Airport Master Plan – Chapters 3 & 4 Updates

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1. I am writing to express serious concerns regarding the Airport Master Expansion Plan and its compliance with federal and state environmental laws, land use regulations, and public transparency requirements. The following questions demand a response in writing to ensure full transparency.

   Accountability and Data Integrity

   Why is the Airport Master Expansion Plan deliberately ignoring FAA Terminal Area Forecast (TAF) projections and instead relying on biased stakeholder data, contrary to FAA planning standards?
   What specific actions were taken to eliminate stakeholder bias, or was bias simply allowed to dictate the forecast?
   Why does MRRA admonish the public for calling it the Airport Master Expansion Plan when MRRA itself uses the term “EXPANSION” in its own materials referencing the Air Traffic Control School? Is MRRA attempting to mislead the public?
   Why does MRRA cherry-pick BasedAircraft.com data while ignoring FAA TAF projections, both of which are FAA sources?
   What proof does MRRA have that the 2022–2023 spike in based aircraft is sustainable and not a one-time anomaly? Or is this inflated data to justify expansion?
   How does MRRA expect FAA to accept projections that blatantly contradict TAF data?
   Where is the FAA documentation or correspondence authorizing MRRA to override TAF data? Or is MRRA acting without FAA approval?
   How often is aircraft data updated, and does MRRA admit it fails to account for temporary or seasonal fluctuations?
   Why do MRRA’s aircraft counts diverge so drastically from FAA estimates? Is MRRA manipulating numbers?
   Has MRRA hired any independent third party to validate its aircraft data, or is MRRA avoiding accountability?
   How will MRRA reconcile its questionable data with FAA funding and compliance requirements under https://www.law.cornell.edu/uscode/text/49/47107?

   Environmental and Public Health Risks (NEPA & CERCLA Compliance)

   Why is MRRA still using a 2010 Environmental Impact Study, which is invalid under https://www.law.cornell.edu/uscode/text/42/4332 after multiple PFAS disasters, including the catastrophic 8/19/2024 spill? Where is the updated NEPA-compliant Environmental Assessment or EIS?
   What environmental studies—if any—have been conducted since the PFAS disaster to assess risks from construction and groundwater disturbance, as required under https://www.law.cornell.edu/uscode/text/42/chapter-103 and Maine DEP regulations? Or is MRRA ignoring these obligations?
   How can MRRA claim the Expansion Plan is separate from environmental issues when construction will disturb toxic PFAS contamination on a CERCLA Superfund site?
   Why does the Expansion Plan fail to address coordination with NEPA, MDEP, and EPA for compliance and long-term monitoring of contamination, as required under CERCLA and RCRA?
   What safeguards—if any—exist to prevent construction from spreading PFAS contamination into groundwater and the environment, as mandated by https://www.epa.gov/pfas/pfas-strategic-roadmap? Or is MRRA gambling with public health?
   Has MRRA conducted a health risk assessment for nearby populations, as required under NEPA and CERCLA, or is MRRA disregarding human health entirely?
   When asked on 10/23/25 about testing soil and debris for PFAS, MRRA had no answer. What is MRRA’s answer now, and who will conduct and publish the results under EPA and Maine DEP oversight?

   Economic and Operational Justification

   Why is MRRA planning infrastructure for Advanced Air Mobility and electric aircraft when no such operations exist? Is this a misuse of public funds under FAA grant assurances?
   Why does MRRA claim economic benefits without any economic impact study? If one exists, why is it being withheld from the public? If not, why is MRRA making baseless claims in violation of FAA policy on benefit-cost analysis?
   What evidence supports MRRA’s assumption that cargo and commercial operations will increase, given zero current activity?
   Has MRRA conducted a market analysis for projected growth in maintenance and cargo services, or is this pure speculation?

   Transparency and Public Engagement (Land Use & Transfer Regulations)

   Why were Chapters 3–4 of the Plan withheld until after the 10/23/25 meeting, denying the public meaningful input, contrary to NEPA’s public participation requirements (https://www.ecfr.gov/current/title-40/chapter-V/part-1506/section-1506.6)? Will MRRA schedule a make-up meeting, or is transparency not a priority?

   Why is MRRA silencing public discussion on PFAS contamination despite documented drinking water contamination and ongoing Superfund investigations under CERCLA OU-13?

   What engineering assessments have been done to prevent damage to underground utilities and worsening contamination during construction, as required under FAA land use compatibility guidelines and CERCLA remedial action standards?

   How will MRRA guarantee expansion activities do not compromise water infrastructure on a CERCLA Superfund site?

   Is there a plan to upgrade stormwater systems to prevent runoff from new impervious surfaces entering sensitive areas, as required under https://www.law.cornell.edu/uscode/text/33/1251 and Maine stormwater regulations?

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