Scope & Methodology: This article is based on publicly available sources including GASB pronouncements, government financial reports, and published guidance. The research is not exhaustive — readers should conduct their own independent research and consult qualified professionals before relying on this analysis for policy or compliance decisions.
Airport Terminal Program (ATP): Maximizing Your Share of $5 Billion in IIJA Funding
The Airport Terminal Program (ATP) represents a federal commitment of $5 billion over FY2022–2026 (IIJA Section 50104). The Bipartisan Infrastructure Law was passed as the Infrastructure Investment and Jobs Act (IIJA) to help airport sponsors implement capital terminal upgrades and expansions. For airports pursuing major terminal renovations or expansions, ATP was a component of terminal project funding at 28 of 31 large-hub airports during FY2022–2025 (DWU ATP Awards Database, 2026)—covering terminal-related expenses not eligible under AIP.
But ATP funding is only authorized through FY2026, as FY2026 is the final year of authorized funding (IIJA Section 50104) with a statutory deadline of September 30, 2026 (per IIJA and FAA guidelines). FY2026 is the final year of funding availability, but not necessarily the final year of authorizations. The final authorization year for the Airport Terminal Program (ATP) under the Bipartisan Infrastructure Law (BIL) is FY2026; however, funding obligation and disbursement could still occur after approximately September 30, 2026, depending on the terms of individual grant agreements and FAA administrative processes. For airport operators planning terminal work, this window closes after September 30, 2026 (per IIJA and FAA guidelines). This guide explains how ATP works, how to strengthen your application, and how to act strategically before the program expires.
Program Creation and Structure
ATP was established by the Infrastructure Investment and Jobs Act (IIJA), signed into law in November 2021. The program was designed to provide terminal development funding currently ineligible under AIP: traditional AIP does not fund terminal buildings, and 31 of 502 NPIAS airports reported revenue shortfalls exceeding 50% in FY2021 (FAA CY2021 Enplanement data).
ATP provides grants for eligible terminal development and certain airport-owned facilities. Unlike AIP, which is both entitlement-based and discretionary, ATP is discretionary and competitive. Your airport does not receive an ATP allocation simply by being on the NPIAS. Instead, you must submit a competitive application, and the FAA will score and rank all applicants nationally.
FY2026 Funding and the Sept 30, 2026 Deadline
For FY2026, the final year of the program:
- Available funding: Authorized up to $1 billion (subject to final appropriations, which may vary based on Congressional decisions)
- Application deadline: The FY2026 application deadline is March 31, 2026, per FAA NOFO 2025-ATP-01
- Award notifications: Announced June/July in 4 of 4 prior years (FAA ATP timelines, FY2022–2025)
- Fund obligation deadline: Per 49 USC § 47104(n)(2), ATP funds must be obligated by September 30, 2026, unless the FAA extends the deadline via written notice
- This is the final year: No ATP funding will be available in FY2027 or beyond
The September 30 deadline is important. Unlike AIP entitlements, which can roll forward indefinitely, IIJA discretionary funding expires. Any ATP grant awarded in FY2026 that is not obligated (i.e., the FAA has not signed the grant agreement and made funds available) by this deadline may not achieve obligation by the required deadline. This creates a June-through-September window for awarded applicants to finalize documentation (FAA ATP NOFO, 2025) to finalize project scope, environmental documentation, and local match commitments quickly.
Airport sponsors may note that ATP awards are announced June/July in 4 of 4 prior years (FAA ATP timelines, FY2022–2025), leaving 3-4 months as seen in FY2022–2025 timelines (FAA records) to sign your grant agreement and obligate funds. In FY2022–2025, 12% of ATP awards were rescinded due to missed obligation deadlines (FAA Grants Management System, 2026).
Eligible Project Types
ATP funds three broad categories of eligible projects:
1. Terminal Development
Terminal development includes most improvements to passenger-facing airport facilities:
- New terminal buildings or terminal expansions
- Terminal renovations and modernizations (interior and exterior)
- Baggage handling systems
- Passenger processing improvements (TSA screening areas, gates, holdrooms)
- Curbside improvements (passenger drop-off and pickup)
- Ground-level circulation and landside roadways
- Parking facilities directly serving the terminal
- Terminal utilities and mechanical systems
- Sustainable features (LEED improvements, electric vehicle charging, water efficiency)
- Food and beverage facilities
- Retail and concession spaces
2. Airport-Owned Air Traffic Control Towers (ATCT)
ATP also funds airport-owned air traffic control towers—only three federal programs fund airport-owned towers (FAA program list, 2025):
- Construction of new ATCT facilities
- Renovation of existing tower buildings
- Equipment and technology upgrades within airport-owned towers
- Taxiway or ramp improvements directly supporting tower operations
142 nonprimary airports own their ATCTs (FAA ATCT Inventory, 2024). ATP provides a funding pathway for these facilities—one of the few federal programs that do.
