AIRPORT LAYOUT PLAN (ALP) NARRATIVE REPORT

AIRPORT LAYOUT PLAN (ALP)

NARRATIVE REPORT

WORKING PAPER #4: BKL CLOSURE

ALTERNATIVE

Burke Lakefront Airport

Cleveland Ohio

October 2022

November 2022 – Revision 1

March 2024 – Revision 2

Prepared for:

City of Cleveland

Department of Port Control

Cleveland, Ohio

Prepared by:

CHA Consulting, Inc.

Jacobsen/Daniels, Inc.

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE i

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

TABLE OF CONTENTS

EXECUTIVE SUMMARY ......................................................................................................................... 1

1.0 BKL CLOSURE ALTERNATIVE EVALUATION ........................................................................... 4

1.1 BKL’S ROLE IN THE AVIATION SYSTEM ...................................................................... 4

1.1.1 Confined Disposal Facilities ............................................................................... 5

1.2 REVIEW OF PAST AIRPORT CLOSURES..................................................................... 5

1.2.1 Richards-Gebaur Memorial Airport, Kansas City, MO ......................................... 6

1.2.2 Merrill C. Meigs Field Airport, Chicago, IL ........................................................... 6

1.2.3 Cincinnati–Blue Ash Airport, Cincinnati, OH ....................................................... 7

1.2.4 St. Clair Regional Airport – Kansas City, MO ...................................................... 8

1.2.5 Kent State University Airport – Stow, OH ............................................................ 8

1.2.6 East Hampton Airport – East Hampton, NY ........................................................ 8

1.3 STAKEHOLDER INTERVIEWS ...................................................................................... 9

1.4 SURPLUS AIRPORT CAPACITY EVALUATION .......................................................... 12

1.4.1 Geographic Location of Users .......................................................................... 12

1.4.2 Alternative Airport Capacity Analysis ................................................................ 13

1.5 GRANT HISTORY AND LEASE REVIEW ..................................................................... 21

1.5.1 Grant History and Federal Obligations .............................................................. 21

1.5.2 State Grant History and Obligations ................................................................. 24

1.5.3 Lease Review .................................................................................................. 25

1.6 AIRPORT CLOSURE OPTIONS ................................................................................... 25

1.6.1 Option 1 – Wait Out Grant Obligations.............................................................. 26

1.6.2 Option 2 – Apply to FAA for Closure ................................................................. 27

1.6.3 Option 3 – Federal Legislation .......................................................................... 28

1.7 FINANCIAL ANALYSIS ................................................................................................ 29

1.7.1 BKL Economic Impact ...................................................................................... 29

1.7.2 Financial Performance ..................................................................................... 30

1.7.2.1 Overall Financial Performance .......................................................... 30

1.7.2.2 Revenue Generation ......................................................................... 31

1.7.2.3 Airport General Operating Expenses ................................................. 32

1.7.2.4 Debt Service ..................................................................................... 33

1.7.3 Airport Leases .................................................................................................. 33

1.7.3.1 City as a Lessee ............................................................................... 33

1.7.3.2 City as a Lessor ................................................................................ 34

1.7.3.3 Terminal Office Space Leases .......................................................... 35

1.7.4 Financial Impacts of Closing BKL ..................................................................... 36

1.7.5 Financial Summary .......................................................................................... 37

1.8 CONCLUSIONS ........................................................................................................... 38

1.8.1 Advantages to Closing BKL .............................................................................. 38

1.8.1.1 Allows the Port Authority and USACE to operate autonomously without

FAA oversight................................................................................... 38

1.8.1.2 Allows the City of Cleveland to develop portions of BKL into an

alternate land use ............................................................................. 40

1.8.1.3 Removal of BKL Operating Losses ................................................... 40

1.8.2 Disadvantages to Closing BKL ......................................................................... 40

1.8.2.1 Economic Impact of Closing .............................................................. 40

1.8.2.2 Reimbursements to FAA & ODOT..................................................... 41

1.8.2.3 Ongoing Maintenance Responsibility ................................................ 41

1.8.2.5 Costs to Demolish Airport Facilities ................................................... 41

TRADE SECRET

ATTY WORK PROD

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE ii

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

LIST OF TABLES

Table 1-1. Airfield Capacity Summary ............................................................................................ 15

Table 1-2. Runway Capability Summary Table .............................................................................. 16

Table 1-3. Relocation of Based Aircraft/Itinerant Users .................................................................. 19

Table 1-4. Federal Grant History and Grant Assurance Expiration ................................................. 21

Table 1-5. Outstanding Federal Unamortized Grant Obligations .................................................... 24

Table 1-6. ODOT Grant History and Assurance Expiration............................................................. 25

Table 1-7. Wait Out Grant Obligations – Opportunities and Constraints ......................................... 27

