Livingston County Airport, the Landing Fee That Reversed, and the Federal Grant Assurance Every GA Pilot Should Know

Livingston County Spencer J. Hardy Airport in Howell, Michigan implemented a landing fee for transient general aviation aircraft earlier this year, then reversed it after organized pilot pushback. The revised policy charges for ramp and facility use - not the act of landing. That distinction is the entire legal argument, and it’s one every GA pilot should understand before it shows up at an airport near them.

What Happened at Livingston County Airport

Spencer J. Hardy Airport (KOZW) is a general aviation field roughly 40 miles northwest of Detroit. It has no airline service and serves the local flying community along with cross-country traffic. It is, by every operational definition, a GA airport.

The airport authority introduced a flat landing fee for transient aircraft. Pilot reaction was immediate and organized. Within a reasonable timeframe, the authority restructured the charges to apply only when a pilot uses the ramp or facilities - not simply for touching down on the runway.

The reversal happened because pilots didn’t just complain. They invoked the specific federal framework that governs airports accepting federal money.

What Is Grant Assurance 22 and Why Does It Matter?

When an airport accepts federal funding through the Airport Improvement Program (AIP), administered by the FAA, it agrees to 39 grant assurances - binding obligations covering everything from civil rights compliance to maintenance standards. These obligations typically run 20 years for major capital projects and 10 years for smaller ones.

Grant Assurance 22 is titled “Economic Nondiscrimination.” In plain terms, it requires the airport to make its facilities available on reasonable terms to all types and classes of aeronautical users, without unjust discrimination.

That word “unjust” carries significant legal weight. Airports can charge for fuel, tie-downs, hangar space, FBO services, and ramp use. What they cannot do - under most interpretations - is single out a class of user for charges that don’t apply to comparable users, or impose fees so unreasonable they effectively discourage GA access to a federally funded public airport.

Is a Landing Fee at a GA Airport Legal?

The FAA has not issued a blanket prohibition on landing fees. But it has taken the position in past enforcement actions that a flat landing fee at a fully grant-funded GA airport can violate Grant Assurance 22 when it isn’t offset by any proportionate service or facility benefit.

A fee for ramp use is defensible - services are being rendered. A fee for the act of landing on a runway built with federal money at a publicly designated airport is much harder to justify under the grant assurance framework.

The statute underlying all of this is Title 49 of the United States Code, Section 47107 - the AIP statute from which Grant Assurance 22 derives. That’s the starting point for understanding your rights as a GA pilot at any federally obligated airport.

Why Airports Try Landing Fees Anyway

Airport finances are genuinely difficult. Many municipal and county airports face declining fuel revenue, rising maintenance costs, and pressure from local governments to reduce tax subsidies. Jet traffic pays landing fees routinely. Airport managers sometimes look at GA traffic and see aircraft consuming runway pavement and maintenance budget without generating proportionate revenue.

The fee looks like a solution. It usually isn’t.

General aviation is mobile. When an airport becomes more expensive or more hostile, traffic diverts. Fuel sales drop. FBO business declines. The revenue a landing fee was meant to capture often routes itself to the next airport down the road - and the airport’s financial case erodes over time. This has happened repeatedly at airports that implemented aggressive fee structures without accounting for the diversion effect.

Why This Matters Beyond Michigan

The same pressure on airport finances exists everywhere. Thin fuel margins, tight municipal budgets, and the temptation to find new revenue streams aren’t unique to Michigan. Landing fees and restrictive policies will come up again at other airports - possibly ones you fly to regularly.

There’s also a network safety argument. GA airports serve as training grounds, emergency alternates, fuel stops, and community connections. When fees discourage access, pilots route around fields they’d otherwise use. That means more flight time over unfamiliar terrain, more fatigue on longer legs, and one fewer field where someone knows the runway condition.

The airport system functions because of its density. Every accessible node matters.

How Pilots Can Push Back Effectively

The Livingston County outcome wasn’t produced by social media frustration. It was produced by pilots who engaged the actual legal mechanism - the grant assurance framework - specifically enough that the airport authority modified its policy rather than defend it.

When the argument is “I don’t like this fee,” airports can ignore it. When the argument is “this fee may put your federal funding relationship at risk,” the conversation changes.

AOPA maintains an airport advocacy program specifically for disputes like this. If you encounter a fee or policy at a public-use airport that appears inconsistent with its federal obligations, AOPA has a submission process and a legal team that has handled these cases before. The FAA also accepts complaints through its regional offices. Both channels are slow - but they produce results, as Livingston County demonstrates.

Showing up to airport authority board meetings matters too. Many airport boards are made up of appointed or elected officials who are not pilots and don’t understand how GA economics work. The difference between what an airliner pays at O’Hare and what applies to a Cessna 172 at a county airport is not self-evident to a non-pilot board member. Local advocacy - explaining what GA contributes to the community and the airport’s revenue base - is unglamorous, time-consuming, and genuinely effective.

Key Takeaways

• Livingston County Spencer J. Hardy Airport reversed a GA landing fee after pilots organized around the federal grant assurance framework, not general objection.
• Airports accepting Airport Improvement Program funding agree to 39 grant assurances with obligation periods of up to 20 years.
• Grant Assurance 22 (Economic Nondiscrimination) is the specific rule that constrains what publicly funded airports can charge GA pilots. It derives from 49 U.S.C. § 47107.
• Charging for ramp use and facility access is legally defensible. Charging for the act of landing on a federally funded runway - with no proportionate service benefit - is not.
• AOPA’s airport advocacy program and FAA regional offices are the formal channels for challenging policies that may violate grant assurances. Using the specific legal language is what moves airports to act.