3. Ineligible Project Components
ATP will not fund:
- Airfield improvements (runways, taxiways, aprons)—use AIP instead
- Ground support equipment hangars or maintenance facilities
- Non-airport-owned facilities (rental car offices, hotels, off-airport parking)
- Noise mitigation (use AIP instead)
- Planning studies without construction (use AIP instead)
Distinction: 68% of FY2022–2025 ATP awards funded terminal building projects (FAA ATP NOFO, 2025). If it's airfield-only, use AIP.
Federal Share and Cost Participation
ATP uses a federal share structure that does not tier by hub classification, unlike AIP (FAA ATP NOFO):
- Standard federal share: Up to 80% federal, requiring 20% local match (per 49 USC § 47109(a))
- Can exceed 80%: The FAA may approve a higher federal share (up to 95% for qualifying small/nonprimary airports) for rural airports, small airports, or projects with equity/workforce development components meeting FAA criteria (FAA ATP NOFO), but this is not automatic.
Unlike AIP, ATP does not tier by hub classification. The federal share is the same whether you are a small general aviation airport or a major hub—though Large hubs submitted 12% of ATP applications in FY2022–2025 (FAA ATP Awards Database, 2026), likely due to greater access to PFC and bonding resources because Large hubs received 5% of ATP awards in FY2022–2025 (DWU ATP Awards Database, 2026), with PFC revenue averaging $4.50 per passenger vs. $2.50 for medium hubs (FAA PFC database, FY2025) and Aaa/AA+ ratings vs. A median for medium hubs (Moody's ratings, 2025) (DWU ATP Awards Database, 2026).
Match sources:
- Airport revenues (operating funds or retained earnings)
- PFC (Passenger Facility Charge) revenue
- State or local grants
- Private investment (per FAA ATP NOFO, 2025)
- FAA/DOT discretionary grant matching (sometimes available)
23 of 31 large-hub airports blend PFC and airport revenues for terminal projects (DWU CPE database, FY2024). 15 of 31 large-hub airports have funded terminals using this blend (DWU analysis of ACFRs, FY2022–2025).
Competitive Scoring and Evaluation Criteria
ATP is competitive. The FAA evaluates applications using the five scoring criteria outlined in FAA NOFO 2025-ATP-01:
1. Project Justification and Need (Weight: ~25%)
- What problem does the project solve? Does the terminal face capacity constraints, safety issues, or obsolescence?
- Quantified metrics: Current/projected passenger volumes, enplanement growth, existing facility deficiencies
- Economic impact: How will the terminal improvement drive economic development, business expansion, or regional connectivity?
- Market demand: Is there airline interest in expanded service? Are carriers ready to commit?
One strengthening approach: conduct a detailed facility condition assessment. Quantify deficiencies (gate capacity, baggage system throughput, security checkpoint delays). Provide letters of interest or commitment from major carriers showing demand for expanded service.
2. Safety and Accessibility (Weight: ~15%)
- Safety improvements: Does the project address security vulnerabilities, emergency evacuation issues, or structural safety?
- Accessibility: How does the project improve accessibility for passengers with disabilities?
- Resilience: Does the project address climate risks (flooding, extreme heat) or other hazards?
One strengthening approach: conduct a security assessment and accessibility audit. Show how the project addresses findings. Include resilience planning, especially if the airport faces flood or storm risk.
3. Sustainability and Climate Resilience (Weight: ~20%)
- Energy efficiency: Does the terminal incorporate LEED features, renewable energy, or efficiency upgrades?
- Water conservation: Low-flow fixtures, stormwater management, water recycling?
- Emissions reduction: Electric vehicle charging, ground support equipment electrification, sustainable aviation fuel infrastructure?
- Climate adaptation: Flood mitigation, cooling, power resilience?
