Airport Rules - Mobil Mechanics/Training

Appreciate the input. I can understand not being allowed to run a maintenance shop out of a hangar, but working on our own planes seems reasonable. Do you allow it at your airport?

To a very limited nature. Think Part 43 Preventative Maintenance performed by pilot. Although the wording of our rules in regulations just say maintenance, a little common sense has to prevail. But a mobile mechanic would definitely catch our attention.

I think that's where we're at. Requiring insurance is acceptable. Asking for $5K isn't. We plan to discuss it at the next advisory meeting, but the next step would be to call the FAA and see where it goes from there.

Without knowing more, the $5k may be the issue. As I said, if the airport has a formally adopted Commercial Minimum Standards, they may require ANY person or business offering maintenance to meet certain contractual, lease, and insurance requirements, to ensure all business are operating on the same playing field. Is the primary tenant paying $5k to the airport for their operation, then they may have a basis for it.

The FAA Grant Assurances don't say airports have to let anyone use their airport for free. As a matter of fact airports are held by Grant Assurance 24.

"It will maintain a fee and rental structure for the facilities and services at the airport which will make the airport as self-sustaining as possible under the circumstances existing at the particular airport, taking into account such factors as the volume of traffic and economy of collection."

Assurance 22. paragraph A. "It will make the airport available as an airport for public use on reasonable terms and without unjust discrimination to all types, kinds and classes of aeronautical activities, including commercial aeronautical activities offering services to the public at the airport."

So airports can impose fees, but they need to be reasonable and not discriminatory. What one person or business gets charged, so does another. $5k may be reasonable, may not be, depends on the situation.
 
he will not conduct any commercial activity
In my experience, it's the definition of commercial activity that defines this rule. Where this was an issue for me, my service agreement with a private aircraft owner was not defined as a commercial operation thus I could perform the work.

Here is one of the references I mentioned above on the self-service of the grant assurances if it is applicable in your case. I highlighted the main parts. As mentioned, while an airport isn't required to provide a place to perform your mx nor allow 3rd party providers, the airport can't use that route to force to use the on-site mx shop.
https://www.faa.gov/documentLibrary/media/advisory_circular/150-5190-6/150_5190_6.pdf
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but the next step would be to call the FAA and see where it goes from there.
FYI: there are FAA Airport District Offices that handle issues/complaints with airports. They might be a better reference to ask than your FSDO.
https://www.faa.gov/airports/airport_compliance/
https://www.faa.gov/airports/airport_compliance/complaints/
 
Just to lay it out there, I do manage an airport and this is something we work with regularly, both with tenants, the fire marshal, and the FAA.

Yes Grant Assurance 22. Paragraph f. states "It will not exercise or grant any right or privilege which operates to prevent any person, firm, or corporation operating aircraft on the airport from performing any services on its own aircraft with its own employees [including, but not limited to maintenance, repair, and fueling] that it may choose to perform."

However Grant Assurance 22. Paragraph h. also states "The sponsor may establish such reasonable, and not unjustly discriminatory, conditions to be met by all users of the airport as may be necessary for the safe and efficient operation of the airport."

In this case, adoption of fire code standards to protect the hangars is the norm, and is supported by the FAA. If we are talking about T-hangars, they don't usually meet code for aircraft maintenance facilities.

But what do I know? :rolleyes:

If truly challenged (by competent lawyers, etc.), I don't think you can get away with saying "we can ban you from turning a single wrench in your hangar because of fire codes..." There's nothing inherently dangerous, fire code or otherwise, with someone using basic hand tools (wrenches, ratchets, screw drivers, etc.) to work on an aircraft. You may be presently be getting away with such a unique view of the grant assurance, but that doesn't mean you're right. Now as soon as you start talking about working with flammable liquids or gases, like painting, stripping, welding, etc. (above and beyond adding oil to the aircraft), I agree the airport has a right to regulate that. But the airport can't simply ban all maintenance in a t-hangar and blame the fire code or "safety." Again, you may be getting away with it, but...
 
The damaged parties are the airport and the FBO. Imposing restriction on shade tree mechanics from performing contract services on an airport is a common practice. Requiring proof of a $5 million liability policy naming the airport as an insured is all it takes.
 