Table 1-8. Apply to FAA for Closure – Opportunities and Constraints............................................. 28

Table 1-9. Federal Legislation – Opportunities and Constraints ..................................................... 29

Table 1-10. BKL Revenues and Expenses ...................................................................................... 30

Table 1-11. BKL Submerged Land Leases ...................................................................................... 33

Table 1-12. 2018 Extracted Rent Roll .............................................................................................. 35

Table 1-13. Opportunities and Constraints Associated with Closing BKL ......................................... 37

LIST OF FIGURES

Figure 1-1. Existing Confined Disposal Facilities ............................................................................... 5

Figure 1-2. Airport Revenues .......................................................................................................... 32

LIST OF ATTACHMENTS

REPORT REVISIONS

Revision 1 (November 2022)

 Added an Executive Summary

Revision 2 (March 2024)

 Updated Opinion of Probable Construction Costs to Demolish BKL and added Attachment C

 Updated Unamortized Grant Obligations

TRADE SECRET

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 1

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

EXECUTIVE SUMMARY

This airport closure alternative study supplements the Airport Layout Plan (ALP) narrative report

by evaluating the Federal Aviation Administration (FAA) requirements to close Burke Lakefront

Airport (BKL). The goal of this analysis is not to provide a recommendation on whether the City

of Cleveland (Airport Sponsor) should or should not close the airport but rather an overview of the

requirements, potential financial or legal implications, and its effect on its stakeholders. Closing

of a public-use federally obligated airport is possible, but the process is complicated as the City

has accepted federal funds to develop the airport and keep it operating safely. If the City of

Cleveland decides to close BKL, one of the following three (3) options may be selected as the

preferred method of closing:

 Option 1: Wait Out Grant Obligations: Under this option, the city would defer closure

until the federal grant obligations expire in 2036 and ODOT, Office of Aviation assurances

in 2039. At that point, the city would provide a 30-day closure notice to FAA. After grant

obligations have expired, only a FAA notice to close is required and not “approval”. An

airport must remain open perpetually and still needs FAA release approval if it has

accepted federal grants for land acquisition. However, a review of the grant history

indicates no federal grants were used for the purposes of fee-simple acquisition of real

property and no surplus property was granted for airport use. The challenges to this option

are the city would have to maintain the airport without federal money through 2036.

 Option 2: Apply to FAA to close BKL now: According to FAA Order 5190.6B, Section

22.20, an airport sponsor may request the release of obligations for an entire airport;

however, the FAA Associate Administrator for Airports (ARP-1) concurrence is required

before granting any release that would enable the disposal of an entire airport for non-

aviation purposes. In addition, each request to release an entire airport is considered by

ARP-1 on a case-by-case basis and at the complete discretion of ARP-1. Some of the

constraints to applying now for closure is proving to the FAA there is a net benefit to

aviation by closing BKL. The City would be required to pay unamortized amounts of

outstanding federal grant obligations over $7.9M and state grants in the amount of $1.5M.

 Option 3: Federal Legislation: Pursuing federal legislation through the U.S. Congress

can be a means to bypass FAA requirements to close an airport. Working with the

legislative branch of the government, legislation can be passed directing the FAA to close

the Airport. Although this may seem like the quickest route to close an airport, it does

require substantial lobbying to elected representatives, the legislation would have to be

introduced and selected for a vote, and lastly, it would need to pass.

Several advantages and disadvantages are presented in Section 1.8 of the report and are

summarized below:

TRADE SECRET

ATTY WORK PROD

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 2

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

Advantages of Closing BKL

1. Allows the Port Authority to operate the Confined Disposal Facility (CDF)

Autonomously: According to the Cleveland-Cuyahoga County Port Authority (Port

Authority), the long-term operation of the CDFs within the BKL airport property limits is

unsustainable, specifically with the US Army Corp of Engineers (USACE) wanting to

establish a multi-year agreement with the Port to accept dredged material from the

Cuyahoga River and harbor. A BKL closure would allow the Port Authority and USACE to

operate the CDFs without FAA oversight and would allow both entities to expand their

CDFs, which are currently limited to airport airspace and land use restrictions.

2. Allows City to develop portions of BKL into alternate land use: Closing the airport

would provide the city an opportunity to expand the ongoing lakefront development in non-

CDF areas. For years, proponents for closing BKL have called for the re-development of

the Airport into recreation areas (parks), housing, and/or commercial mixed-use

development. Any new development would have to consider the ongoing dredge,

sediment, and processing facilities of the CDF that would be adjacent to any new

development. Any future development would be costly, given that BKL is built on

submerged lands constructed by dredged material and solid waste.

