What Belongs in a Hangar Tenant File

This one is short on purpose. It is a checklist you can run against your own files this week: nine records per tenant, why each fails, and how to check.

The FAA's expectation, stated in its hangar use guidance, is that a sponsor manages the use of hangars through an airport leasing program requiring a written lease agreement or permit, monitors how hangars are used, and takes steps to prevent unapproved non-aeronautical use. Everything below supports that.

1. The Lease, With Every Amendment and Assignment

Not the version you think is current. The signed original plus every amendment, extension, assignment, and consent, in order.

Why it fails: Amendments get executed and filed separately from the original, or not filed at all. Assignments happen when a hangar changes hands and the paperwork trails the transaction.

What auditors find: Detroit's Office of the Auditor General found 16 of 58 tenants had no lease at all, and that the department could not produce lease agreements for several tenants. A Cuyahoga County audit found payments received on leases where the county did not hold a copy of the agreement.

The check: Every occupied unit maps to one active, complete lease file. Every unmatched occupant is a finding.

2. A Current Certificate of Insurance

This is the item most likely to be out of date right now, at almost any airport.

What to require. Requirements vary, but published examples give you a sense of the range. El Dorado County, California requires motor vehicle liability of not less than $250,000 per person, $500,000 per occurrence, and $500,000 property damage where vehicles are used on the premises, and commercial general liability including hangarkeepers coverage of at least $75,000 or the value of stored aircraft for personal hangars with a ground lease. The county must be named as additional insured, and the lessee must provide replacement certificates at least 30 days before expiration. The City of Fort Worth's minimum standards require the city to be named additional insured, with primary and non-contributory coverage and a waiver of subrogation. General liability requirements of $1,000,000 per occurrence with the airport named as additional insured are common at GA fields.

What "additional insured" means and why it matters. Being named additional insured makes the airport an insured party under the tenant's policy for liability arising out of the leased premises. It is the mechanism by which the tenant's insurance responds to a claim that names the airport.

Here is the part that gets underappreciated: that protection exists only while the policy is in force. If the certificate expired eight months ago and nobody noticed, the airport's additional insured status went with it. You do not discover this at renewal time. You discover it when there is a claim.

Why it fails: Certificates mirror the underlying policy term, so most expire annually. Collecting them once at lease signing is not a system. Somebody has to re-collect every year, for every tenant, forever.

What auditors find: The City of Boise's internal audit sampled 30 leases and found 9 without current certificates on file. Nearly a third, at an airport with dedicated staff.

The check: Sort every certificate by expiration date. Count the ones that have passed.

3. Aircraft Registration and Based Aircraft Verification

Track the N-number of the aircraft in the hangar, and verify it is registered.

This connects directly to an obligation you already have. Non-primary NPIAS airports must enter based aircraft tail numbers at basedaircraft.com, and the counts for single-engine, multi-engine, jet, and helicopter aircraft on the 5010 airport master record come from that data. The site is a component of the annual inspection process. An entered N-number is only verified and counted if it is found in the FAA aircraft registration database and is not duplicated at another airport. The underlying requirement traces to FAA Order 5010.4, which calls for based aircraft data from the most reliable source possible.

Why it matters beyond the 5010: Based aircraft counts feed the national plan and support development justification. And practically, verifying that a tenant's registered aircraft is actually based in that hangar is the cleanest evidence that the hangar is in aeronautical use.

The check: Every hangar tenant file has an N-number, and that N-number appears in your validated based aircraft list.

4. Sublease Consents

If your lease requires written consent to sublease, the consent should be in the file. If a tenant is subleasing without one, that is worth knowing.

Why it fails: Subleases are often informal arrangements between pilots that nobody thinks to document, and the airport learns about them incidentally.

The check: Does anyone occupy a hangar whose lease is in someone else's name? Is there a consent on file?

5. Security Deposit Record

The amount required by the lease, the amount actually received, the date, and where it is held.

What auditors find: Detroit's audit found the airport held $100,519 in refundable tenant deposits against only $1,005 in the corresponding account, with no written policy for handling deposits and no separation from the department's general funds.

The check: Total deposits your leases say you hold. Compare to your deposit account. They should match.

6. Rate History and Escalation Record

The current billed rate, the rate stated in the lease, the escalation clause if any, and the date each adjustment was applied.

Why it fails: Escalators require someone to remember, calculate, and bill. Miss a few cycles and the gap compounds quietly.

The check: For each lease with an escalation clause, recalculate from inception and compare to what you bill today.

7. Hangar Use Documentation

Some airports use an annual hangar use certification signed by the tenant, paired with a physical inspection. Coalinga and Hanford in California both operate hangar use and inspection policies with annual inspections on 30 days' notice, implementing the 2016 FAA policy directly.