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FYI: the grant assurance "self-service" protections only apply to the aircraft owner and their employees. It's stated in several guidance docs. Unfortunately, it does not apply to any outside 3rd party mx providers. But where it does draw the line is if the airport prohibits the owner's self-service rights in order to direct all mx services to a domiciled commercial mx provider. Which in the OPs case it sounds like the intent and if the airport does fall under these FAA rules then they may want to rethink their position. In my experience, it can make for some interesting discussions at an airport commission meeting if this is in fact the intent of the OPs airport new rules.

Define "employee" or "owner." As someone above noted, all it (arguably) takes is granting the A&P a nominal ownership interest in the aircraft. Would that truly survive a challenge? Maybe not, but it shows the silliness of some of the rules.
 
Grant assurances don't allow the airport to prohibit certain activities, but it does not prevent them from regulating those activities to ensure the safe and efficient operation of the airport for all operators. As a matter of fact, the airports are encouraged by the FAA to have such regulations, and to ensure fair and equal treatment of all users.

I've been involved in discussions about this regarding ultralights. The FAA considers ultralights a legitimate "aeronautical activity", so airports receiving federal funding must allow them, but may impose "reasonable restrictions" in the interest of safety. At, say, JFK, a complete prohibition of ultralights is doubtless "reasonable", but at smaller fields, not so much, and a number of UL pilots have prevailed and with the FAA's assistance, gotten permission to fly over the objections of the airport management. Similarly, a prohibition against owner maintenance would have to be justified in the name of safety.

If we are talking about T-hangars, they don't usually meet code for aircraft maintenance facilities.

For commercial aircraft maintenance, probably not. But otherwise, how is it different from a homeowner (or renter) working on his own car in his own garage?
 
Define "employee" or "owner."
Owner as defined by FAA. Employee I believe was as per Labor dept but dont hold me to that.
As someone above noted, all it (arguably) takes is granting the A&P a nominal ownership interest in the aircraft. Would that truly survive a challenge?
I dont think "ownership" will fly if not on the registration record. Employee sure. Did that twice for a month or so.
Maybe not, but it shows the silliness of some of the rules.
Having seen both sides of this on grant airports and non-grant ones I dont necessarily think the rules are silly. They're there for a reason in most cases. For example, had 2 clients lose aircraft to hangar fires due to some mx ops. Where I take exception is when the rules are used for gain by others. The grant rules actually give you more stroke than non-grant situations in my experience. In the OPs situation it appears to be the case with the shop beeching about losing business. I dont believe its Jacks fault that mechanic cant run his business. But I do have a suspicion that shop owner knows someone to get it this far. Been there also.:rolleyes:
 
But otherwise, how is it different from a homeowner (or renter) working on his own car in his own garage?
Most airports are public property.
 
<snip>
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Part 2 - Our new airport manager says she's a rule follower and mentioned this rule:
Lessee agrees he will not conduct any commercial activity such as pilot instruction, aerial spraying, charter flights, air taxi, sightseeing flights, aerial photography, aircraft engine or airframe repair, and avionics repair within the Hangar or on the Airport.
<snip>

Yes it will likely get messy,
if she is a rule follower she should learn how to read the rule. If the Mobile mechanic were the Lessee it would apply. By her argument the 5K charge will apply to the exterminator or housekeeper, detailer, you might hire to come perform work in your hanger. If I am going to be charged 5K for lease/electric/water, then I will want to insist that those services are provided. The intent of the rule is to prevent you from running a business out of your hanger, likely for insurance reasons, see below.

The more common complaint is that the airports require business to carry liabilty insurance and name the City on the policy (I am not an insurance guy, so may not have the details correct).
So the business owner complains that he is forced to by an insurance policy that the mobile mechanic is not required to.

What usually happens is either the Mobile mechanic makes some sort of arrangement with the City, or probably more common, just works with the hanger door closed and doesn't advertise that he is doing so.

Brian
Another question to bring up is for your commission to define "commercial operations" if that is the term they are using and how they classify the shop who is complaining. One method how we worked around this was that I was a private contractor to a specific owner. Since I always used a mx services agreement with customers this was sufficient to prove a "private contract." One commission tried to include the use of "private contractors" in their rules but couldn't use that verbiage since they were a public body. Are any of your airport rules in the public domain somewhere?

