FAA
04 November 2025

This memorandum serves to revise guidance on the application of the Limited Federal Financial Assistance Categorical Exclusion established by Section 788(a) of the 2024 FAA Reauthorization Act (Pub. L. No. 118-63). 

On December 19, 2024, APP-420 issued the guidance memorandum entitled “Initial Instructions to Office of Airports Environmental Protection Specialists on Implementation of Section 788(a) of the 2024 FAA Reauthorization Act.” The Office of Airports has received feedback from Office of Airports Environmental Specialists, airport sponsors, and the industry regarding the utility of those instructions. That feedback demonstrated that revisions in some key aspects of this guidance would be advisable. APP-420 is now updating the memorandum to address the input received and to align this guidance with current administration priorities regarding improving the efficiency of the environmental review process.

APP-420 therefore revises its implementing guidance to indicate that section788(a) of the FAA Reauthorization Act of 2024 can be applied to all projects involving funding requests below the defined financial thresholds, including those that receive no Federal investment, provided extraordinary circumstances are not present.

The instructions contained in the December 19, 2024, Memorandum are rescinded and replaced with this Memorandum.

Not a member?
Take a look at our member benefits