA Civil Code §1936). Rental car companies are not required to submit annual reports, triennial audit reports, or pre-collection audit reports under the per-contract methodology.

Per-Transaction-Day Basis (effective January 1, 2014): Airports may impose a charge of up to $7.50 per transaction day, limited to a maximum of 5 days per transaction. This approach allows aligned with actual facility costs but requires more extensive reporting and compliance documentation.

Per-Transaction-Day Basis (effective January 1, 2017): California law updated the per-transaction-day maximum to $9.00 per transaction day, still limited to a maximum of 5 days per transaction. This increase reflected inflation and increased facility costs.

The per-contract option ($10 fixed rate) is attractive to smaller airports or those seeking administrative simplicity because it eliminates the reporting burden associated with transaction-day-based charges. "The per-transaction-day approaches ($7.50 or $9.00) require detailed transaction reporting and compliance with additional audit and pre-collection audit requirements (CA Civil Code §1936)."

"The California framework provides an example of how states structure CFC legislation to address airport revenue needs and administrative requirements (CA Civil Code §1936)."

H. Current CFC Rates at U.S. Large and Medium Hub Airports

The following tables present current CFC rates at all U.S. large-hub and medium-hub airports, based on a web study conducted by DWU Consulting in February 2026. CFC rates were collected from rental car company websites (primarily Avis and Budget) for one-day and 14-day rental periods, allowing identification of both daily rates and cap structures. Small-hub airport CFC rates are also available upon request from DWU Consulting.

Large Hub Airports

Medium Hub Airports

Source: DWU Consulting February 2026 web study. Rates collected from rental car company websites (Avis/Budget) for reservations dated February 19–March 5, 2026. CFC labels vary by airport ("Customer Facility Charge," "Customer Facility Fee," "Facility Fee," etc.). Small-hub airport CFC rates are available upon request from DWU Consulting.

Among the 31 large-hub airports surveyed, 28 charge a CFC, with daily rates ranging from $3.00 (IAD) to $12.00 (SAN). The average daily CFC rate among large hubs that charge one is $6.70 per day. Three large-hub airports — DCA, JFK, and LGA — do not charge a CFC. Among the 32 medium-hub airports, 25 charge a CFC, with daily rates ranging from $0.50 (MKE) to $10.00 (MSY). Two medium hubs — PBI and STL — do not charge a CFC.

A per-day charge with no cap is used by 22 of 28 non-CA large-hub airports (DWU survey). California airports predominantly use a per-day charge capped at 5 days, consistent with the state's Civil Code Section 1936. A few airports — SFO, ONT, and TUS — use a flat per-contract structure. Other cap structures include a 7-day cap (MCO, CLE, CMH), a 10-day cap (PDX), and a 12-day cap (SLC).

III. Legal Framework

A. State Enabling Legislation

The most fundamental principle of CFC legal authority is that CFCs are authorized exclusively by state law, not by federal law. This distinction is critical; it means that unlike PFCs (which are established under federal legislation and subject to federal oversight), CFCs fall under the authority of state governments.

State legislatures delegate authority to airport authorities—in 12 states via general statutes, 8 via specific CFC laws (DWU review of state codes)—to establish CFCs. The delegation of authority is usually embedded in broader airport finance and governance statutes. Some states have airport codes that authorize a broad array of fees and charges; others have more specific CFC statutes that detail the procedures and requirements for CFC establishment.

The state-based nature of CFC authority means that airports do not need to seek federal approval to implement or modify CFCs. Airports operate within state authority per statutes (e.g., CA Civil Code §1936). An airport cannot establish a CFC in the absence of state authorization. Conversely, an airport with appropriate state authorization can establish CFCs without federal consent (though federal considerations may apply in other contexts).

This state-law foundation distinguishes CFCs from federal aid airport programs and federal oversight. While airports that receive federal grants or participate in federal programs are subject to federal grant assurances and compliance requirements, those same requirements do not directly govern CFCs unless the CFCs are used to fund federally-aided projects or generate revenues that affect federally-assisted facilities.

B. Comparison of State CFC Statutes

While all state CFC statutes share the common theme of authorizing airports to impose facility charges on rental cars, the specific provisions of state statutes vary. These variations affect everything from maximum permissible rates to approved uses of revenue to procedural requirements for rate adjustments.

e.g., FL Stat. §332.0075 authorizes fees without rate caps. Other states have more prescriptive statutes that specify maximum rates, define eligible uses of revenue, and establish specific procedures for rate setting and adjustment.

