Like much of the transportation industry during the COVID-19 pandemic, America’s airports are experiencing significant losses in revenue. Airports Council International predicts that the U.S. airport industry will lose $23 billion as a result of COVID-19. Title XII of Division B of the Coronavirus Aid, Relief, and Economic Security, or CARES, Act addresses these significant economic disruptions by providing approximately $10 billion to U.S. airports “to prevent, prepare for, and respond to the impacts of the COVID-19 public health emergency.” The funding is somewhat discretionary, with a requirement that it be used for any purpose for which airport revenues may lawfully be used, so long as the use of funds is related to the airport,
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