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FAA Order 5190.6C: What Changed for Hangar Operators

T

The Hangar Direct Team

hangardirect.com

complianceFAAlease management

On February 20, 2026, the FAA replaced its Airport Compliance Manual, Order 5190.6B, with Order 5190.6C. For hangar operators there is no single dramatic rule change. The real change is that FAA guidance on waitlists, residency preferences, illegal charter, self-fueling, lease terms, and land use inspections now sits in one current document, and FAA staff will cite it back to you by section number.

Plenty of airport offices still have the 2009 version of the manual saved on a shared drive. That version picked up three interim changes between 2021 and 2023. The new order folds those changes in and updates ten more chapters. Section numbers moved in several places, which is why the FAA published a Section Renumbering and Retitling Chart alongside it. If your rules, leases, or board memos cite 5190.6B paragraph numbers, some of those citations now point to the wrong place.

This post covers the parts that matter to people who lease hangars and manage tenants. This is a general explainer, not legal advice. Your FAA Airports District Office and your airport attorney are the authorities on any specific situation.

What the Manual Is, and What It Is Not

It is guidance for FAA staff. The FAA describes the order as providing "basic guidance for FAA personnel in interpreting and administering the various continuing commitments airport owners make to the United States as a condition for the grant of federal funds or the conveyance of federal property for airport purposes." It is not a regulation. Your obligations come from your grant assurances and property deeds.

In practice, it is the rulebook anyway. ADO staff, regional compliance specialists, and the people who investigate informal and formal complaints read your obligations through this manual. If you end up in a Part 13 or Part 16 complaint, 5190.6C is the text the FAA will measure you against.

What it replaced. Order 5190.6C cancels 5190.6B and absorbs its three changes (December 2021, December 2022, and September 2023), then updates Chapters 6, 7, 8, 12, 13, 14, 15, 20, 21, and 22, along with Appendix G.

One caution. Some of the hangar-relevant text below, especially in Chapters 9 and 10, first showed up in Change 1 in December 2021. If nobody on your team read Change 1, it is new to you, and the FAA will not treat it as new.

Leased Space, Waitlists, and Residency (Chapter 9)

You have a duty to negotiate in good faith. Section 9.7 says sponsors must make space available for noncommercial users, "(i.e., hangars and tie-down space for individual aircraft owners)," and that "unless it undertakes to provide these services itself, the sponsor has a duty to negotiate in good faith for the lease of premises available to conduct aeronautical activities."

You do not have to lease ground for a private hangar while your own hangars sit empty. Section 9.7.b is useful and often overlooked: "When adequate facilities are otherwise available for lease, Grant Assurance 22, Economic Nondiscrimination, does not compel sponsors to lease vacant property to entities seeking to construct facilities for private aeronautical use." The FAA's own example is a request to build a private hangar while vacant hangars on the field could meet the applicant's needs. The section cross-references Grant Assurance 38, Hangar Construction. To rely on it, you need records showing that vacant units exist and actually fit the aircraft. If your vacancy data lives in someone's head, this defense is weak.

Waiting lists should be open to review. In its discussion of FBO management agreements for federally funded apron, the manual lists "nondiscriminatory waiting lists for tie-down or hangar spaces" as an acceptable practice. It adds: "Waiting lists should be available for review by existing and prospective airport tenants to ensure transparency and avoid the appearance of unjust discrimination in the selection of tenants." The sentence sits in an apron-management context, but it is the clearest written statement of what the FAA expects from any hangar list. Our waitlist post covers intake and ordering. The new point is transparency: tenants should be able to see where they stand.

Residency preferences are out. Section 9.10 is blunt. Preferring local residents when assigning hangars is "unreasonable and unjustly discriminatory, and can result in the granting of an exclusive right contrary to Grant Assurance 22, Economic Nondiscrimination, and Grant Assurance 23, Exclusive Rights." Paying local taxes does not change that: "a local tax obligation does not establish a reasonable basis upon which to discriminate between resident and nonresident airport users." If your waitlist rules give county residents priority or a discount, fix it before a nonresident files a complaint.

Rates can change over time, but there is a right way to do it. Section 9.2.d says a sponsor "does not engage in unjust discrimination simply by imposing different lease terms on carriers and users whose leases have expired." It recommends making new rates effective when all similarly situated tenants can move together, and suggests timing new agreements to expire alongside existing ones. Section 9.5.e says ground leases of five years or more should include periodic adjustments tied to a recognized index or appraisal. Setting defensible rates covers the mechanics.

Illegal Charter and Minimum Standards (Chapter 10)

Illegal charter. Section 10.7, added in Change 1, is the material most relevant to hangar operators. The FAA is clear that it "does not want airport sponsors to investigate suspected illegal aeronautical activities," such as illegal air charters. Concerns go to your local Flight Standards District Office. The section does describe lease and rules language that some sponsors use, including requiring tenants "to provide listing of aircraft used for commercial activities and their owners" and requiring copies of the current FAA-issued operating certificate for commercial operators. The stated reason matters for revenue: "This helps ensure that the airport sponsor charges the appropriate rates and charges to the commercial operator." A commercially used aircraft sitting in a hangar leased at a noncommercial rate is a rate problem as well as a safety problem.

Minimum standards and flying clubs. Section 10.1 confirms that "The FAA does not provide formal approval of minimum standards," though ADOs will advise, and Section 10.6 restates the FAA's flying club policy. We cover both in a separate post.