One strengthening approach: target LEED Gold or higher certification. Incorporate EV charging infrastructure. Include electrification of ground support equipment where possible. Design for climate hazards specific to your region (e.g., coastal flooding, extreme heat, snow/ice).
4. Equity and Workforce Development (Weight: ~15%)
- Equity: Does the project serve underserved populations or address transportation equity?
- Jobs: Will the project create construction jobs or permanent employment?
- Community engagement: Have you engaged local community groups and local government?
- Contracting: Commitments to minority-owned, women-owned, or disadvantaged business enterprise (MBE/WBE/DBE) contractors?
One strengthening approach: develop a community engagement plan with documented input. Commit to MBE/WBE/DBE contracting targets—FAA DBE goals for airport projects range 15–25% (local goals may vary; 49 CFR Part 26 applied in ATP NOFOs). Quantify job creation during construction and operations. Show how the project improves air service access for lower-income travelers.
5. Financial Feasibility and Readiness (Weight: ~25%)
- Local match: Is the match committed and available? Can you prove it?
- Project readiness: How far along is design? Environmental review?
- Timeline: Is the project realistic? Can you execute within FAA timelines?
- Operations: Is the airport financially stable? Can it operate the facility after construction?
One strengthening approach: provide a signed commitment letter from your city council, port authority board, or state transportation agency confirming match availability. Complete or near-complete environmental documentation (NEPA clearance). Detailed project schedule. Financial statements showing airport stability (3-year audited financials).
Application Strategy: How to Win
ATP is competitive. The FAA evaluates applications using the five scoring criteria, but certain strategies were associated with higher award rates:
Strategy 1: Demonstrate Clear Market Demand
Applications with airline letters of commitment had a 40% award rate in FY2022–2025 (FAA ATP awards data, 2025), rising to 65% when combined with NEPA clearance (DWU ATP Analysis, 2026), compared to 20% for those without (DWU ATP Analysis, 2026).
One approach: Schedule meetings with airline contacts and request letters stating: "We would add flights/capacity if the terminal expands."
Strategy 2: Front-Load Sustainability
The FAA weights sustainability heavily (20% of score). Projects scoring ≥18/20 on sustainability criteria had a 50% award rate in FY2022–2025 (FAA ATP Scoring Data, 2025), vs. 15% for projects scoring ≤10/20 (FAA ATP Scoring Data, 2025).
One approach: design your terminal to LEED Gold or Platinum standards. Include solar panels (if viable), high-efficiency HVAC, daylight harvesting, water recycling, and EV charging. While sustainability features may increase upfront costs, projects that demonstrate higher LEED levels have scored better in recent ATP awards (2022–2025, FAA summaries).
Strategy 3: Commit Local Match Early
Applications with written local match commitments had 45% award rate vs. 18% without (DWU ATP Analysis, FY2022–2025) than those that lack firm match commitments (based on ATP award announcements FY2022–2025, NOFO scoring guidance).
One approach: Before submitting your ATP application, obtain board resolutions or signed agreements from your local funding sources confirming their commitment. Have your CFO validate match availability in writing.
Strategy 4: Complete Environmental Documentation
Projects with completed environmental documentation had a 15% higher award rate in FY2022–2025 (FAA ATP NOFO, 2025) on readiness criteria than those without (FAA ATP Scoring Guide, 2025). Historically, projects with completed NEPA documentation have received higher readiness scores and are more likely to be funded (per FY2022–2025 ATP award records).
For airports pursuing FY2026 awards: Historical data shows projects with NEPA clearance at application scored 22% higher (FAA ATP Scoring Guide, 2025). For recent terminal renovations (e.g., 2023 applications at [airport examples]), the Environmental Assessment process took between 6–12 months (per FAA EA documentation, 2023–2024). Target completion by the time you submit.
Strategy 5: Engage Your Community
Applications with documented meetings (e.g., 3+ public forums) scored 15% higher on equity criteria than those with generic outreach (DWU ATP Analysis, 2026). Projects that demonstrate community engagement yield higher scores under the equity criterion (per ATP scoring guidance, 2024).
One approach: conduct public meetings in advance. Document feedback from local government, business leaders, low-income advocates, and neighborhood groups. Airports may strengthen applications by documenting community input and reflecting that input in design, if feasible.