3. Removal of BKL operating loss: According to financial data provided by the city, BKL

records an average annual loss of approximately $900,000. These net losses at BKL are

included as an expense line item in the calculation for the commercial airline rates and

charges currently operating at CLE. Removing the $900,000 BKL operating loss from

those calculations could lower the cost per enplaned passenger at CLE.

Disadvantages to Closing BKL

1. Reimbursements to FAA & ODOT: If the City decides to close BKL and apply for closure

in 2023 (Option 2), approximately $9.4 million would have to be paid back to the FAA and

ODOT.

2. Economic impact of closing: There are multiple businesses located at BKL, both

aeronautical and non-aeronautical that would be impacted by BKL closing. The two main

aeronautical tenants, Signature and Aitheras, employ 18 and 35, respectively. Numerous

entities lease space from Signature’s hangars, including organ transplant companies, local

television station helicopters, Cleveland Clinic and University Hospital emergency

helicopter services, and other commercial/charter and noncommercial aviation operators.

Presumably, much of this activity would

relocate to CLE, CGF, or other airports outside the city, but some may simply cease to

exist.

3. On-going maintenance responsibility: The City of Cleveland would be responsible for

the repair and maintenance of BKL without federal and/or state assistance throughout the

legal challenges and FAA approvals, until 2036 if waiting out grant obligations.

4. Signature lease buy-out: In 2016, the FBO (Signature Flight Support) negotiated a

ground lease and constructed a 6,000-square-foot executive terminal, a 20,000-square-

foot hangar, and a new fuel farm. These capital costs, according to Signature, were

approximately $16.5 million.

TRADE SECRET

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 3

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

TRADE SECRET

ATTY WORK PROD

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 4

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

1.0 BKL CLOSURE ALTERNATIVE EVALUATION

This airport closure alternative study supplements the Airport Layout Plan (ALP) narrative report

by evaluating the Federal Aviation Administration (FAA) requirements to close Burke Lakefront

Airport (BKL or the Airport) if chosen as the preferred alternative. The following analysis takes

into consideration guidance on grant assurances and federal obligations provided in FAA Order

5100.38D, Change 1, Airport Improvement Program Handbook. In addition, the Airport

Compliance Manual (FAA Order 5190.6B) was used to review FAA guidance on the requirements,

steps, and feasibility of closing an airport. The goal of this analysis is not to provide a

recommendation on whether the City of Cleveland (Airport Sponsor) should or should not close

the airport but rather an overview of the requirements, potential financial or legal implications, and

its effect on its stakeholders. In pursuance of an airport closure, the FAA’s primary concern is

proper documentation/analysis of how an airport closure would provide a net benefit to the

aviation community. If selected as the preferred alternative, this report could be used as the first

step in the process if the City of Cleveland chooses to proceed and begin the process to close

BKL.

To evaluate the potential benefits/implications of closing BKL, the following tasks were performed:

 Stakeholder interviews were conducted to document the significance of BKL to their

existing and future operation, in comparison to an alternate airport.

 Review of other successful or unsuccessful airport closures

 Evaluation of nearby alternative airports that could support activity from BKL given facility

availability and expansion potential

 Review of FAA grant history and federal and/or state obligations related to BKL

 Financial conditions and implications

1.1 BKL’S ROLE IN THE AVIATION SYSTEM

BKL is located along Route 2 in Cleveland, Ohio on the shore of Lake Erie. BKL is in proximity to

major business centers, making this airport an active general aviation facility serving the entire

Northeast Ohio region. The service from this airport was classified in the 2023-2027 National Plan

of Integrated Airport Systems (NPIAS) Report as a Regional General Aviation airport. BKL plays

a role as a reliever airport for the greater Northern Ohio region and Cleveland Hopkins

International Airport (CLE), as well as providing service for multiple medical transport operations.

According to the FAA Terminal Area Forecasts (TAF), BKL had a total of 36,964 operations in

2021, made up of a diverse fleet mix of General Aviation (GA) activity. GA consists of many types

of users; however, the activity at BKL has a high level of corporate jet activity, which demonstrates

that BKL activity is tied to serving business users. In addition to business and corporate activity,

professional sports teams use BKL (visiting Major League Baseball and National Basketball

Association teams) to fly in and out of Cleveland for games on larger commercial service aircraft,

including Boeing 737s, 757, and Airbus 319s. BKL is also used for medical transport flights and

organ transportation for local hospitals such as the Cleveland Clinic and University Hospitals

(Aitheras, Aery Aviation). BKL also supports flight schools training pilots on single-engine piston

aircraft. Ultimate Air launched commercial service from BKL 2015 with Cleveland to Cincinnati

flights 5 days a week. Before the pandemic, Ultimate had plans to increase the route to three

times daily in 2020. Ultimate eventually shut down operations in March 2020 but restarted in July

2020 only to pause once again in September 2020. In April 2021, Ultimate restarted service to

Cincinnati but then paused service as of December 2021 and as of October 2022 has not

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 5

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

returned. Finally, BKL is home to the Cleveland National Air Show, which takes place for three

days every Labor Day weekend.

