SAVANNAH 

HILTON HEAD 

.--------1 N T E R N A T I 0 N A L 

SAVANNAH 

AIRPORT 

COMMISSION 

CHAIRMAN 

Sylvester C. Formey 

VICE-CHAIRMAN 

Stephen S. Green 

COMMISSIONERS 

Shirley B. James 

Sheldon Tenenbaum 

Lois C. Wooten 

LEGAL COUNSEL 

James B. Blackburn 

EXECUTIVE DIRECTOR 

Gregory B. Kelly,AA.E. 

ASSISTANT 

EXECUTIVE DIRECTOR 

John Rauback, AAE. 

December 7, 2015 

Mr. Byron K. Huffman 

Acting Director 

Airports Compliance and Management Analysis 

Federal Aviation Administration 

800 Independence A venue SW 

Washington, DC 20591 

RE: Policy and Procedures Concerning the Use of Airpo1t Revenue Proceeds from Taxes 

on Aviation Fuel. 

Dear Mr. Huffman, 

The Savannah Airport Commission has not and does not rece ive any funds re lated to 

local aviation fuel sales tax collections, nor does it, or has it received "offsetting" services 

from the taxing authority which applies taxes to the sale of aviation fuel at our airport. In 

fact, in the twenty-six plus years I have been at this airport this issue has never been 

brought up by the FAA that I am aware of; until just after this year's Georgia State 

Legislative session which ended in July, 2015. 

Now all ofthe sudden we have to tell the FAA how we plan to "amend any noncompliant state laws and local ordinances to conform to federal law", and to develop 

reporting requirements and tracking systems related to local taxes collected by December 

8, 2015. While it is clearly in our own best interest to get this done as quickly as possible, 

the December 8

111 deadline is not reasonable considering what we have to go through to 

come up with a viable plan. We began working on this shortly after being notified in 

August of this year and as of this writing do not have enough information to present a 

plan. We still have yet to determine the following: 

1. Are the existing LOST, SPLOST, and ESPLOST being applied to sales of 

aviation fuel at our airport? 

2. If so, what sales are being taxed? We know how much fuel is delivered to this 

airport but we don't know where it is being taxed and by who. 

3. How much in terms of dollars is being collected? We have our estimate but we 

need to confirm this. 

4. Whether or not taxes applied under ESPLOST can be considered since those 

funds have to go to education constitutionally. 

We have been working with the State of Georgia Aviation Program Office and the 

State of Georgia Depattment of Revenue (DOR) to get these issues resolved but, the 

DOR has advised us that it will not be able to get us the information we need until 

January of 2016 at the earliest. We cannot move forward on this until we have accurate 

information. The FAA should understand this and understand that we are fully engaged in 

this and are making every effort possible to get this resolved so we can provide the FAA 

with a meaningful plan. 

400AIRWAYSAVENUE · SAVANNAH, GEORGIA 31408 • 912.964.0514 P • 912.964.0877 F •WWW.SAVANNAHAIRPORICOM 
It is our intent to request that the Georgia Dept. of Revenue establish a protocol to send the local 

tax revenues collected directly to this airport instead of to the taxing authority first. This will make it 

much easier for us to meet the reporting and tracking requirements established by the FAA. It is next 

to impossible for us to tell the FAA how we will report and track until we have the detailed 

information we need. 

Please contact me if you have any questions or need additional information and please consider 

this as our request for an extension on the submission date for our final plan. 

Sincerely, 

Greg B. Kelly, A. 

GBK:mmd