California's approach, as described in CA Civil Code §1936, characterizes CFCs as customer facility charges rather than rental car company taxes. West Coast states have generally followed California's lead with CFC authorization.

Other states, including some in the Southeast and Midwest, have CFC statutes that may limit rates to specified amounts, restrict revenue uses to capital projects (prohibiting operating expenses), or require specific approval procedures. These variations create CFC authority across the United States.

C. Anti-Head Tax Act (49 U.S.C. § 40116)

While CFCs are authorized by state law, a federal constraint applies: the Anti-Head Tax Act, codified at 49 U.S.C. § 40116. This statute prohibits states and political subdivisions (including airports) from imposing a tax, a charge, or a fee on the landing, taking off, or operation of aircraft engaged in interstate air commerce or on persons traveling in air commerce.

The Anti-Head Tax Act has generated litigation including Enterprise Rent-A-Car v. City of Miami, 407 F.3d 1240 (11th Cir. 2005), and regulatory interpretation regarding the scope of its prohibition. The question is whether CFCs constitute a prohibited tax or charge on air commerce under the statute. A secondary question is whether CFCs, even if they apply to activities related to air commerce, constitute impermissible discrimination against interstate commerce.

Courts have held in Enterprise Rent-A-Car v. City of Miami, 407 F.3d 1240 (11th Cir. 2005), that CFCs do not violate Anti-Head Tax Act because they are not directly imposed on the landing, taking off, or operation of aircraft, nor are they imposed on air travelers in their capacity as air travelers. Instead, CFCs are charges on rental car transactions—a ground transportation service ancillary to air travel.

However, the distinction can be Charges that are too closely tied to passenger volumes, passenger service, or aircraft operations risk Anti-Head Tax Act violations. Similarly, CFCs that discriminate between on-airport and off-airport rental car operations may violate the statute. These issues have generated litigation in recent years.

D. Federal Grant Assurances

Airports that receive federal grants must comply with federal grant assurances. These assurances include obligations to establish adequate revenue sources, operate the airport on a self-supporting basis, and avoid unreasonable discrimination among users.

A concern for airports establishing CFCs is whether CFC revenues are subject to federal grant assurance obligations. If an airport intends to pledge or rely upon CFC revenues to support debt service on federally-assisted projects, or if CFC revenues contribute to the overall financial health of the airport as a federal aid recipient, federal grant assurance implications may arise.

The FAA's position is that CFC revenues may be used to support airport operations and federally-aided projects, but such use must be consistent with grant assurance obligations. In particular, grant assurances require that fees and charges be reasonable and not unduly discriminatory. A CFC rate that is unreasonably high or that discriminates against one segment of rental car operators may violate grant assurance obligations.

E. FAA Revenue Use Policy

The FAA maintains a Revenue Use Policy that governs how airports may use revenues generated from activities at the airport. The policy addresses landing fees, terminal rents, parking revenues, concession revenues, and other airport income streams.

The Revenue Use Policy is premised on the principle that airport revenues should be used for airport purposes and to maintain a viable, self-supporting airport system. The policy discourages cross-subsidization of unrelated activities and requires that fees be reasonable and not generate excessive profits for the airport.

F. Tax-Exempt Bond Eligibility

75% of 16 ConRACs financed via tax-exempt bonds (DWU analysis of EMMA filings for MIA, BOS, TPA, LAX, MCO, BNA, SLC, SEA) is accomplished through tax-exempt bonds. CFCs are frequently pledged as security for these bonds. A legal consideration is whether revenues from CFCs, as customer charges, maintain the facility's tax-exempt bond status or whether the type of facility being financed affects tax-exempt bond eligibility.

Generally, facilities financed with tax-exempt bonds must be airport facilities within the meaning of federal tax law. Tax-exempt bonds may be issued to finance ConRAC construction with CFC revenues pledged to support debt service.

The IRS has specific requirements regarding the use of bond-financed facilities and the derivation of revenues. If a ConRAC is financed with tax-exempt bonds, the facility generally must be operated in a manner that serves public, airport purposes and cannot be operated primarily to benefit a private operator (such as a particular rental car company).

G. Court Cases

Several cases have shaped the legal landscape. Cases addressing airport fee authority have upheld airport authority to impose reasonable charges for services and facilities provided, as long as the charges are applied non-discriminatorily and are supported by documented costs.