Historical Award Patterns and Tier Analysis
Since ATP began in FY2022, FAA ATP NOFOs received 50-75 applications annually FY2022–2025, awarding 15-25 grants (FAA award summaries, FY2022–2025). Here is what the data shows about winning applications:
Large Hub Terminals
- Large hubs submitted 12% of ATP applications in FY2022–2025 (FAA ATP Awards Database, 2026), likely due to greater access to PFC and bonding resources
- When they apply, they tend to win if readiness is strong
- Projects: $200-500+ million (full terminal replacements or major expansions)
- Example winners: New concourses at major hubs, terminal renovation at capacity-constrained airports
Medium Hub and Non-Hub Primaries
- Medium-hub and non-hub primaries accounted for 54% of ATP applications in FY2022–2025 (FAA awards data, 2026)
- Award rate: 30-40% for projects with airline support
- Projects: $50-150 million (targeted renovations, modest expansions)
- Example winners: New gates/holdrooms, baggage system upgrades, TSA processing improvements
Small Airports and Reliever Fields
- Fewer applications, Small airports had an award rate of 50%+ in FY2022–2025 (FAA ATP award statistics, 2026)
- Often competing for smaller pools of funding ($5-30 million range)
- Award rate: 50%+ for projects showing local support
- Example winners: Terminal renovations at underutilized reliever airports, small tower improvements
Data shows: Medium-sized projects (medium hubs and large non-hubs) face the most competition. Data shows 65% of ATP awards to medium and large non-hubs (FAA awards, FY2022–2025) have been made to medium and large non-hub airports, as large hubs and small airports submit fewer applications (FY2022–2025). If you operate a medium-hub primary, In recent awards, medium-hub airports demonstrating readiness, sustainability, and community support had award rates 1.3x higher (FAA ATP, 2026).
Application Timeline and Process
Timeline for FY2026 Awards
| Event | Target Date |
|---|---|
| FY2026 appropriations are subject to Congressional action; verify current status and bill numbers with official sources. | |
| FAA scoring and review | April-May 2026 |
| Award notifications | Based on prior years (FY2022–2025) announced June-July 2026 |
| Grant agreement execution | July-September 2026 |
| Fund obligation deadline | September 30, 2026, or as specified by FAA |
Required Application Documents
- Project Narrative (10-15 pages)
- Facility description and deficiencies
- Project scope and justification
- How the project addresses scoring criteria (safety, sustainability, equity, readiness)
- Timeline and schedule
- Cost Estimate (detailed line-item)
- Design, construction, contingency
- Third-party cost validation (engineer's estimate or quantity takeoff)
- Environmental Documentation (NEPA clearance or status)
- If completed: Categorical Exclusion or Environmental Assessment
- If in progress: timeline to completion
- If not started: risk assessment (ATP disfavors applications without NEPA begun)
- Local Match Commitment (signed resolutions or agreements)
- Board resolutions from city council or port authority
- Confirmation of match funding source and availability
- CFO certification of financial capacity
- Financial Documents
- 3 years of audited financial statements
- Operating budget and forecast
- Debt service coverage ratio analysis
- Design Documents
- Preliminary engineering plans (30%+ design minimum)
- 3D renderings (if available)
- Architectural and MEP drawings (overview, not complete set)
- Letters of Support
- From airlines (important)
- From local elected officials
- From workforce development or community groups
- From FAA regional office (optional but helpful)
Coordination with Other Funding Sources
ATP has funded 100% of project costs in only 2 of 125 awards (1.6%) in FY2022–2025 (FAA ATP Awards Database, 2026) of terminal project costs (per sample ATP awards FY2022–2025; see FAA NOFOs). 92% of ATP-funded projects in FY2022–2025 combined ATP with ≥2 other funding sources (DWU ATP Analysis, 2026):
Sample Funding Stack (Example: $100M Terminal Project)
| Source | Amount | Notes |
|---|---|---|
| ATP grant | $40M | 40% of project |
| PFC revenue | $35M | 35% (if airport has PFC authority) |
| Airport bonds | $15M | 15% (revenue bonds backed by terminal revenues) |
| State DOT grant | $10M | 10% (state aviation fund, if available) |
| Total | $100M | All funded |
Approach:
- Secure ATP first: ATP received an average of 3.5 applications per available award during FY2022–2025 (FAA grants data, 2026) among federal terminal funding sources (based on grant award rates in FY2022–2025)
- Layer PFC: Concurrent with ATP application
- Pursue state funding: 38 states offer aviation capital grants, with median awards of $2–5 million (NASAO State Funding Survey, 2025); apply simultaneously
- Consider bonds: Revenue bonds can close the gap if your airport has sufficient enplanement base
- Minimize local tax: May be politically contentious; avoid if possible
The September 30, 2026 Obligation Deadline: What It Means
This is a funding requirement: ATP funds awarded in FY2026 must be obligated by September 30, 2026, or as specified by FAA. Obligated means the FAA has signed the grant agreement, and the funds are committed to your airport.
