An avigation easement is a property right acquired from a landowner, which protects the use of airspace above a specified height and imposes limitations on the use of the land subject to the easement.

There is a two-fold purpose for an avigation easement: one is to preserve the right to remove obstructions and limit development on the ground to heights that do not cause an issue for safe landings and take-offs; the other is to protect the investment made in constructing the runway, by ensuring that the runway threshold does not have to be displaced, as vegetation grows, and development occurs. When public airports receive federal funds for improvement projects, the airport must agree to abide by FAA requirements, such as providing for safety for both pilots and people on the ground, including obtaining rights from adjacent properties when needed. In general, uses that interfere with pilot visibility and instrumentation, including manmade structures or natural growth that penetrate specified heights, must be removed. An avigation easement provides the rights to do so.

The current easement only includes a portion of the approach within the Matanuska River Park and fails to provide a safe approach to the runway. The need to provide a safe approach has already resulted in the threshold of Runway 16 being displaced 500 feet, shortening the available landing length. In 2016, an aeronautical survey was completed for the airport. The aeronautical survey included an airspace analysis of the terrain, vegetation, and manmade structures that surround the airport to determine whether there were any safety issues to air traffic. In some cases, objects identified in an airspace analysis can remain and approach procedures can be adjusted to reflect their presence. However, when objects are located near the runway ends and significantly impact the approach and departure from the runway, the conflicts have to be mitigated by removing the object or relocating the runway threshold. After the completion of the aeronautical survey, an Obstacle Action Plan was developed for all objects deemed to pose a hazard to air traffic at the Palmer Airport. The plan identified certain objects, such as Lazy Mountain, that can remain and other objects, such as trees, that need to be mitigated. Over the course of the past five years, the city has undertaken an effort to remove trees at each runway end. Few obstacles remain besides trees in the Matanuska River Park.

To answer this, we need to know the needs of the airport. Palmer Municipal Airport recently completed an aviation activity forecast to determine the “critical aircraft” in use at the Airport.  The critical aircraft is defined as the most demanding aircraft with 500 operations (take-offs or landings) or more annually.  The study identified the Convair 580, used by the Division of Forestry for aerial firefighting, as the critical aircraft.  Per FAA’s guidance, the Convair 580 requires 6,060 feet for safe take-off and landing procedure.  Therefore, the full 6,009 feet of Runway 16/34 is necessary and the threshold for Runway 16 should be relocated back to the runway end. 

Options for modifying the Airport to accommodate the Park could include shifting the runway to the south, relocating the Airport completely, or shortening the runway even further. These options were discussed during the planning phase of the project and will be further evaluated in the alternatives evaluation during the National Environmental Policy Act (NEPA) process for reasonableness and feasibility.

Whether a proposed project alternative is reasonable is depends on the extent to which it meets the purpose and need.

Feasibility is evaluated after a proposed project alternative has been determined reasonable. Feasibility is based on the following factors:

• Economic feasibility
• Ability to serve the community’s needs
• Safety, engineering, user considerations
• Environmental considerations

Shifting the runway south:

Moving the runway to avoid current and future airspace penetrations within the park would require shifting the runway 2,200 feet to the south.  This shift would include:

• Acquisition of additional land for the Airport
• Re-routing approximately 1-mile of Outer Springer Loop (owned by the State of Alaska Department of Transportation)
• Increases in traffic and airport noise for Borough residents to the south of the Airport
• Conversion of active farmland and portions of the golf course to airport use
• Acquisition and/or relocation of multiple residences

Relocating the airport completely:

Relocating an airport in modern times has significant challenges, not the least of which is finding a suitable and publicly acceptable location.  Although Wasilla’s airport was relocated in the 1990s, the Mat-Su has changed significantly since that happened, with very few, if any, suitable areas available that would not pose similar, although likely more significant, impacts than those identified above.

Shortening the runway:

Shortening the runway sufficiently to avoid current and future airspace penetrations and provide for aviation safety does not meet the need of the Airport and its users and could result in significant cost. 

The airport was developed by Palmer, with funding from FAA, to service a wide variety of aircraft, from small to large.  Although small aircraft make up the majority of operations and don’t require the full length of Runway 16, medium to large aircraft accounted for 20% of airport operations in 2019.  In fact, in 2017, the Large Aircraft Apron was doubled in size specifically to accommodate parking of large planes, and the planned Taxiway N project (construction anticipated in 2022) will be designed to accommodate large aircraft traffic and provide access to large, undeveloped lots in the southwest corner of the airport.  Larger aircraft commonly using the runway include the Douglas DC-3, Canadair CL215, Convair 580, Dehavilland DHC-8, and the Avro RJ85; a new operator on the airport expects to add the Douglas MD80 to this list.  Although pilots can choose to operate on shorter runways than the length necessary by FAA guidance, it is Palmer’s intent and duty to use the existing infrastructure to provide safe operating conditions for pilots and the public as much as practicable, not to shorten the runway and force pilots to make a choice about safety.

