3. Fuel Flowage Fee Strategy & Methodology May 2016 i
CONTENTS
SECTION ONE: JAA Fuel Flowage Fee Background............................................................................ 1
1. JAA Fuel Flowage Fee History ...................................................................................................1
2. Purpose of this Fuel Flowage Fee Strategy & Methodology ...................................................1
3. Justification of Fuel Flowage Fee Collection at JAA Airports...................................................2
4. Notable Changes to Past Policies..............................................................................................2
SECTION TWO: JAA Fuel Flowage Fee Practices and Procedures...................................................... 3
1. Assessment of Fuel Flowage Fees.............................................................................................3
2. Fuel Flowage Fee Exemptions...................................................................................................3
3. Fuel Flowage Fee Review ..........................................................................................................3
4. Reporting Requirements ...........................................................................................................4
5. Implementation of This Methodology......................................................................................4
6. Inclusion of Fuel Flowage Fees in General Aviation Rates and Charges.................................4
7. Inclusion of Fuel Flowage Fee Language in Subsequent Lease Agreements..........................4
APPENDIX A: Standard FFF Reporting Form ..................................................................................... 5
APPENDIX B: Recommended Fuel Flowage Fee Lease Language...................................................... 6
4. Fuel Flowage Fee Strategy & Methodology May 2016 1
SECTION ONE: JAA Fuel Flowage Fee Background
1. JAA Fuel Flowage Fee History
The Jacksonville Aviation Authority (JAA) has collected fuel flowage fees (FFF) from its lessees since at
least the 1970s, historically assessed as a certain charge per gallon of aviation gasoline (100LL or avgas),
Jet-A, or automobile gasoline (mogas) pumped into the fuel tank of an aircraft. This method is known as
“into-plane” and is the process utilized by many airports around the nation. Other historical JAA ancillary
concession charges related to FFFs included a per-liter fee on oils and lubricants and a per-gallon security
fee on fuel pumped at Jacksonville Executive at Craig Airport (JAXEX), the latter added after the terrorist
attacks of September 11, 2001.
Tenants responsible for payment of fuel flowage fees to the Authority typically include fixed base
operators (FBOs) that sell retail fuel to customers, or private companies or individuals who possess
storage tanks on their leaseholds from which they pump fuel into their own aircraft. Prior to
implementation of the methodology in this document, applicable lessees reported their gallons pumped
to the JAA Finance Department each month by submitting a “Monthly Gross Revenue Fuel Report,” and
the burden for separating gallons pumped at different rates rested with the reporting tenant. Charges at
each airport differed widely; at the time this document was created, seven different rates were in use
across four different categories of FFF charge. This disjointed arrangement was the result of lease
agreements created years (sometimes decades) apart from one another under different executive
leadership groups and prevailing economic conditions. Adding to the confusion was the fact that several
government lessees were precluded from paying fuel flowage fees altogether through “grandfathered”
agreements.
A need was therefore perceived to standardize and streamline this process, resulting in the creation of
this Fuel Flowage Fee Strategy & Methodology.
2. Purpose of this Fuel Flowage Fee Strategy & Methodology
The purpose of this document is to establish an Authority-wide business policy that standardizes and
streamlines the assessment of fuel flowage fees at all Jacksonville Aviation Authority airports. It replaces
the fragmented FFF framework in place at the time of its creation and outlines new methods of fee
assessment, implementation and review. Furthermore, this methodology serves as a reference that
clearly outlines the reasoning behind and the processes involved in the JAA’s FFF collection strategy. In
effect, it answers the questions raised by the absence of such a policy in the past.
An additional intent of this methodology, in line with the desire to dispose of the current disorganized
rate structure, is to ensure that a discriminatory environment does not exist. According to Federal
Aviation Administration (FAA) Order 5190.6B, “Grant Assurance 22, Economic Nondiscrimination, requires
the [airport] sponsor to make its aeronautical facilities available to the public and its tenants on terms
that are reasonable and without unjust discrimination,” and more specifically that the airport “must
impose nondiscriminatory and substantially comparable rates, fees, rentals, and charges on all air carriers
and users that assume similar obligations, use similar facilities, and make similar use of the airport.” The
procedures within this document eliminate disparate rates and, therefore, the potential for claims of
unjust discrimination as well.
5. Fuel Flowage Fee Strategy & Methodology May 2016 2
3. Justification of Fuel Flowage Fee Collection at JAA Airports
The JAA, as a recipient of federal Airport Improvement Program (AIP) funds, derives its authority to
collect FFFs from FAA grant obligations. Specifically, Grant Assurance 24, Fee and Rental Structure,
stipulates that an airport must “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.” The aforementioned FAA Order 5190.6B further clarifies this requirement, stating that
“…airports should be operated efficiently both for aeronautical users and the government, relying
primarily on user fees and placing minimal burden on the general revenues of the local, state, and federal
governments.”