1.1.1 Confined Disposal Facilities

Operating as both a neighbor and a tenant, Confined Disposal Facilities (CDFs) are located on

obligated airport property . A CDF is a technology in which

dredged material is placed inside perimeter dikes built up above the water surface level. This

technology provides more protection to the adjacent surface water as any contaminated material

is confined. The dredged material at BKL comes from the Cuyahoga River. The dredging normally

occurs in the fall and the spring to maintain the river and Cleveland harbor as a navigable

waterway.

The Cleveland-Cuyahoga Port Authority (Port Authority)

currently operates the northern half of CDF 9 and all of CDF 12. The U.S. Army of Engineers

(USACE), Buffalo District operates and maintains CDF 10B, and CDF 13 is closed.

Figure 1-1. Existing Confined Disposal Facilities

1.2 REVIEW OF PAST AIRPORT CLOSURES

This task provided a baseline understanding of recent successful and unsuccessful public airport

closures. The closure of an airport is extremely rare, so a review of historical events was used to

supplement guidance in FAA Order 5190.6B. Some challenges to closing an airport include legal

implications, user opposition, and logistics involved with transferring aeronautical activity from

one airport to another. A review of recent airport closures provided an understanding of both the

pros and cons of closing an airport and the potential challenges that may occur if this becomes

the City’s preferred alternative. The following airports were reviewed to document how/why the

airport initiated an airport closure, timeframe, challenges, and disposition:

 Richards-Gebaur Memorial Airport, Kansas City, MO

 Meigs Field Airport, Chicago, IL

 Blue Ash Airport, Cincinnati, OH

 St. Clair Airport, Kansas City, MO

 Kent State University Airport, Stow, OH

 East Hampton Airport, East Hampton, NY

TRADE SECRET

ATTY WORK PROD

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 6

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

1.2.1 Richards-Gebaur Memorial Airport, Kansas City, MO

Located in Kansas City, the Grandview Airfield was constructed in 1941 on land owned by the

City of Kansas City, MO. In 1955, the city transferred the property to the United States, which the

U.S. Air Force used as a military base until 1976 when it was deactivated.

In 1985, the United

States conveyed the airport land back to the city via the Surplus Property Act. This conveyance

required the city to use the property as a public use airport, and it established the Richards-

Gebaur Airport. Between 1986-1994, the city accepted $12 million in federal Airport Improvement

Program (AIP) funds for airport development. Each grant required the acceptance of grant

assurances that the airport would be available to the public for aeronautical use. Between 1983

and 1997, the City of Kansas City experienced an $18 million operating deficit at Richards-Gebaur

Airport. Following this loss, the city submitted a request to the FAA to close the airport and pursue

redeveloping the land. In 1998, the FAA approved a plan to close the airport, and the city closed

Richards-Gebaur Airport in 1999. The city and the FAA agreed to a memorandum of agreement

which required the city to deposit $5 million into an escrow account to be dispersed by the FAA

for federally eligible aviation improvement projects in the Kansas City area. The city also agreed

that for 20 years, it would deposit all net proceeds from the anticipated lease of the airport to be

used at other general aviation airports.

Today, the former airport is used by Kansas City Southern

Railroad. Several businesses are removing the old runway and facilities to build a large truck-to-

rail freight center with above-ground and underground storage.

1.2.2 Merrill C. Meigs Field Airport, Chicago, IL

Merrill C. Meigs Field Airport, located in downtown Chicago adjacent to Lake Michigan, operated

from December 1948 until March 2003.

In the 1970s, Meigs Field operated as a critical facility

for the aeromedical transport of patients and organs to downtown hospitals as medical

transportation technology modernized. The Chicago Department of Aviation operated the Main

Terminal Building. Former Chicago Mayor, Richard M. Daley, forced the closing of Meigs in 2003

by ordering the overnight bulldozing of its runway without notice to the FAA. While aviation

enthusiasts and commentators rejected the decision, the supporters of Mayor Daley believed it

was in the city’s best interest for the land to be a park.

The FAA fined the city $33,000 for closing an airport with a charted instrument approach without

giving the required 30-day notice.

In 2006, the city dropped all legal appeals and agreed to pay

the $33,000 fine and $1 million in FAA AIP funds. The FAA initially held that the city improperly

used $1.5 million of AIP funds to demolish Meigs and threatened to impose up to triple the amount

Friends of Richards-Gebaur Airport v. F.A.A, 251 F.3d 1178 (8th Cir. 2001) Retrieved from

https://casetext.com/case/friends-of-richards-gebaur-airport-v-faa.