Shortening the runway would severely limit Palmer’s ability to attract large aircraft tenants, as well as higher-speed aircraft that require similar runway lengths.  These tenants provide tax revenue and jobs to Borough residents.  Shortening the runway would also likely cause some existing tenants to relocate.  One such tenant is the Division of Forestry, who employs 14 permanent full-time positions, 65 permanent seasonal positions, and roughly 60 temporary positions.  As there is no other suitable airport in the Mat-Su, Forestry’s aerial firefighting operations would need to relocate, likely to Kenai or Fairbanks, taking several jobs with them.  In addition, relocating the aerial firefighting base would increase response times for Mat-Su area wildfires, risking additional loss of life and property from catastrophic wildfire events like the recent McKinley and Sockeye Fires.  In fact, the current threshold on Runway 16, which was displaced in the 1980s to avoid conflicts with trees in the Park, already limits which air tankers Forestry uses, and has contributed to the decision of potential tenants to not locate commercial jet and other larger aircraft operations and their associated employment and other economic benefits to Palmer and the Mat-Su.

However, some private developments for higher-speed and larger aircraft have already started or are planned in the near future and include millions of dollars in investments.  If the runway were to be shortened now, many of these developments would stop at a significant cost of lost revenue to the Borough and Palmer and lost jobs to area residents, not to mention the investment losses to these private companies, as well as the loss of goodwill for the Borough and Palmer.

Furthermore, Palmer and the FAA have invested significant funds in constructing and maintaining a 100-foot-wide, 6,008-foot-long runway and its associated taxiways, including a $7.8M project in 2017 to repave this runway, expand the Large Aircraft Apron, and make other miscellaneous improvements.  Shortening the runway would cause the FAA to discontinue any funding for the unused portion of the runway and taxiways, and maintenance costs would fall solely on Palmer.  With fewer tenants and associated revenue, it is unlikely that Palmer would be able to maintain the paved surfaces, eventually rendering them useless and a hazard.  However, as a condition of the FAA funding, Palmer has agreed to maintain, operate, and make available for public use these FAA-funded improvements.  If Palmer were to not meet this requirement, FAA could demand repayment of the grant funds and withhold funding of any future projects.  

Though the airport is owned and operated by the City of Palmer, it is a facility that serves people throughout the Mat-Su.  Examples of the many regional operations that the airport supports include:

• Division of Forestry’s Mat-Su Area Office and regional aerial firefighting base  
• Everts Air Cargo maintenance operations (formerly Ravn)
• Flight schools
• Aircraft mechanics/aircraft parts and other small businesses that serve the aviation community
• Rendezvous point for fixed-wing and rotor-wing medical evacuations

Anything that happens at the airport also has an impact on the Borough’s tax base.  Not only is the land south of the airport primarily residential properties that contribute significant tax dollars to the Borough, but the Borough collects over $98,600 annually in property assessments from businesses on the airport.  With planned development of larger operations, this will only continue to increase.

The airport also provides an important element of the regional emergency response and recovery in a disaster scenario.  Following the November 2018 earthquake, the Anchorage and Merrill Field Air Traffic Control Towers were evacuated, and the airports closed.  The FAA’s Alaska Air Traffic Service contacted Palmer Airport as a potential divert location.  With no tower to be a safety concern, Palmer Airport was inspected and reopened almost immediately, with the capability of handling large aircraft including Boeing 737s and even the military’s C-17 Globemaster, if needed.  A shorter runway that accommodates the tall trees in the Park would not allow this important option. In fact, the displaced threshold already limits these large aircraft to which direction is safest to land.

This example shows the importance of the Airport as an emergency landing location; however, it also shows its potential role in recovery from a disaster that cuts off land-based travel between Anchorage and the Mat-Su.  With one or more of the Knik River bridges damaged, for example, emergency equipment and supplies can be airlifted to Palmer using large civilian or military aircraft, then trucked throughout the Mat-Su as needed.  There is no other airport north of Anchorage and south of Fairbanks that can support such an operation.  Shortening the runway to accommodate the tall trees in the Park, or even maintaining the displaced threshold, is not in the best interest of the residents of the Mat-Su for disaster response and recovery.

Palmer is NOT interested in clear-cutting the Park.  Palmer IS interested in partnering with the Borough to manage penetrations of the airspace while preserving the Park.  This will involve selectively removing trees that are so tall that they penetrate the airspace.  However, it does not mean that all of the trees in the Park need to be removed.

