Why Non-Part 139 Airports Need Self-Inspection Programs
FAA Advisory Circular 150/5200-18D provides comprehensive guidance on airport safety self-inspection programs. While mandatory self-inspection requirements apply only to Part 139 certificated airports, the FAA explicitly recommends that all airport operators — including non-certificated facilities — adopt a self-inspection program proportionate to their operations.
The reasons are practical, not just regulatory. A self-inspection program does four things for you: it identifies hazards before they cause incidents, creates a documented record of your diligence, supports insurance claims and liability defenses if something does go wrong, and demonstrates responsible stewardship to your community, your governing body, and your funding agencies.
The absence of a federal certification requirement does not mean the absence of liability. If an accident occurs at your airport and you cannot demonstrate that you were regularly inspecting and maintaining the field, you face significant legal exposure. Your inspection records are your first line of defense.
Types of Inspections
A complete self-inspection program includes four types of inspections, each serving a different purpose and operating on a different schedule.
| Inspection Type | Frequency | Purpose |
|---|---|---|
| Daily Inspection | Each day the airport is active | Walk or drive the airfield to check runway and taxiway surfaces, lighting, signage, windsock condition, and the presence of wildlife, foreign object debris (FOD), or obstructions. |
| Periodic Condition Inspection | Weekly, monthly, or quarterly depending on activity level | More detailed assessment of pavement condition, drainage, markings, NAVAID areas, fencing integrity, and fuel system condition. Use measurement tools and document specific findings. |
| Continuous Surveillance | Ongoing | General observation by anyone present on the airfield — staff, tenants, or pilots. The goal is to catch abnormalities, unauthorized activity, or emerging hazards between formal inspections. |
| Special Inspection | As triggered by events | Performed after severe weather, construction activity, unusual events, or pilot reports. Focused on areas or systems that may have been affected by the triggering event. |
For most small GA airports, a daily walkaround combined with a more thorough monthly condition inspection provides a reasonable baseline. Airports with higher activity levels, instrument approaches, or complex infrastructure should consider more frequent periodic inspections.
What to Inspect
Your inspection checklist should cover every element of the airfield that affects the safety of operations. At a minimum, this includes:
Pavement Surfaces
Check runways, taxiways, and aprons for cracks, potholes, edge deterioration, standing water, and foreign object debris. Pavement failures that start small can grow rapidly under traffic and weather stress. Document the location and severity of any deficiencies you find so you can track their progression over time.
Lighting Systems
Verify that runway edge lights, threshold lights, taxiway lights, the rotating beacon, and any approach lighting systems are operational. Test pilot-controlled lighting (PCL) systems regularly — a pilot arriving at night who cannot activate the lights via radio has no way to know the system is malfunctioning until it matters most.
Signage and Markings
Runway markings, hold position markings, and airfield signs should be visible and compliant with FAA Advisory Circular 150/5340-1 standards. Faded markings and damaged signs are among the most common deficiencies found during state inspections, and they are relatively inexpensive to correct.
Wind Indicator and Segmented Circle
The windsock should be visible from pattern altitude, properly illuminated for night operations (if applicable), and in good physical condition. At non-towered airports, the windsock and segmented circle are primary tools pilots use to determine runway orientation and traffic pattern direction.
Fencing and Perimeter Security
Inspect perimeter fencing for breaks, gaps, and unauthorized access points. At GA airports, fence damage often comes from falling trees, vehicle impacts, and animal activity. Perimeter breaches create both security and wildlife management concerns.
Drainage
Check drainage structures, ditches, and culverts for blockages, erosion, and standing water. Poor drainage leads to pavement deterioration and can create wildlife attractants near the airfield.
Fuel Storage and Dispensing
Inspect fuel tanks, dispensing equipment, bonding and grounding connections, and spill containment systems. Fuel safety is covered in more detail later in this chapter.
NAVAID Critical Areas
If your airport has navigational aids such as VASI, PAPI, or REILs, inspect the equipment and ensure that critical areas are clear of obstructions, vegetation growth, and unauthorized objects that could affect signal quality.
Documentation
Every inspection should produce a record. This does not need to be elaborate — what matters is consistency and completeness. At a minimum, each inspection record should capture the date and time of the inspection, the name of the person who performed it, weather and field conditions observed, any deficiencies identified, and the corrective action taken or planned.
Keep your inspection records in a single, organized system. Whether that system is a paper logbook, a spreadsheet, or a digital platform is less important than the discipline of using it every time. Records should be retained for at least three years, and longer if your state or insurance carrier requires it.
Hangarly's operations module provides a structured inspection log and maintenance tracking system designed for airport operators. Log findings, attach photos, assign corrective actions, and maintain a searchable history — all in one place. This creates the documentation trail that protects you in liability situations and demonstrates compliance during FAA or state reviews.