Good point on the definition of a "commercial operation." How is hiring a mechanic any different than hiring a teenager or detailer to sweep out the hanger or vacuum and clean your airplane once a week?

Brian
 
Most airports are public property.

Not counting private use airports, about 80% are publicly owned. If you include private airports, 80% are privately owned.

But what do I know... about 90% of the airports I land at are privately owned.

I suspect the majority of owners who want to do their own maintenance or hire a mobile freelancer are much more likely to be found at privately owned (i.e. smaller) airports.
 
A friend of mine had a plane torched due to rampant stupidity by a T-hangar neighbor. It makes sense to restrict someone from doing any painting or fuel system maintenance in a hangar, but restricting someone from replacing a tire or replacing a radio makes zero sense from a fire safety perspective. That's just airport managers colluding with their favorite maintenance shop.
 
A friend of mine had a plane torched due to rampant stupidity by a T-hangar neighbor. It makes sense to restrict someone from doing any painting or fuel system maintenance in a hangar, but restricting someone from replacing a tire or replacing a radio makes zero sense from a fire safety perspective. That's just airport managers colluding with their favorite maintenance shop.
Why not just prohibit people from setting their hangars on fire.
 
I suspect the majority of owners who want to do their own maintenance or hire a mobile freelancer are much more likely to be found at privately owned (i.e. smaller) airports.
I guess it depends on how you define public use vs private use. But the majority of the airports I performed maintenance on as a freelance mechanic were supported by public dollars, i.e., tax dollars, grants, etc. The private ones were usually a small collection of hangars and a single runway. Some had a mx shop and some didn't. The money for me was at the public airports. And it was rare when I ventured onto someones private airstrip in their backyard. So I think it's your perspective on the matter.
 
I guess it depends on how you define public use vs private use. But the majority of the airports I performed maintenance on as a freelance mechanic were supported by public dollars, i.e., tax dollars, grants, etc. The private ones were usually a small collection of hangars and a single runway. Some had a mx shop and some didn't. The money for me was at the public airports. And it was rare when I ventured onto someones private airstrip in their backyard. So I think it's your perspective on the matter.
The FAA database has columns for private or public use, and private or public ownership, that's where my numbers came from.
 
The FAA database has columns for private or public use, and private or public ownership, that's where my numbers came from.
As I mentioned it depends on how you define it. There are a number of privatly owned airports on those lists that allow full public use and in some cases receive FAA grant and other public moneys. So even though the airport is listed private it may still have to follow certain rules as true pblically owned airports.
 
A friend of mine had a plane torched due to rampant stupidity by a T-hangar neighbor. It makes sense to restrict someone from doing any painting or fuel system maintenance in a hangar, but restricting someone from replacing a tire or replacing a radio makes zero sense from a fire safety perspective. That's just airport managers colluding with their favorite maintenance shop.
That's silly. One could shut off the fuel valve and easily work on the carburetor safely, while a mis-wired radio might be an electrical fire hazard, but all of that is potentially possible for the "allowed" mechanic to mess up, also.
 
He can pay $5K per year. They say they're basing this on the cost of a ground lease / water / electricity and other expenses the shop owner would have.
That doesn't seem fair unless they are going to actually give that mechanic space to do the maintenance (is the on-field mechanic required to let transient mechanics set up in his space?), and not simply use your space which you have already paid for for the purpose of storing your aircraft.
 
That doesn't seem fair unless they are going to actually give that mechanic space to do the maintenance (is the on-field mechanic required to let transient mechanics set up in his space?), and not simply use your space which you have already paid for for the purpose of storing your aircraft.

I think it seems obvious that the airport isn't looking to be fair, it is trying to steer business to the on-field maintenance facility.
 
We don’t pay so much in taxes so some little buddy buddy nonsense can’t try to save a failure business.

If the mechanic hates free market, move to a non public field and pay off the owners, or better yet build his own airport and he can make his own rules.

What a horrible business owner, his shop is failing and instead of asking why folks don’t want to use his big facility on the same airport, he decides to attack others and try to use cronies to force people to give him their business and force others out of business.

Have you thought about sharing his anti free market pro cronie positions and shop name on aviation groups?
 
Many airports struggle for any level of financial solvency. A smaller (repeat smaller) airport may only have one or two business' located on field and those business' may be the primary source of airport income for the city. This would include rent, taxes on business and employees, fuel sales from transient aircraft flying in for maintenance, etc..