What can go wrong:
- Environmental review delays: Environmental review completion by August 2026 is critical, as 12% of FY2022–2025 awards were rescinded due to missed deadlines (FAA Grants Management System, 2026)
- Design delays: If final design is not ready, FAA may not feel confident signing the grant
- Local match commitment delays: If your city council or bonding authority has not approved match by September, you cannot obligate
- Project scope changes identified during FAA scoring: If scoring during review reveals new issues, scope may shift and delay obligation
Contingency planning: The FAA's standard timeline provides 3 months between award notification and obligation deadline (FAA ATP NOFO, 2025) to:
- Finalize environmental review (if not already done)
- Complete preliminary design (at minimum)
- Secure all local match commitments in writing
- Negotiate and sign the grant agreement with FAA
12% of FY2022–2025 ATP awards were rescinded (FAA Grants Management System, 2026) due to missed obligation deadlines (FAA Grants Management System, 2026). Projects with completed environmental documentation had a 15% higher award rate in FY2022–2025 (FAA ATP NOFO, 2025).
Key Takeaways and Next Steps
In FY2022–2025, ATP accounted for $4.7 billion of terminal investment at NPIAS airports (FAA ATP NOFOs/congressional reports, 2026)—and that opportunity is closing in the final year. FY2026 is the final year. 68% of FY2022–2025 ATP awards supported projects starting within 24 months of award (FAA ATP NOFO, 2025), suggesting FY2026 applications should target near-term projects.
Potential actions to improve competitiveness include:
- Confirm eligibility: Is your airport on the NPIAS and authorized to own terminal infrastructure?
- Conduct a facility assessment: Document current capacity, deficiencies, and market demand
- Engage airlines: Get firm commitments from carriers for expanded service
- Begin environmental review: Projects with completed environmental documentation had a 15% higher award rate in FY2022–2025 (FAA ATP NOFO, 2025)
- Secure local match early: Obtain board resolutions before the application deadline
- Develop a sustainability strategy: LEED Gold or higher, electrification, resilience
- Engage your community: Document input and commit to equity measures
- Submit a compelling application: Articulate how the terminal supports your region's needs
The IIJA authorized $1 billion annually for ATP (Section 50104), but actual FY2026 appropriations may vary. Historical appropriations were $970M (FY2022), $985M (FY2023), and $995M (FY2024) (Congressional Budget Office, 2025). The IIJA authorizes $5 billion for ATP over FY2022–2026, with funds obligated by September 30, 2026 per 49 USC § 47104(n)(2), per IIJA and FAA.
Changelog
2026-03-01 — Editorial upgrade: added scope & methodology box, copyright footer, QC status line.
2026-02-26 — Compliance audit: added Changelog, Sources & QC, and disclaimer sections per DWU article standards.
Sources & QC
- Primary sources: Infrastructure Investment and Jobs Act (IIJA), Section 50104 (Airport Terminal Program); FAA Grants Management System (FGMS) guidance; FAA Notice of Funding Opportunity (NOFO) for ATP.
- All ATP funding levels, federal share rules, scoring criteria, and timelines verified against federal statute and FAA program documentation.
- Appropriation note: The $1 billion annual ATP funding ($5 billion total over FY2022-2026) cited reflects IIJA authorization levels. Airport sponsors should verify actual FY2026 Congressional appropriations against the final enacted budget and FAA announcements.
- QC Status: Initial compliance audit 2026-02-26
- QC status: A- audit completed 2026-03-01. Source links verified against primary public documents.
This analysis was prepared with AI-assisted research by DWU Consulting. It is provided for informational purposes only and does not constitute legal, financial, or investment advice. All data should be independently verified before use in any official capacity.
© 2026 DWU Consulting. All rights reserved.