NOTAMs: When and How to Issue Them
When you identify a condition that affects the usability or safety of your airport, you have a responsibility to issue a Notice to Air Missions (NOTAM) so that pilots are aware before they arrive. NOTAMs are issued through the FAA's NOTAM system, and the process for submitting them depends on your region — contact your Flight Service Station or FAA Regional Airports office to establish the procedure for your field.
Common situations that require a NOTAM include:
- Runway closure or reduced length available
- Taxiway or apron closures
- Inoperative airfield lighting, including the rotating beacon
- Inoperative or unreliable pilot-controlled lighting
- Pavement damage that affects usability
- Construction activity on or near the movement area
- Significant wildlife activity, particularly large animals on or near the runway
- Temporary obstructions such as construction equipment or vehicles near the runway
Issue NOTAMs promptly. A hazard that exists without a NOTAM is a hazard you have failed to communicate — and that failure increases your liability significantly if an incident occurs.
Some airport managers hesitate to issue NOTAMs because they worry it will discourage traffic or make the airport look poorly maintained. This is exactly backwards. A NOTAM shows that you are aware of the condition and have taken responsible action to communicate it. Failing to NOTAM a known hazard is far more damaging — both legally and reputationally — than the NOTAM itself.
Wildlife Management
Wildlife strikes are a safety concern at airports of every size. While large commercial airports typically have dedicated wildlife management programs, small GA airports face many of the same hazards — deer on runways, bird flocks near approach paths, and standing water that attracts waterfowl.
FAA Advisory Circular 150/5200-33C provides guidance on wildlife hazard management at airports. Key practices for small airports include:
- Eliminate attractants. Standing water, tall grass, open waste containers, and berry-producing vegetation near the airfield all draw wildlife. Managing the habitat around your runways and taxiways is more effective and less expensive than trying to scare animals away after they arrive.
- Document strikes and sightings. Report all wildlife strikes to the FAA Wildlife Strike Database (available online). Track sightings during your daily inspections. This data helps you identify patterns and may trigger a Wildlife Hazard Assessment if activity reaches certain thresholds.
- Coordinate with USDA Wildlife Services. The USDA's Wildlife Services program provides technical assistance and direct management support to airports of all sizes, often at no cost. They can help you develop a wildlife management plan tailored to your specific conditions.
- Manage vegetation. Keep grass at a height that discourages roosting and foraging by the bird species common in your area. The optimal height varies by region — your state aeronautics agency or USDA Wildlife Services office can advise on local best practices.
Fuel Safety
Even at the smallest airport with a single self-service fuel pump, fuel operations require careful attention to safety, regulatory compliance, and environmental protection. FAA Advisory Circular 150/5230-4 provides guidance on aircraft fuel storage, handling, and dispensing.
Key Fuel Safety Practices
- Regular equipment inspection. Inspect fuel storage tanks, dispensing pumps, hoses, nozzles, and filters on a documented schedule. Look for leaks, corrosion, physical damage, and wear on seals and connections.
- Bonding and grounding. Verify that bonding and grounding systems are intact and functional. Static discharge during fueling is a fire hazard that proper bonding eliminates.
- Fuel quality. Test fuel for contamination (water, sediment, and particulates) according to ASTM standards. Maintain records of all fuel quality tests. Contaminated fuel is among the most preventable causes of engine failure in general aviation.
- Spill prevention and response. Maintain spill containment and cleanup equipment near fueling areas. Have a written spill response procedure and ensure anyone involved in fueling knows how to use it. Report spills to the appropriate environmental authority as required by your state's regulations.
- NFPA compliance. Fuel storage and dispensing should comply with NFPA 407 (Standard for Aircraft Fuel Servicing). Fire extinguishers should be accessible, properly rated, and inspected on schedule.
- Training. Anyone involved in fueling operations — including self-service pump users — should understand basic fueling safety procedures, bonding requirements, and emergency response steps.
Building Safety Into Your Routine
The most effective safety programs are not elaborate — they are consistent. A ten-minute daily walkthrough that happens every morning is worth more than a comprehensive inspection that happens sporadically. The goal is to build inspection and documentation into the daily rhythm of operating your airport, not to create a separate compliance exercise that competes with your other responsibilities.
Start with a simple checklist that covers the basics: pavement, lighting, windsock, fencing, and fuel. Expand it over time as you develop a better understanding of the specific hazards and maintenance patterns at your field. The inspection infrastructure you build now will serve you well as your airport grows.
The next chapter covers lease administration and tenant management — the business side of running an airport that directly affects both your revenue and your compliance obligations.