Part of an airport manager's job is, in many cases, to seek to keep the airport as financially sound as possible. The loss of one or two business' on the field could have a significant effect on the airport's viability. Just about every airport has a group that wants to shut it down (Damn airplane noise! or Look how much money we can make by turning it into a housing development!). When an airport becomes a significant financial burden on the city, the howls for shutting it down get louder and more people climb on board with the idea.

Many aircraft repair shops also struggle with financial viability. Having shade tree mechanics on the field can hurt the mx shop's financial viability. You can't blame a business that pays city rent, city taxes, and help support the viability of the airport, for wanting to protect its own interests AND for wanting to protect the viability of the airport by staying in business.

At smaller airports the mx shop and the airport are in a symbiotic relationship, far more so that almost any other business elsewhere in the city. Failure of one, may mean failure of the other.

I saw this exact scenario at Petaluma Airport many years ago where I had a parts business on the field and there was one other business, a mx shop. At the time I really hated the mx shop and the city's effort to keep out shade tree mechanics. It was a source of "displeasure" for most pilots on the field. A million years later, I can now see the validity of both sides of the argument.

Should pilots be able to have an outside mechanic service their plane? Of course! But what if the loss of business to the on-airport facility ultimately leads to closing of the airport?

This was a real possibility to the tiny Petaluma Airport in the 1980's. Now it's a thriving airport with a number of business' and more than a hundred aircraft of all kinds, including jets. And the MX shop is still on the field.

Things could have turned out very differently for Petaluma Airport without the protection the mx shop got at the time. The location would now make a ton of money for the city in residential taxes.

In the end, I have no idea what the right answer is, and I am glad I'm not in the position to have to choose.
 
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As I mentioned it depends on how you define it. There are a number of privatly owned airports on those lists that allow full public use and in some cases receive FAA grant and other public moneys. So even though the airport is listed private it may still have to follow certain rules as true pblically owned airports.

That's true. I wonder how many privately owned airports are in that situation?
 
One of the things that was always curious about in situation like this is if the airport can be shown to supporting a monopoly to protect a maintenance business on the airport. And the maintenance guy screws up and something bad happens can the airport or city be held partially liable for making this monopoly?
 
That manager needs a change of mind. You're hiring someone to WORK on your plane, not offering services out of your hangar... I'd get a lawyer involved 100%.

Also, no over head is BS. It may not be the SAME overhead, but the mobile mechanic still has overhead costs.
So WRT part one, as long as the mobile mechanic pays the 5 grand, they are ok with him working in the plane? Sounds kind of punitive to me!
 
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@Lndwarrior:

If a based- A&P/IA shop is having financial solvency issues, the airport manager should be asking why. Not all businesses are worth protecting. Not saying this is the situation in the OP's case, but if the shop is just poorly run, doesn't do quality work, tries to charge well above-market rates, or otherwise has managed to fall out of the good graces of enough pilots, it needs to close. One of our on-field A&P/IAs also services motorcycles and small boats when he has extra time. But he is a good mechanic, who communicates well with customers, so he has a pretty reliable flow of GA repair/maintenance work and loyal customers.
 
That's true. I wonder how many privately owned airports are in that situation?

I am based at such an airport. Privately owned but grant eligible. As I understand it, they can assert a monopoly. The old owner was quite captive of his hangar tenants, it was expected that you did your annual locally. His airport, his rules.
 
Having shade tree mechanics on the field can hurt the mx shop's financial viability.
I don't know your definition of a shade tree mechanic as to me shade tree guys show up and sign off $200/20 minute annuals. But freelance mechanics have been around for decades. But as for freelance mechanics being a primary reason the on-site mechanic shop fails had not been my experience. Many reasons cause mx shops to fail but if a shop is losing local business it usually revolves around personality, lack of specific services, or the mechanic is just not business savvy. When a freelance mechanic shows up it usually a result of those failure reasons. For example, my rates were usually higher than the local guy due to my travel expenses and I would offer a service, like owner-assisted mx, that the local guy didn't want to do. I have even been called by local mechanics to help with some work loads. Now if you have an airport full of $200 annual owners then sure it can put a good mx shop out of business but I've never seen that either. Regardless, a solid local shop will not fail even when a few freelance mechanics show up.
At smaller airports the mx shop and the airport are in a symbiotic relationship, far more so that almost any other business elsewhere in the city. Failure of one, may mean failure of the other.
While you mention you have experience with this, I would venture that was the exception more than the norm. In my experience don't know of any mx shop that has kept an airport afloat. Now airports that don't support mx shops, plenty. I know one airport right now that has dragged its feet to construct new T-hangars after a hurricane hit from several years ago. The resident mx shop has had to go mobile because there are limited customers. Prior to storm they did 28 annuals per year from locally based aircraft which took care of the bills. But if the hangars are not built by end of next years, he said he plans to relocate. How did the airport respond? They upped his hangar rent instead of start on building the hangars.:rolleyes:
 
