DONNA M. DUNK, CPA 

AUDITOR-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 

TREASURER -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 of the County of Sonoma, operator of Charles M. Schulz Sonoma 

County Airport (KSTS), hereinafter referred to as "Sonoma County Airport" and responds to the 

Federal Aviation Administration ("FAA") recent amendment to the FAA Policy and Procedures 

Concerning the Use of Airport Revenue ("FAA Amendment"}. The FAA Amendment addressed 

how proceeds from taxes imposed on the sale of aviation fuel are to be used. We apologize for 

the delay in the submission of this letter for your consideration. 

Based on our understanding of the applicability of the 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 of aviation fuel. There are three 

"special taxes", as defined in Section 3 of Article XIII A of the 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 of voters in 

the County and the proceeds from those special taxes are for specified uses, as approved by the 

voters, and are not for general use or purposes. Each of these tax measures has restrictions on 

the use of revenue and those restrictions can only be removed or amended by a vote of the 

electorate. Revenues collected pursuant to the three special taxes described above are 

distributed to those agencies for whose benefit the taxes are imposed, each of which 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 Authority to 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 for the 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 of aviation 

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 County will implement 

necessary changes to comply. 

It is our understanding that the FAA Amendment applies to the portion of state 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 if you disagree with our understanding of the applicability of the 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 of Sonoma