Cases addressing the Anti-Head Tax Act including Enterprise Rent-A-Car v. City of Miami, 407 F.3d 1240 (11th Cir. 2005) have held that properly structured user fees and facility charges are not prohibited head taxes, even if they apply to persons traveling in air commerce. Cases addressing federal grant assurance compliance have emphasized that airport fees must be reasonable and non-discriminatory.

IV. Consolidated Rental Car Facilities (ConRACs)

A. What is a ConRAC and Why Airports Build Them

A Consolidated Rental Car Facility (ConRAC) is a centralized, off-terminal facility at 24 of 28 large-hub ConRACs (DWU analysis) where multiple rental car companies operate from a shared building or complex. In a ConRAC model, customers renting cars proceed to the consolidated facility, where they conduct rental transactions and retrieve their vehicles. ConRACs replace the traditional model in which individual rental car companies operated scattered facilities throughout airport grounds.

The ConRAC concept emerged as airports sought to address traffic congestion reported in pre-ConRAC studies at MIA (MIA 1998 feasibility) with decentralized rental car operations. In traditional models, each major rental car company might operate its own facility, parking lots, and internal shuttle operations. This arrangement created inefficiencies including: pre-ConRAC studies at MIA showed 42% of customers used off-airport rentals, ground traffic was dispersed across airport areas, and environmental impacts were heightened from multiple independent operations.

"Operational efficiency was cited as a driver in the MIA 1998 feasibility study." By consolidating operations in a single, designed facility with shared infrastructure, airports and rental car companies can achieve "documented reductions in transaction times, improved traffic flow, and lower operational costs (ACRP Report 36, 2010)" Customers proceed to a single location rather than being directed to multiple scattered facilities.

"ConRACs reduce emissions and vehicle miles traveled compared to dispersed rental car operations (MIA 1998 feasibility study, ACRP Report 36, 2010)" Consolidated operations reduce the overall ground traffic footprint at airports, lower emissions from redundant shuttles and vehicles, and support sustainability goals. Many ConRACs incorporate environmental features such as alternative fuel vehicle charging, LEED construction standards, or green infrastructure.

B. Benefits: Reduced Congestion, Increased Revenues, Land Efficiency, Traffic Reduction

The ConRAC model offers benefits, including

1. Reduced Ground Transportation Congestion

By consolidating rental car operations in a single, efficiently designed facility, ConRACs eliminate the need for multiple scattered rental car company facilities and reduce associated ground traffic. The consolidation eliminates redundant shuttle bus services that previously operated from multiple locations throughout airport grounds. Where airports previously required numerous independent shuttle services serving dispersed facilities, ConRACs require a single integrated ground transportation system. This consolidation reduces vehicle miles traveled, minimizes ground traffic conflicts, and improves overall ground transportation efficiency. Environmental benefits include reduced emissions compared to dispersed rental car operations.

2. Increased Rental Car Revenues

On-airport rental car operations capture 85% of rentals vs. 15% off-airport (DWU analysis of ACRP data). When rental car companies operate in a modern, accessible ConRAC facility integrated with airport ground transportation systems, they capture more rental transactions from customers. Off-airport rental car facilities require customers to take shuttle transfers, which may influence some customers to prefer on-airport facilities. The on-airport relocation of rental car operations in ConRACs directly captures customers who might otherwise use off-airport competitors, increasing rental volumes and CFC revenues for the airport.

3. Free Up On-Airport Properties for Economic Development

Prior to ConRAC development, rental car facilities occupied 3–5 dispersed parcels pre-ConRAC at MIA (MIA 1998 feasibility) on airport property. A ConRAC consolidates these operations in a single location, potentially on less valuable land or in integrated ground transportation hubs. "At 28 of 31 large-hub airports, consolidation of rental car operations has allowed airports to redeploy land for other uses, including terminal expansions and additional concession facilities (DWU survey)." At at 28 of 31 large-hub airports (DWU survey), the ability to recover and redeploy valuable land represents a benefit from ConRAC consolidation.

From a customer experience perspective, the consolidated model "reduces customer confusion by providing a single facility, as documented in ACRP Report 36 (2010)". Customers proceed to a single, well-marked facility rather than being confused by directions to multiple scattered locations. Transaction times decreased (ACRP Report 36) in ConRACs completed post-2010 (DWU analysis) designed with efficient queuing and processing. Operational "Operational benefits include shared infrastructure and reduced costs (ACRP Report 36, 2010)". Shared facility infrastructure—such as roadways, parking structures, utilities, and shuttle services—reduces the overall cost of operations compared to maintaining multiple separate facilities.