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I wonder how many privately owned airports are in that situation?
More than I thought. Plus there seems to be a number of different methods how or what funding a private airport has access to. No two airports ever seem to be operated the same.
 
@Lowflynjack - it occurs to me that there may be a secondary agenda here to make it difficult for some of the "riff-raff" owners who are on the "cheapskate side" and try to discourage them and get them to leave so that some of the bigger badder planes on the waiting list can come in. Of course they'd be ignorant and probably willing to pay the local shop's prices, too...
 
Time to run the shop out of business just for being a crybaby.
 
Time to run the shop out of business just for being a crybaby.

Good idea, then the city can justify closing the airport because it has no services and doesn’t produce enough revenue.
 
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I have a friend who pays a different lease for his hangar to do maintenance out of it. Not sure what the difference in price is between commercial and private ownership.

I also know several A&P/IA's on the field that freelance. I think Juneau is the exception. Only one maintenance shop on the field. They always have a back log of work and do their best to help folks out. The freelance A&P's often take on or help out the maintenance shop with workload.

A friend bought out a maintenance shop on the field with the intention of providing GA maintenance service. His family obligations prevented him from providing a timely service to his customers. The business failed. Good customer support, support in a timely fashion, fair labor rates and good customer relations is what it takes for someone to make a business successful in my eyes.

None of the freelance A&P/IA's that I know pay anything to the airport. They do everything from annual inspections, oil changes, troubleshooting/repairs.
 
Last night was the Airport Board meeting. We had 30 pilots show up!

The last proposal we had seen was $3700/year and the same insurance requirements we have as hangar tenants. When they started the meeting, they told us they had heard a lot of complaints and had adjusted their proposal to $500/year, or a one-time emergency fee of $75, and insurance. Everyone of us who spoke up told them this is not acceptable, it needs to be $0.

I brought up the point that the insurance requirements were just copied from the hangar lease, even leaving in the provision to cover passengers, which mechanics usually don't have. I also reminded them that anyone based at the airport, that wants the mobile mechanic's services already has the required insurance to protect the City.

At the end of the meeting, the 5 board members would not all agree to removing the fee, so they voted to table the discussion. Since they're only an advisory board, there was a City staff member there and he said he had to present a proposal to "staff" last night. He said he would tell them there was a recommendation to remove the fee, and also one to make it $500. The next step is to put it in front of the City Council and have them vote on it in February. We will be there to voice our concerns again.
 
Good idea, then the city can justify closing the airport because it has no services and doesn’t produce enough revenue.
The City won't be closing the airport. Samsung just agreed to open a chip manufacturing site in Taylor. If anything, the airport is about to explode!
 
Similar thing is happening at a local airport here. It's always crappy mechanics that have to resort to tactics like this. My mechanic's personal hangar is on the airport where I'm based and I like to go to him because he's FAR better than the guy on field. On-field mechanic got grumpy when people on the field were going to my mechanics personal hangar rather than his... Went to the city and said you needed a bathroom to operate a business out of the airport. It does not have the desired effect, just ****es everyone off and we just find other ways to not use the on-field mechanic.
 
Similar thing is happening at a local airport here. It's always crappy mechanics that have to resort to tactics like this. My mechanic's personal hangar is on the airport where I'm based and I like to go to him because he's FAR better than the guy on field. On-field mechanic got grumpy when people on the field were going to my mechanics personal hangar rather than his... Went to the city and said you needed a bathroom to operate a business out of the airport. It does not have the desired effect, just ****es everyone off and we just find other ways to not use the on-field mechanic.
Yep. We've already had one shop offer a discount to anyone based on the field and if we fly our planes to him, he'll give us a ride back.