Yes. Because the Matanuska River Park is a publicly owned resource, it is protected under Section 4(f) of the Department of Transportation (DOT) Act of 1966.  Also, some elements of the Park were made possible through grant funds administered by the Land and Water Conservation Fund (LWCF) Grant Program; therefore, the Park is also protected by Section 6(f).  However, neither of these regulations categorically protect the Park from an additional easement or selective tree removal.  The laws do prevent the FAA from funding a project that results in a “conversion of use” without other mitigating actions to offset the impact.  In this case, an avigation easement that allows Palmer to maintain the airspace above the Park would be considered a conversion of use, from parkland to managed airspace, and the processes provided in Section 6(f) of the LWCF Act and Section 4(f) of the DOT Act will need to be followed.

Section 6(f) of the LWCF Act contains strong provisions to protect Federal investments and the quality of assisted resources.  The law is firm but flexible and allows for easements and other “conversions” through an evaluation and approval by the Alaska State Parks Grant Administrator.  The Borough and Palmer can work together in consultation with the state grants administrator regarding the conversion of use request, mitigation measures, and conversion requirements.  Once the Borough and Palmer determine acceptable mitigation options, an impact evaluation and an alternative evaluation by the Department of the Interior National Park Service (NPS) can be completed.  After the Borough concurs with the easement and mitigation measures, written consent of Alaska State Parks can be obtained, and NPS approval of the land conversion/transfer can take place.

Section 4(f) provides for consideration of park and recreation lands, wildlife and waterfowl refuges, and historic sites during transportation project development.  The law, now codified in 49 U.S.C. §303 and 23 U.S.C. §138, applies only to the U.S. DOT, and Section 4(f) applies to projects that receive funding from or require approval by an agency of the U.S. DOT, such as the FAA.  The analysis and consultation process to assess impacts to a publicly owned park are similar to those outlined under Section 6(f), except that the FAA would develop an impact evaluation assessing the overall conversion of use.  The Borough, Palmer, and FAA would meet to outline mitigation options to offset impacts to the Park as a result of the avigation easement. FAA would finalize the commitment to mitigate the impacts through an FAA Section 4(f) impact finding.  

The FAA provides federal funding to airports such as Palmer, who serve a vital role in the nation's system of integrated airports.  Palmer is able to apply for a grant to fund the acquisition of an avigation easement and necessary mitigation for impacts to the Park in association with the easement. Funding under the current Airport Improvement Program would pay for 93.75% of the overall project cost; Palmer would be responsible for providing 6.25% in matching funds to complete this project. 

Tree heights were measured in 2015. At that time, the number of trees that needed to be removed was approximately 106.  The City of Palmer is currently in the process of completing a photogrammetric survey of the trees in the Matanuska River Park to evaluate the current height of the trees that currently penetrate the airspace. 

Yes.  In fact, Palmer would be required to mitigate impacts to the Park.  The Borough’s Matanuska River Park Master Plan, adopted in 2014, identifies the overall vision for the Park and what needs exist in order to make that vision happen.  The Master Plan states that the Borough wishes to “work with the City of Palmer to minimize park impacts from future airport expansion while supporting air transportation safety.”  Although no airport expansion is proposed, this easement and necessary mitigation presents an opportunity for the Borough to demonstrate the spirit of cooperation envisioned by this goal.  Furthermore, the project is an opportunity for the Borough to enhance the park user’s safety by cooperating with the airport and to enhance the park user’s experience by completing mitigation.

Projects identified in the Master Plan that could be considered in the mitigation include but are not limited to:

• Extension and enhancement of the Riverfront Trail.
• Development of a riverfront attraction to potentially include a large waterfront pavilion for public events/rental, a recreation facility with decks and a rooftop view area, a nature center with rental cabins, a kayak or boat launch, and/or other options that take full advantage of the site views and attracts residents and visitors.
• Preserving the old-growth forest area in the north and eastern portions of the Park, including proactively addressing runoff, drainage, and erosion; rationalizing the existing network of trails into a sustainable, low impact single track trail network; and supplementing the low impact trails with a main Forest Loop Trail configured as a “figure eight” with access spurs to support intensive year-round use.
• Constructing river access and interpretive signs that engage residents in appreciating Palmer’s historical river connections, including the Dena’ina and Ahtna trade route between the interior and saltwater, and George Palmer’s trading post across the river.
• Enhancing connectivity between the lower and upper camping levels with trail and stairs.
• Constructing a winter trailhead.
• Constructing additional trails, including ADA accessible pathway.

This list isn’t intended to restrict the Borough’s proposals for mitigation, and other projects could be considered.  However, any mitigation will need to be agreed upon by the FAA for funding, and by the FAA and NPS as appropriate to offset the “conversion of use” impacts.