Whether or not you inspect annually, keep a record of what you know about how each hangar is used, and any correspondence about it.

Why it matters: The 2016 hangar use policy says FAA personnel conducting a land use or compliance inspection may request a copy of the sponsor's hangar use program and evidence that the sponsor has limited hangars to aeronautical use. Having a program you cannot document is close to not having one.

8. Waitlist Position and History

If you maintain a waiting list, keep dated records of positions, offers made, and transfers.

Why it matters: Waitlist fairness is a recurring source of complaints, and the FAA's hangar policy specifically says sponsors should minimize the time people spend waiting. A Minnesota Legislative Auditor review of Metropolitan Airports Commission hangar leasing found that a lease transfer not done in a timely way created the impression that waiting list priority had not been honored. Note the framing: the impression was the problem.

An undocumented waitlist is impossible to defend and easy to attack.

9. Correspondence

Notices, complaints, warnings, and any conversation that would matter if it were later disputed.

Why it matters: Under 14 CFR Part 16, a sponsor responding to a formal complaint files its answer within 20 days, with supporting documentation. Correspondence is often the documentation. We walked through that complaint process and its deadlines last week.

The One-Page Version

For each tenant, you should be able to produce:

Signed lease plus all amendments and assignments
Current, unexpired certificate of insurance naming the airport as additional insured
Verified N-number matching your based aircraft list
Sublease consent, if applicable
Deposit amount, received date, and location
Current rate, lease rate, escalation terms, and adjustment history
Hangar use record or certification
Waitlist history, if the unit was assigned from a list
Correspondence file

If you cannot produce all nine for a given tenant in a few minutes, that tenant is a gap. If you cannot produce them for most tenants, the gap is the system, not the tenants.

Beyond the Tenant File: Three Airport-Level Checks

The tenant file is the unit of record, but audit reports flag a few things that live above any single tenant. While you are checking files, check these too:

Receivables past 90 days with no contact. San Antonio's city auditor found $1.3 million of airport receivables more than a year old, with required dunning letters not sent and late fees provided for in the leases never charged. Run an AR aging; anything past 90 days that nobody has contacted is the finding.

Third-party-reported revenue never independently verified. If an FBO calculates its own fuel flowage fees and nobody checks the gallons, you are trusting a number you did not compute. Cobb County's 2025 internal audit and a DeKalb County audit both flagged exactly this.

A written leasing policy. Multiple audits land on the same root finding: no documented process for how leases get approved, renewed, and monitored. It is the finding that explains all the others.

How to Actually Run This

Do not try to fix everything at once. Run it in this order, because it sorts by consequence:

Today: Expired insurance certificates. This is the one with a real, uninsured downside, and it is the fastest to check.

This week: Occupants with no lease, and leases past their end date with the tenant still in place.

This month: Escalation clauses never applied, and the deposit reconciliation.

This quarter: Everything else, plus a written policy so the next person does not have to rediscover all of this.

The counts matter more than the dollars when you present this. "Nine of thirty tenants have no current certificate of insurance" is a sentence that produces action. A dollar estimate invites an argument about the estimate.

If your version of this checklist is currently a filing cabinet, that is the problem the Hangar Direct platform was built to solve: it keeps all nine records per tenant, tracks the compliance documents, and tells you which ones are missing.

Sources

FAA, Frequently Asked Questions on FAA Policy on Use of Hangars at Obligated Airports. https://www.faa.gov/airports/airport_compliance/hangar_use
Policy on the Non-Aeronautical Use of Airport Hangars, 81 FR 38906 (June 15, 2016)
City of Boise Office of Internal Audit, Report 17-01, Airport Leases. https://www.cityofboise.org/media/5128/1701airportleases.pdf
City of Detroit Office of the Auditor General, Coleman A. Young International Airport audit, 2019
City of San Antonio Office of the City Auditor, Report AU08-010
Cobb County Internal Audit, Report 2025-003 (Aug. 18, 2025); DeKalb County Office of Independent Internal Audit, IA-2025-0268-AP (Dec. 2025)
Cuyahoga County Department of Internal Auditing, Facilities Revenue Audit, 2023
Minnesota Office of the Legislative Auditor, Report FAD 03-54, Metropolitan Airports Commission hangar leasing and use (Sept. 29, 2003). https://www.auditor.leg.state.mn.us/fad/pdf/fad0354.pdf
El Dorado County airport ground lease and hangar insurance requirements
FAA Order 5010.4, Airport Safety Data Program; basedaircraft.com
14 CFR 16.23