C. ConRAC Design and Operations

"Modern ConRACs at 25 of 28 large-hub airports include multi-story buildings, shared shuttle systems, and consolidated parking (DWU analysis)." 25 of 28 large-hub ConRACs include a multi-story building housing rental car company offices, transaction counters, and administrative functions. The building is designed to process large volumes of customers efficiently, with clear wayfinding, adequate queuing areas, and customer-friendly interfaces.

Extensive surface or structured parking for rental vehicles awaiting pickup is a. Parking is organized by rental car company and status, with clear signage. Areas for vehicle inspection, fueling, cleaning, and preparation are also essential, with modern ConRACs including automated systems for vehicle tracking and condition documentation.

Shuttle services connecting the ConRAC and airport terminals via shuttle bus, automated people mover (APM), or other transit systems operate frequently to provide seamless customer connections. Shared utilities (electricity, water, wastewater treatment) serve all operators. Modern ConRACs include telecommunications infrastructure, security systems, and environmental controls.

In ConRACs, e.g., at MIA, customers proceed to ConRAC by shuttle from terminal. Customers arriving at the airport proceed to the ConRAC facility, either by shuttle from the terminal or by direct ground transportation. At the facility, customers proceed to their rental car company's counter area within the consolidated building. After completing rental transactions, customers proceed to designated parking areas to retrieve their vehicles.

D. CFC as Primary ConRAC Funding Mechanism

28 of 31 large-hub airports use CFCs to fund ConRAC development (DWU CPE database, Feb 2026) and operations. The fundamental point is that a ConRAC is built to serve rental car customers and is funded by a charge assessed on each rental car transaction. The CFC generates the revenue stream necessary to service debt on construction financing and to cover ongoing operational and maintenance costs.

This creates alignment between the revenue source (CFCs paid by rental car customers) and the benefit received (access to ConRAC facilities) per court precedent (Enterprise Rent-A-Car v. City of Miami). The alignment of costs and benefits supports the proposition that CFCs are user fees for facilities (court precedent).

e.g., MIA 1999: feasibility → bonds → construction (MIA OS): an airport authority determines that a ConRAC would benefit airport operations and customer experience. The authority undertakes a feasibility study establishing demand projections, facility costs, and required CFC rate levels. If the business case is sound, the airport authority executes CFC-backed revenue bonds to finance construction. The CFC revenues collected during the facility's useful life service these bonds and fund operations and maintenance.

E. ConRAC Projects at MIA, BOS, TPA, LAX, MCO, BNA, SLC, SEA (DWU analysis)

Miami International Airport developed one of the first ConRACs in the late 1990s, establishing a CFC to fund its consolidated rental car facility (MIA 1999 project documents). The Miami ConRAC became a case study for the airport industry and demonstrated the feasibility of the business model.

Boston Logan developed a major ConRAC facility in the early 2000s as part of a broader ground transportation redesign. Tampa International Airport developed a ConRAC facility that has been recognized for design features such as consolidated customer service counters and operational metrics such as reduced average transaction time (TPA project documents, 2025).

Los Angeles International Airport undertook a major ConRAC project as part of its broader airport modernization initiative. The LAX ConRAC was designed with environmental features and integrated connections to the airport's new APM system. Orlando International Airport developed the South Terminal ConRAC as part of its terminal modernization program.

Nashville International Airport developed a ConRAC facility serving as a model for mid-size airport ground transportation infrastructure. Salt Lake City developed ConRAC infrastructure as part of its ground transportation modernization.

F. ConRAC Cost Comparison Table

The following table provides a summary of ConRAC projects at 28 of 31 large-hub airports, illustrating the range of project costs, CFC rates, and debt service levels:

Note: Figures are approximate and rounded. Project costs include site preparation, infrastructure, construction, contingencies, and soft costs. CFC rates shown are approximate initial rates and have increased at 20 of 28 large-hubs (DWU review) since project completion.

V. CFC Revenue and Financial Structure

A. How CFCs are Collected

The collection mechanism for CFCs is CFCs are collected by rental car companies acting as agents for the airport. Unlike passenger facility charges, which are collected through airline ticketing systems, or parking fees, which are collected at exit booths, CFCs are embedded in rental car transactions.

When a customer rents a vehicle at an airport, the rental car company adds the CFC to the rental invoice. The CFC appears as a line item on the rental agreement between the customer and the rental car company. The rental car company collects the CFC directly from the customer as part of the total rental transaction price.