Friends of Richards-Gebaur Airport v. F.A.A, 251 F.3d 1178 (8th Cir. 2001) Retrieved from

https://casetext.com/case/friends-of-richards-gebaur-airport-v-faa.

Hubbard, S. (2008 November 16). Kansas City Business Journal. American City Business Journal.

Retrieved from https://www.bizjournals.com/kansascity/stories/2008/11/17/focus23.html.

Freeman, P. (2022, June 22). Meigs Field. American Aviation Historical Society. Retrieved from

http://www.airfields-freeman.com/IL/Airfields_IL_Chicago_C.htm#meigs.

U.S. DOT/FAA. (2004, March). Revocation of Class D Airspace Area. Federal Register: Daily Journal of

the United States Government. Retrieved from https://www.federalregister.gov/documents/2004/03/26/04-

6861/revocation-of-class-d-airspace-area-chicago-il.

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 7

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

($4.5 million) in penalties.

The city claimed that some of the money was legitimately spent on

environmental cleanup at the site, and the FAA dropped the penalty. The city amassed more than

$500,000 in legal fees during two years of legal battles. Today, the site where Merrill C. Meigs

Field Airport once stood is a public park for the city.

1.2.3 Cincinnati–Blue Ash Airport, Cincinnati, OH

Established in 1921 as a dirt runway airmail route, this airfield underwent several names and

ownership transitions. The private-use airport was dedicated as the Watson Field Airport in 1928,

handling operations between Cleveland, Ohio, and Louisville, Kentucky.

After World War II, the

strip was sold to the City of Cincinnati and named the Blue Ash Airport. Following a flood of the

Lunken Airport, federal funds were granted to the Greater Cincinnati Airport (now CVG), which

began providing service in the 1950s. For the next 30 years, the Blue Ash Airport and property

use would have several failed plans towards expanding operations and facilities. Development

plans were hampered by community opposition, politics, and the City of Cincinnati’s decision not

to accept federal funding. The original field of the Blue Ash Airport had approximately 1,400 acres

of land. However, after zoning was developed in the area, the City of Cincinnati decided additional

monetary ventures could be pursued with the undeveloped airport land.

Some property sections

were used for industrial development and an 18-hole golf course. The remaining property, 130

acres of airfield, was sold to the City of Blue Ash in 2006 in an agreement for $37.5 million over

30 years.

The agreement specified that Blue Ash would commit up to $2 million in matching

funds to the FAA grants received by the City of Cincinnati. Should the City of Cincinnati not receive

the required $10 million in FAA funds requested, the city would have the option of closing the

airport. Maintaining operations at this airfield fell short in 2012 as the City of Blue Ash

acknowledged that it could not afford to reconfigure the airfield and keep it operational. The City

of Cincinnati was also interested in improving other regional airports. In 2017, the FAA recognized

that the city is no longer contractually obligated to continue operating this airport, and the airport

properly filed a 30-Day notice.

Today, the area houses commercial buildings and a golf course,

and it is still under further development towards additional public use spaces.

The airport

officially closed in 2012.

U.S. DOT/FAA. (2004, March). Revocation of Class D Airspace Area. Federal Register: Daily Journal of the United

States Government. Retrieved from https://www.federalregister.gov/documents/2004/03/26/04-6861/revocation-of-

class-d-airspace-area-chicago-il.

Gertler, J. (2012, January). “Early Aviators-Hugh Watson”. Retrieved from https://earlyaviators.com/ewatson.html.

Blue Ash Airport Park Master Plan. (2012, July). Retrieved from

https://web.archive.org/web/20120716220249/http://www.blueash.com/filestorage/79/Blue_Ash_Airport_Park_Master

_Plan_2012.pdf.

Osborne, K. (2005, July). "City Shops an Airfield". The Cincinnati Post.

U.S. DOT/FAA. (2012, September). Permanent Closure of Cincinnati Blue Ash Airport. Federal Register: Daily

Journal of the United States Government. Retrieved by https://www.federalregister.gov/documents/2012/09/11/2012-

22255/permanent-closure-of-cincinnati-blue-ash-airport.

City of Cincinnati. (2016, December). Airport Property Redevelopment. Clean Ohio Revitalization Fund

Application. Retrieved from https://web.archive.org/web/20140101193252/http:/www.cincinnati-

oh.gov/dote/cache/file/4425D4A5-2720-4C6F-87B238C633654A28.pdf.

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 8

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

1.2.4 St. Clair Regional Airport – Kansas City, MO

The St. Clair Regional Airport was built in the 1960s through the efforts of former World War II

pilots and other aviation enthusiasts.

