### DONNA M. DUNK, CPA AU DITOR

-CONTROLLER TREASURER -TAX COLLECTOR

585 FISCAL DRIVE, SUITE 100 SANTA ROSA, CA 95403

PHONE (707) 565-263 1

FAX (707) 565-3489

January 10, 2017
Federal Aviation Administration ERICK ROESER ASSISTANT AUDITOR-CONTROLLER

TREASUR ER-TAX COLLECTOR JONATHAN KADLEC ASSISTANT AUDITOR-CONTROLLER

TREASURER -TAX COLLECTOR

Attention: Director, Airport Compliance and Management Analysis 800 Independence Avenue SW Washington, D.C. 20591 Subject: Compliance with FAA Policy and Procedures Concerning Use of Airport Revenue (79 Fed. Reg. 6628201, November 7, 2014) Dear Sir/Madam:
This letter is sent on behalf ofthe County ofSonoma, operator of Charles M. Schulz Sonoma County Airport (KSTS), hereinafter referred to as "Sonoma County Airport" and responds to the Federal Aviation Adm inistration ("FAA") recent amendment to the FAA Policy and Procedures Concerning the Use ofAirport Revenue ("FAA Amendment"}. The FAA Amendment addressed how proceeds from taxes imposed on the sale ofaviation fuel are to be used. We apologize for the delay in the submission ofthis letterfor your consideration. Based on our understanding ofthe applicability ofthe FAA Amendment, we believe that the Sonoma County Airport is in compliance with its requirements. The County of Sonoma ("County" ) does not impose any general sales tax on the sale ofaviation fuel. There are three "special taxes", as defined in Section 3 ofArticle XIII A ofthe California Constitution, on sales of products and services within the County, including aviation fuel, that are subject to sales taxes in California. The three special taxes were approved by the required 2/3 majority ofvoters in the County and the proceeds from those special taxes are for specified uses, as approved by the voters, and are notfor general use or purposes. Each ofthese tax measures has restrictions on the use of revenue and those restrictions can only be removed or amended by a vote ofthe electorate. Revenues collected pursuant to the three special taxes described above are distributed to those agencies for whose benefit the taxes are imposed, each ofwhich is a separate agency. The County does not receive revenue from these special taxes. The special taxes are:
1. Measure M (effective 4/1/2005)-

**~cent** tax; proceeds paid to Sonoma County Transportation Authorityto be used for roads, public transit and bicycle lanes. 2. Measure Q (effective 4/1/2009)-

**~cent** tax; proceeds paid to Sonoma Marin Area Rail Transit to be used forthe construction, operation and maintenance of a regional rail transit system.3. Measure F (effective 

### 4/1/2011)- }{cent tax; proceeds paid to Sonoma County Agricultural Preservation and Open Space District to protect, preserve and provide access to certain types of land

. Sonoma County Airport does not sell aviation fuel. Fuel that is sold at Sonoma County Airport is sold and dispensed by private parties who collect and remit sales taxes on the sale ofaviation fuel to the State of California Board of Equalization ("BOE"). The BOE then remits payment of sales tax proceeds in accordance with its own procedures

. It is our further understanding that BOE has provided an action plan response as it relates to achieving compliance with the FAA Amendment. If BOE's action plan response requires a change in the County's current approach to receipt and use of any sales tax revenues distributed by BOE, the Countywill implement necessary changes to comply.
It is our understandingthat the FAA Amendment applies to the portion ofstate and local general sales tax revenues derived from the sale of aviation fuel and that such tax revenues must be spent on aviation programs and for airport-related purposes. Because the County does not impose, and does not receive, revenue from general sales tax derived from the sale of aviation fuel, there are no sales tax proceeds that are subject to the FAA Amendment. For that reason, we believe that the Sonoma County Airport is in compliance with the FAA Amendment. Please advise ifyou disagree with our understanding ofthe applicability ofthe FAA Amendment to sales taxes imposed on the sale of aviation fuel at Sonoma County Airport. Thank you for your consideration to this matter. Thank you,

Erick Roeser Assistant Auditor-Controller-Treasurer-Tax Collector County ofSonoma