Self-Service Fueling Now Includes Electric Charging (Chapter 8)

According to the FAA's Summary of Updates, Section 8.7.b now states that refueling for self-service purposes "includes AVGAS, Jet A, electric charging, and other fueling sources." It also says alternative fueling sources used by new entrants are treated the same as conventional fueling under the self-service restriction, and it references Section 770 of the 2024 Reauthorization Act on 100LL. The chapter warns that channeling self-service activities to a commercial provider "may be an exclusive rights violation."

The practical result: a rule saying only the FBO may charge an electric aircraft gets the same analysis as a rule saying only the FBO may fuel a piston single. We cover self-fueling and Grant Assurance 40 in a separate post.

Lease Review (Chapter 12)

The FAA does not approve your leases. Section 12.3.a says the FAA "does not review all leases, and there is no requirement for an airport sponsor to obtain FAA approval before entering into a lease." Section 12.4 adds: "The FAA does not approve leases, nor does it endorse or become a party to the lease agreements."

Use the review list as your own checklist. When an ADO does review a lease, Section 12.3.b lists the provisions it looks at:

  • Premises. Is the tenant holding options or rights of first refusal on land it does not need?
  • Purpose. Does the lease state it, "such as 'the noncommercial storage of the owner's aircraft'"?
  • Term. "Most tenant ground leases of 30 to 35 years are sufficient to retire a tenant's initial financing," and the FAA "should not consent to proposed lease terms that exceed 50 years."
  • Payment. "All leases for a term of more than five (5) years should contain provisions for periodic adjustment of rates."
  • Title and subordination. Does title to improvements vest in the sponsor at expiration, and is the lease subordinate to your federal obligations?
  • Assignment and subleasing. Did the sponsor keep "the right to approve in advance an assignment (a sale or transfer of the lease) or sublease by the tenant"?

Our hangar lease agreement guide turns this list into clause-by-clause language.

Land Use Inspections (Chapter 21)

Chapter 21 was streamlined to walk through each phase of an inspection: airport selection, pre-inspection, onsite inspection, potential noncompliance areas, corrective action, and the post-inspection report. Regions must conduct at least two GA land use inspections per year, and the FAA targets at least 18 airports nationally. Before inspectors arrive, they ask for a list of all leaseholds, aeronautical and nonaeronautical. Among the most common problems the chapter names is "using hangars to store vehicles or other unrelated items." We cover inspection preparation in detail in a separate post.

Housekeeping Changes That Affect Your Files

  • Form 5010-1 is gone. Chapter 2 deletes all references to the cancelled FAA Form 5010-1 and points readers to the Airport Data and Information Portal (ADIP) for the Airport Master Record.
  • Attachments were removed. The FAA removed the Chapter 2 attachments titled Airport Grant Assurance Self Compliance, A Guide to Sponsor Obligations, and Sample Lease Log. It also removed the old Appendix G sponsor checklist. If your procedures name the Sample Lease Log as your template, keep the log and update the citation.

Related Federal Changes in the Same Window

  • Grant Assurance 40. Added April 25, 2025, it protects access to 100LL. The FAA's December 10, 2025 Q&A says no replacement fuel yet meets the statutory criteria.
  • Section 743 of the 2024 Reauthorization Act. For projects outside the FAA's ALP approval authority, Kaplan Kirsch summarizes, once a sponsor gives notice the FAA "has 45 days to assert jurisdiction, or the agency loses jurisdiction over that project."
  • Section 703. AOPA's June 1, 2024 summary of the GA provisions in the 2024 Reauthorization Act says Section 703 "Doubles the maximum penalty for an airport that illegally diverts airport revenue," and notes that before the change "the penalty is the amount equal to the illegal diversion in question, plus interest." Chapter 15 describes the change and notes limits on applying it to older diversions, so ask counsel how it applies to your history.

What This Means Practically: A 30-Minute Review

Block out half an hour with your lease files and your rules and regulations open:

  • Replace citations. Search your rules, minimum standards, and lease templates for "5190.6B" and update them to 5190.6C section numbers using the FAA renumbering chart.
  • Read your waitlist rules for residency language. Delete any resident priority or resident discount.
  • Decide what tenants can see. Write down how an existing or prospective tenant can check their position on the hangar list.
  • Add a commercial-use disclosure. Have each tenant certify annually which aircraft are used commercially, and collect operating certificates where they apply.
  • Check every lease over five years for an escalator. If it has none, put it on the renegotiation list for the next renewal.
  • Check assignment and sublease clauses. Each lease should require your written approval in advance.
  • Check terms over 35 years. Any lease or option package that could run past 50 years needs an ADO conversation.
  • Review self-fueling rules for electric charging. If your rules mention only avgas and Jet A, update them.
  • Pull your leasehold list. Confirm you could hand an inspector a list of every leasehold, aeronautical and nonaeronautical, today.
  • Read Chapters 9, 10, and 12 once, in full. Together they are under 40 pages.

Most of the work here is keeping records current: tenant use, aircraft, lease terms, and list position. If you want that in one place, Hangar Direct is built for it at platform.hangardirect.com.

Sources

Put the new manual to work on your own leases

Most 5190.6C exposure lives in lease terms, waitlist records, and tenant use files. Book a walkthrough and see how airports keep those records in one place an FAA reviewer can follow.

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