The development of the airport was paid for with a mix of

federal, city, and private funds. This non-towered, general aviation airport consisted of

approximately 79 acres and had six based aircraft. In the late 1990s, maintaining the airport began

to cost the city $30,000 to $50,000 a year. The airport was located at the intersection of Missouri

Highway 47 and Interstate 44, making the land valuable for retail and other developments that

could expand the local tax base. Since the St. Clair Regional Airport was federally obligated, the

city had to repay more than $760,000 in federal grants used to pay for improvements. The FAA

recognized that the City of St. Clair met the federal grant payback requirement and gave the

required 30-day notice of closure in 2017.

1.2.5 Kent State University Airport – Stow, OH

The Stow Airfield was constructed in 1920 and, in 1942, became part of Kent State University.

This airport consists of 320 acres, one paved 4,000’ x 60’ runway, parallel taxiway, medium

intensity runway and taxiway lighting, terminal building, fuel farm, 14 T-hangars, community

hangar, maintenance hangar, and an aircraft parking area. As Master Plan Study in 2006 did

include one alternative to close of Kent State University Airport (1G3) and the transfer of

operations to Portage County Regional Airport (POV). However, the study concluded that the

financial gain from redeveloping and constructing adequate facilities at POV would be difficult.

Since then, the University has invested in 1G3 and the airport remains open and a viable part of

the University flight training program.

1.2.6 East Hampton Airport – East Hampton, NY

East Hampton Airport (HTO) is a general aviation airport in the NPIAS. The Town of East Hampton

has owned and operated HTO for several decades. HTO previously received federal grants to aid

airport development and was subject to statutory grant assurances. The Town of East Hampton

wanted to restrict what type of aircraft could operate at the facility, which the FAA prohibits without

approval under 14 CFR 161. The FAA provided the town with four options: 1) negotiate an

agreement for mandatory restrictions on aircraft per Part 161; 2) close the airport after the grant

assurances expire, which was September 2021; 3) close the airport after assurances expire and

open it as a private airport; and 4) continue to operate the airport as a public use airport. The town

elected to close the airport and re-open it as a private facility so it could restrict access. On

January 20, 2022, and amended on February 17, 2022, the Town of East Hampton notified the

FAA that it sought to transition HTO on May 17, 2022 from a public-use airport to a private-use

airport. The FAA recognized that HTO met the requirements and accepted the transition to a

private-use airport.

On May 19, 2022, HTO became East Hampton Town Airport (JPX), a private

Freeman, P. (2022, June). St. Clair Municipal Airport and Regional Airport. Missouri Aviation Historical Society.

Retrieved from http://www.airfields-freeman.com/MO/Airfields_MO_SE.htm#stclair2.

U.S. DOT/FAA. (2012, September). Permanent Closure for St. Clair Missouri. Federal Register: Daily Journal of the

United States Government. Retrieved from https://www.federalregister.gov/documents/2017/10/13/2017-

22231/notice-of-release-and-permanent-closure-of-the-st-clair-regional-airport-st-clair-missouri.

U.S. DOT/FAA. (2022, March). Permanent Closure of the Public-Use of East Hampton Airport. Federal

https://www.federalregister.gov/documents/2022/04/15/2022-08059/permanent-closure-of-the-public-use-of-east-

hampton-airport.

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 9

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

facility. Immediately following this change, three separate court orders were issued in the New

York Supreme Court, Suffolk County, filed by airport users. The temporary restraining orders

(TRO) stated that the Town of East Hampton is temporarily prohibited from closing HTO and

becoming private.

After the three TROs were issued, and to fully comply with the orders, the Town of East Hampton

submitted a request to the FAA informing it that the town was ordered to delay the closure of HTO

and requested direction and assistance on the next steps it should take. The FAA responded that

they could not safely reverse the deactivation process. The HTO location identifier ceased to exist

on May 19, 2022; the previous airspace for HTO did not exist; the existing instrument procedures

were decommissioned; and a letter of agreement was already executed between the town and

the FAA for the existing airport traffic control tower (ATCT). For those reasons, the FAA

recommended continuing to operate as a private airfield. In October 2022, after various lawsuits

by existing tenants, and aviation organizations like the National Business Aviation Association

(NBAA), the courts ruled the town could not close or privatize the airport. It was also estimated

the Town spent over $2.5M just in legal fees to close and re-open as a private facility.

It is noted that as compared to the six airports discussed above, BKL has a substantially more

capable airfield, can accommodate any size of general aviation aircraft along with some

commercial aircraft, and maintains a commercial operating certificate to support scheduled airline

activity. The closure of BKL could therefore be considered of greater significance than any of

these other airport closure activities.

1.3 STAKEHOLDER INTERVIEWS

Stakeholder interviews were conducted to document BKL’s role in the aviation system, the

northern Ohio region, and the City of Cleveland. These interviews were conducted to gauge a

response to a potential closure of the airport. Major findings from the stakeholder interviews are

summarized below.