On the business out of a t-hangar, that is prohibited at most airports, but what if the mechanic comes to your hangar? I can't run a commercial operation out of my hangar, but having someone work on my plane there should be fine.
 
In all of this noise, has anyone on the airport board inquired after the reason pilots get their maintenance done elsewhere? Perhaps an anonymous poll would shed some light on the situation in a way even a functionary can comprehend. Someone should offer to setup the surveymonkey and keep the results viewable for maximum funnylaffs. :D
 
Since they're only an advisory board, there was a City staff member there and he said he had to present a proposal to "staff" last night.
Where you able to determine who the mechanic knows on the advisory board or the City Council? Something still seems missing for that mechanic's business issue to make it this far especially with the numbers of people you brought. Maybe it's just at your airport but it sure appears that guy knows someone from my experience in "fighting" these situations. FWIW: The insurance requirement, sure, but any airport access fees for a private contract between owner and mechanic, no.
We've already had one shop offer a discount to anyone based on the field and if we fly our planes to him, he'll give us a ride back.
Make this your opening statement before the CC meeting. If they will allow money to leave their jurisdiction then it may shed light on the real issue behind the scenes. Good luck.
 
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Where you able to determine who the mechanic knows on the advisory board or the City Council? Something still seems missing for that mechanic's business issue to make it this far especially with the numbers of people you brought. Maybe it's just at your airport but it sure appears that guy knows someone from my experience in "fighting" these situations.
The shop owner is on the advisory board! Since they didn't vote on the proposed fee yet, it's not considered a conflict of interest, but it will be.

Essentially, the Public Works Director told us they want to be fair and equitable and they're struggling to figure out what that is. I have the meeting notes from the 10/11 meeting. "The Board was given estimated rates for the SFBO (Specialty Fixed Base Operator) provision based on a 5,000sf hangar, base water rate, base sewer, base trash, electric and admin fee. Which comes to approximately $3700 per year and proof of Insurance"
 
The shop owner is on the advisory board!
:rolleyes:. This was the #1 issue I faced directly or indirectly when I ran into these issues as a freelance mechanic.
it's not considered a conflict of interest
Why not contact the TX Ethics Commission? It probably doesn't specifically apply to your advisory board but I believe they may have some oversight of the city council. I know of them from a different issue but they seemed to be keen on this sort of obvious conflicts.
The Board was given estimated rates for the SFBO (Specialty Fixed Base Operator) provision based on a 5,000sf hangar, base water rate, base sewer, base trash, electric and admin fee. Which comes to approximately $3700 per year and proof of Insurance"
Ask the city council how many other city/airport contractors are required to follow these same terms when bidding on city/airport work? Then ask them how does a private contract between an owner and their mechanic fit into this clause. Another route that has worked is to get a small group of resident pilots, formalize your requests/comments and seek a one-on-one meeting with the person you oversees the city council. I never initiated this but the owners who wanted me to work did and brought a different take to the matter outside of the public meeting scenario. In one case, it was solved in the mayor's office with no further voting required.
 
The shop owner is on the advisory board! Since they didn't vote on the proposed fee yet, it's not considered a conflict of interest, but it will be.

Essentially, the Public Works Director told us they want to be fair and equitable and they're struggling to figure out what that is. I have the meeting notes from the 10/11 meeting. "The Board was given estimated rates for the SFBO (Specialty Fixed Base Operator) provision based on a 5,000sf hangar, base water rate, base sewer, base trash, electric and admin fee. Which comes to approximately $3700 per year and proof of Insurance"

Did they consider kicking out the based mechanic, thus making him "get mobile" and creating this mysterious fair and equitable playing field for him?

Or perhaps subsidizing his rent to make it equal to the mobile mechanics if that's a desirable outcome?

Did they consider that "leveling the playing field" is not a concern of airport operations for differing types of operations at all?

Did they consider that the fixed-based mechanic may not be the standard to "level against" in the first place? Particularly because he sounds like a substandard shop. Perhaps they should double his existing rent, thus forcing him to get better, or move out of the way for a superior operator who can then capture the on-field opportunities?



Dealing with idiots like these was the worst part of owning an FBO, and I would never wish It upon anyone.
 
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