Given this regulatory framework, the Authority has instituted fuel flowage fees for the following primary
reasons:
as an acknowledgement of its prerogative to charge reasonable fees to users of its airports,
ensuring compliance with the grant obligations previously highlighted (most notably to operate
the airport in as self-sustaining a manner as possible).
to mitigate environmental liabilities assumed by the Authority’s allowing large amounts of fuel to
be stored on its property. Although tenants possessing tanks are required to carry insurance, the
implications of an environmental event are far-reaching and time consuming, and would result in
a large burden upon the JAA.
4. Notable Changes to Past Policies
This Fuel Flowage Fee Methodology implements a number of new processes and eliminates several long-
standing FFF practices. These include:
Security and “mogas” fees are removed.
The former was a dated charge with little justification for its existence and no accounting for its
allocation (i.e., no direct security improvements resulted from collection of the security fee),
while the latter was a negligible charge for a little-used fuel source. The elimination of both
serves to streamline bookkeeping.
Oil and lubricants fees are removed.
Like the security and mogas fees, the charges on oils and lubricants unnecessarily complicated
the accounting process. In addition, this fee was applied only to certain tenants.
A separate government rate no longer exists.
No record could be found for the justification of the existing lesser rate at JAA airports or why
each airport had different government rates.
As is the case with all changes implemented by this document, the intent of removing the above practices
was to streamline bookkeeping processes and ensure fair and comparable rates to all JAA tenants subject
to FFF charges.
6. Fuel Flowage Fee Strategy & Methodology May 2016 3
SECTION TWO: JAA Fuel Flowage Fee Practices and Procedures
This methodology replaces fuel flowage fee practices and procedures at the time of its creation and
replaces them with the following:
1. Assessment of Fuel Flowage Fees
JAA fuel flowage fees will be assessed per gallon pumped into aircraft fuel tanks, and at two rates only –
Jet-A and 100LL. This method serves to simplify accounting and recordkeeping procedures by eliminating
segmentation of Jet-A and 100LL charges (i.e. “Government Jet, GA Jet, GA 100LL, etc.).
Fuel flowage fee rates will apply to all FFF-paying tenants at the same rate. By extension, any future
adjustment of the rate will apply to all tenants.
In addition, all ancillary and concession charges are removed from the FFF picture. Tenants will no longer
be required to pay security fees, oil or lubricants fees, or mogas fees.
2. Fuel Flowage Fee Exemptions
FAA certificated Part 121 scheduled air carriers at Jacksonville International Airport (JAX), under current
executed agreement with the Authority and in good standing, are not required to pay a FFF. Fixed base
operators at JAX are responsible for deducting gallons pumped into air carrier aircraft from their Jet-a
gross each month, thereby arriving at the total chargeable gallons.
This exemption applies only to air carrier aircraft fueled at the JAX terminal building.
3. Fuel Flowage Fee Review
A review of FFF rates will occur annually and consist of the following criteria:
an analysis of the Consumer Price Index (CPI) activity over the period since the last FFF review.
However, a decrease of the CPI at the time rates are adjusted will not constitute a requirement
on the part of the JAA to lower the FFF.
a survey of FFF rates throughout the Northeast Florida region, State of Florida, and Southeast
United States. The JAA representative conducting the survey will include airports similar to the
Authority's mix (small uncontrolled general aviation, towered corporate GA, etc.) in the survey to
ensure an accurate data sample.
an assessment of prevailing economic conditions, including the market price of oil.
Once every three years, following completion of the annual review on the third year, representatives
from Business Development and the management teams of each general aviation airport will make a
determination on FFF adjustment based on the information gathered during the review. The point at
which adjustments (if any) will take effect will be determined by this group and communicated to
7. Fuel Flowage Fee Strategy & Methodology May 2016 4
affected lessees within a reasonable time period, but in no case will less than thirty (30) days notification
be provided.
4. Reporting Requirements
FBOs will be required to report total monthly fuel deliveries no later than the fifteenth day of each month
for the preceding month's activity. The Jacksonville Aviation Authority Fuel Flowage Fee Reporting Form
(see Appendix A) should be used for all reporting and submitted to the JAA Finance Department utilizing
the contact information on the form.
Those tenants with government fuel contracts should continue using their previous reporting method
until the government contract is renewed, at which time government fuel will be adjusted to the new
rate, and the new form should be used.
As previously mentioned, JAX FBOs will be responsible for subtracting gallons pumped into air carrier
aircraft from total deliveries to avoid incurring unnecessary FFF charges. The JAA assumes no
responsibility for a JAX FBO’s failure to report exempt air carrier gallons at any given time.