 Cleveland-Cuyahoga Port Authority (Port Authority): The Port Authority is the sponsor

for CDFs 9 and 12, both located on airport property. Their location continues to limit the

Port Authority’s ability to enter into long-term agreements with the U.S. Army Corp of

Engineers (USACE) to accept dredge material in the future. Because the Port Authority’s

operation is “on-airport” property, they must submit airspace approvals and construction

safety phasing plans and are subject to FAA approvals. The Port Authority would like its

CDF operations to be separate from the Airport with dedicated access. Currently, access

to CDF 12 requires utilizing the airport-controlled eastern vehicle service road, and certain

construction activity takes place within the Runway Protection Zones (RPZ). The closure

of BKL could provide additional CDF capacity, would reduce operating costs, and would

increase certainty for maritime commerce.

 US Army Corp of Engineers (USACE): The USACE currently maintains CDF 10B, which

as of October 2022, will reach capacity within 18 months (2 more dredge cycles). Located

adjacent to BKL, the CDF 10B capacity is currently limited due to airspace height

requirements. Like the Port Authority’s position, a closure of BKL would present

opportunities to expand operations and increase capacity.

 Ohio Department of Transportation (ODOT) Office of Aviation: ODOT supports public

use airports throughout the state with funding and administrative support. Pursuant to

ODOT’s Standard Assurances, which the City of Cleveland agreed to when it accepts

state grants, the City would have to return those funds to ODOT, if BKL would close.

According to ODOT, Standard Assurances 9 and 10 require an airport to pay back the

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 10

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

total amount of ODOT funds received either for facilities or equipment if within 20 years

from the date of the grant contract.

According to ODOT, the City received $1,468,091

from 2018-2019.

 Ohio Department of National Resources (DNR): The Assistant Chief Office of Coastal

Management stated that the existing Standard Lease Line (SLL) expires in 2042 and

currently only covers the northern side of BKL. The SLL gives the City the right to occupy

territory on Lake Erie. Uses allowed are airport expansion, port development, and CDF

operations. Any alternative development of the airport would require coordination with

DNR, and a consent to sublease would be required if proposed land use is not one of the

permitted uses. DNR did not provide a position on the airport’s closure.

 Signature Flight Support (Signature): Signature is the primary tenant at BKL, providing

fixed based operator (FBO) services, including hangar storage, aircraft maintenance, and

fueling. Signature is currently leasing both corporate hangars from the city, in addition to

their ground lease for their FBO facility and fuel farm. Signature currently has a master

lease covering the ground lease for their new FBO facility, the fuel farm, and the corporate

hangar located adjacent to their FBO facility, which expires in 2043. At this time, the new

FBO would revert to the city at the end of the lease terms. In 2016, Signature invested

approximately $16.5M by constructing the new FBO facility and fuel farm. The second

hangar is also leased by Signature on a separate lease, which expires in 2022. Signature

stated that they served/serviced over 900 companies over a 12-month period and their

heavy investment in BKL was attributed to an increase in itinerant activity at the Airport.

In addition, Signature stated Aery Aviation was a new tenant subleasing space, providing

organ and physician transport for the Cleveland Clinic.

 Aitheras Aviation Group (Aitheras): Aitheras has seven based aircraft, 35 employees,

and leases the 15,000-square-foot hangar and adjacent 6,000 square feet of office space

at BKL on Signature’s leasehold. Aitheras provides FAR Part 135 charter service,

including air ambulance (medical air ambulance, organ harvest transport, physician

transport, etc.) for University Hospitals (UH) and Cleveland Clinic, maintenance, and

traditional charter. During BKL closure discussions, Aitheras discussed airports near BKL

that could potentially support their operation. They stated that Cuyahoga County Airport

(CGF) would be comparable as it has an instrument landing system (ILS) and an aircraft

rescue and firefighting (ARFF) facility; however, they would have to evaluate how a shorter

runway and weather at CGF may impact their operations. They currently conduct

approximately 200 operations a year but stated their activity would increase significantly

as they are adding another aircraft to their fleet at BKL for organ transplant.

 Cleveland National Air Show: The Cleveland National Air Show, Inc. (Air Show) is a

financially self-sufficient 501 (c) (4) nonprofit corporation. The volunteer Board of Trustees

comprises 35 local businesses and civic and community leaders. The Air Show typically

entertains 60,000-100,000 Clevelanders and visitors annually over the three-day Labor

Day weekend event. According to the Air Show, the last economic impact study was

completed in 2011; however, the overall impact on the region at that time was just over

Ohio Department of Transportation. (2022, September). Ohio Airport Grant Program For General Aviation Airports.

Retrieved from https://www.transportation.ohio.gov/static/Programs/Aviation/Grant-Program/Direct-

Grant/Appendix%20D%20-%20Standard%20Assurances.pdf.

