For any airport, preparing for a 14 CFR Part 139 inspection can be a sizable undertaking. From record-keeping to the physical facility, the breadth of topics under review requires the coordination of a wide variety of stakeholders to ensure compliance.
 Mike Nakornkhet ascended to the position of airport director at San Francisco International early last year. His 25+ years in the industry include more than two as chief financial officer and executive vice president of Denver International Airport, and 13 years in various roles of SFO’s Finance Department prior to that. |
At San Francisco International Airport (SFO), third-party industry experts have played an important role in evaluating the airport’s performance under various FAA Part 139 regulatory requirements. Their independent assessments of our airfield markings have provided valuable insight into both strengths and opportunities, drawing from the best aviation practices as well as relevant lessons learned in other sectors. Their findings have helped airport leadership make informed strategic decisions about strengthening and modernizing compliance capabilities.
The Limitations of Traditional Procurement
While these third-party services have delivered significant value, obtaining them through traditional procurement channels has been challenging. The city and county of San Francisco’s competitive procurement process involves multiple layers of review to ensure fairness and transparency. Even when prioritized, contracts have historically required approximately nine months to advance from initial concept to execution. When an airport identifies a pressing need to ensure its compliance with FAA Part 139 regulatory requirements, nine months can be too long for meaningful resolution.
The possible solution emerged while our Safety, Health and Compliance team was managing one of these projects. At SFO, we commonly use as-needed contracts to secure specialized services when specific needs arise. This prompted the airport to consider whether a similar approach could be applied to the broad and diverse set of technical and operational requirements under the FAA Part 139.
The concept was straightforward—competitively procure a comprehensive and highly technical contract in advance, then activate specific services through individual work orders. Rather than initiating a new solicitation each time a need arises, the airport would have a contracting vehicle ready for immediate use. Work orders could potentially be executed in a fraction of the time and with significantly fewer administrative resources than traditional standalone contracts.
Designing and Validating the Solution
Turning this concept into reality, however, required innovation and thoughtful design. No single contractor possesses all the specialized expertise and equipment needed to support the full range of FAA’s Part 139 requirements. To address this, SFO structured the solicitation so that a prime contractor could assemble a multidisciplinary team of qualified subcontractors.
Because the idea appeared to be new within the industry, SFO contacted peer airports and service providers to determine whether similar contracts existed. Stakeholders expressed strong interest, but no directly comparable examples were identified.
To validate the market capability, SFO issued a Request for Information (RFI) to more than 100 firms providing relevant services. Responses confirmed that firms did not have direct experience with this contracting structure, but qualified firms could be assembled to fulfill the intent and technical scope. This feedback supported the feasibility of the model and helped develop a clear and practical Request for Proposals (RFP).
Working with the airport administrative and legal staff, SFO developed an RFP that defines minimum qualifications for the prime contractor and required demonstrated capabilities across eight Part 139 subject areas, through internal staff or subcontractors.
Two proposals were received. A panel composed of representatives from SFO, the San Francisco Public Utilities Commission and San Jose Mineta International Airport (SJC) conducted a structured and scored evaluation and interviewed both proposers. Following selection and negotiations, SFO executed the contract with Jacobs Engineering Group Inc. in August 2026.
From Procurement to Implementation
We are currently in the process of issuing the contract’s first work orders, beginning with major initiatives including a comprehensive update of the Airport Certification Manual and development of an Airfield Asset Management Program. These projects will strengthen how the airport allocates resources and prioritizes maintenance needs.
Peer airports contributed valuable ideas and support during development. To extend these benefits industry-wide, SFO included cooperative procurement, or “piggyback” language, allowing eligible organizations to use this contracting vehicle for their own needs.
The effort to bring this contract from concept to reality required a collective effort from many internal and external stakeholders. We hope that this new model will offer airports a practical tool to meet emerging challenges and deliver the safest possible facilities for the traveling public.
Mike Nakornkhet ascended to the position of airport director at San Francisco International early last year. His 25+ years in the industry include more than two as chief financial officer and executive vice president of Denver International Airport, and 13 years in various roles of SFO’s Finance Department prior to that.