5. Implementation of This Methodology
This new methodology will go into effect for applicable lessees on January 1st
, 2017. In cases where a
tenant has an active government fuel contract, assessment of the new rate will apply to government fuel
after completion of that contract. Otherwise, the new rate will apply to all other fuel types for that
tenant beginning January 1st
.
Affected lessees will receive notification of the proposed changes following their approval by the JAA’s
Chief Executive Officer, but in no case will implementation occur with less than thirty (30) days’ notice to
lessees.
The “grandfathered” agreements of some governmental tenants, whereby the lessee is not required to
pay a fuel flowage fee, will be reviewed prior to renewal, and inclusion of FFF provisions will be
negotiated with the lessee at the time of renewal.
6. Inclusion of Fuel Flowage Fees in General Aviation Rates and Charges
Upon commencement of this policy, fuel flowage fee rates will be included on the JAA “General Aviation
Rates and Charges” document. Lease agreements should refer to this document and should avoid
reference to a specific FFF rate.
7. Inclusion of Fuel Flowage Fee Language in Subsequent Lease Agreements
Where possible, and to promote standardization and commonality between leases, the language
delineated in Appendix B is recommended for inclusion in new or renewed agreements with FFF-
applicable entities. However, the text contained therein serves as a recommendation for future use only
and in no way acts as an amendment to or replacement of any language or lease agreement currently in
effect at the time this Methodology was enacted.
8. Fuel Flowage Fee Strategy & Methodology May 2016 5
APPENDIX A: Standard FFF Reporting Form
COMPANY:
MONTH: YEAR:
FUEL TYPE GALLONS PUMPED RATE PER GALLON TOTAL
X 0.068$ = -$
Total Jet-A pumped
minus airline* gals. pumped -
X 0.068$ = -$
-$
CERTIFICATION: I hereby certify that the above information is true and correct and reflects an accurate accounting
of gallons delivered during this period
Date Authorized Signature Type or Print Name
Phone Title (President, Owner or other duly authorized officer)
Reporting Instruction:
1 This report and corresponding monies due shall be submitted so that it is received by the JAA no later
than the fifteenth (15th) day of each month for the preceding month's activity.
2 Report must be signed by president, owner or other duly authorized person.
3 All documentation and payments shall be submitted to: JACKSONVILLE AVIATION AUTHORITY
Attn: Finance
14201 Pecan Park Rd.
Jacksonville, FL 32218
(904) 741-3756----FAX (904) 741-3765
concessionreporting@flyjacksonville.com
*An "airline" shall mean any FAR Part 121-certifcated scheduled air carrier aircraft at Jacksonville International Airport under a current, executed agreement with
the Jacksonville Aviation Authority.
Avgas
JACKSONVILLE AVIATION AUTHORITY
MONTHLY FUEL FLOWAGE FEE REPORTING FORM
Jet-A
Total Jet-A Gallons
TOTAL DUE
For Use by JAX FBOs
9. Fuel Flowage Fee Strategy & Methodology May 2016 6
APPENDIX B: Recommended Fuel Flowage Fee Lease Language
The following language is recommended for inclusion in lease agreements executed or renewed after
implementation of this Fuel Flowage Fee Strategy and Methodology:
"Lessee shall collect and remit to the Authority fuel flowage fees levied per gallon of Jet-A or 100LL
fuel pumped into aircraft fuel tanks. Fuel flowage fees shall be assessed at the rate(s) currently
listed in the Authority’s General Aviation Rates and Charges document.
Lessee agrees to report and pay fuel flowage fees on a monthly basis.
Lessee acknowledges and agrees that Authority reserves the right, with not less than thirty (30)
days written notice to Lessee, to adjust fuel flowage fees, which adjustments may include, but
shall not be limited to, alteration of the rates, method of collection or basis for calculation.”
It is also recommended that JAX FBO agreements contain the following additional language:
“Unless otherwise advised in writing in advance by Authority, fuel flowage fees shall not be
collected from fuel pumped into the aircraft of FAR PAR 121 scheduled commercial air
transportation companies, both signatory and non-signatory, under an executed agreement with
the Authority, as indicated on a listing or notice to be provided to Lessee by the Authority from
time to time.
Lessee assumes full responsibility for reporting fuel pumped into such commercial air carrier
aircraft and at no time will the Authority be held liable for Lessee’s failure to report, or errors in
reporting, air carrier gallons pumped.”
A wide variance in fuel flowage fee lease language existed at the time this Strategy and Methodology was
created. Many agreements listed the actual rate to be charged, which rendered that section of the lease
obsolete as soon as any rate changes occurred. Using the language above that references the rate listed
on an external document keeps that section of the agreement current and relevant.