TRADE SECRET

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 11

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

$7M, which is expected to be over $10M today. The 2022 ticketing database included

spectators from 44 different states and six foreign countries. In addition to the hotel rooms

purchased by the spectators, the Air Show generates downtown hotel nights via room

blocks for 600-750 room nights. According to the Air Show personnel, they could not

relocate the three-day weekend to an area airport given the amount of sterile air space

required for the acrobatic performances, most of which is supplied by the open water of

Lake Erie.

In addition, interviews were conducted with identified alternative airports that could potentially

serve activity from BKL, including Cuyahoga County Airport (CGF), Lake County Executive Airport

(LNN), Kent State University Airport (1G3), Medina Municipal Airport (1G5), Cleveland-Hopkins

International Airport (CLE), and Lorain County Regional (LPR). Alternative airport interviews were

important to identify alternate facility availability, operational requirements, and future

development potential. An inventory of operational navaids and facility availability is further

discussed in the Surplus Airport Capacity Evaluation section of this report. A summary of

discussions with alternative airports is included below.

 Cuyahoga County Airport (CGF): The CGF airport manager stated that there is currently

a waiting list for hangars; however, some of the existing hangar infrastructure needs

rehabilitation. There is currently no waiting list for tie-downs. Approximately 20,000 square

feet for future hangar space is available for development on the north side of the airport;

however, future development would have to mitigate potential wetlands in the area. The

airport does have ample space on the south side of the runway, but development would

be more expensive as there is no south-side taxiway infrastructure. The relocation of

Taxiway ‘A’ (full-length parallel taxiway on the north side) is the focus going forward to

provide standard runway-taxiway separation. Over the last five years, the airport has

undergone substantial improvements by reconstructing its 5,502-foot runway, improving

the safety areas beyond the runway ends, and reconstructing 20,000 square yards of

existing apron pavement. CGF also has a voluntary noise abatement program between

11:00 PM and 7:00 AM. Although CGF has important airfield infrastructure for corporate

GA (runway length, ILS, approach lights), the lack of available hangar space would be an

issue for any potential BKL relocations.

 Lake County Executive Airport (LNN): The airport manager for LNN stated that hangars

are at capacity and the airport currently has a waiting list. The facility can accommodate

transient operations but does not have the current capacity to absorb all BKL operations

and based aircraft. Upcoming development for LNN will include additional T-hangars to

satisfy the current waiting list and improving taxiway geometry. Currently, LNN’s priority

focus and goal at the airport is to meet FAA design standards and attract more corporate

activity. LNN’s development goals include facility development on the north side of the

airport and a parallel taxiway.

 Kent State University Airport (1G3): The airport manager of 1G3 stated that the airport’s

primary focus was supporting Kent State University’s training activity. They are currently

planning for additional hangars, but their focus would be on academia and flight training.

Airport management also stated they were at capacity for operations at the one runway

airport. With almost 73,000 operations a year and limited hangar and ramp space, 1G3 is

limited in absorbing BKL GA activity.

 Medina Municipal Airport (1G5): The 1G5 airport can handle the general activity of

aircraft that can land on their runway (3,556’); however, there is no availability for aircraft

storage in the hangars. Short-term tie-downs are available and managed by the FBO, but

TRADE SECRET

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 12

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

the apron and tie-down space is limited. 1G5 could handle additional general aviation

operations on their existing runways, however there is no availability for aircraft storage in

the existing hangars. The Airport manager identified that the FAA has approved federal

funds for updating taxiway and runway lighting.

 Cleveland-Hopkins International Airport (CLE): No interview was conducted with CLE

since the City of Cleveland operates both CLE and BKL. An inventory of facilities available

and future development initiative is included in the Alternative Airport Capacity Analysis

section of the recently updated Master Plan. Overall, CLE can accommodate the

operations of the large corporate aircraft that use BKL currently; however, like other

airports, existing surplus hangar space is not currently available at CLE.

 Lorain County Regional (LPR): According to airport management, LPR has no vacant

hangars or tie-downs, with a waiting list for both. Accommodating BKL’s jet operations or

based aircraft was not something they could confirm immediately. Additional hangar space

is welcomed and needed; however, any hangar development would have to be completed

by others as the County is not in the position to construct hangars themselves and enter

into ground leases. However, LPR does have ample room for development of corporate

hangars if constructed by others.

1.4 SURPLUS AIRPORT CAPACITY EVALUATION

If BKL were to close, the City of Cleveland would have to show that closing BKL would provide a

net benefit to the civil aviation system. Nearby airports were identified that could potentially

support aeronautical users and activity from BKL. These airports identified have the most potential

to be alternate/substitute airports based on their proximity to users, airfield features, hangar and

apron/tie-down availability, and available property for development:

 Cuyahoga County Airport (CGF)

 Cleveland-Hopkins International Airport (CLE)

 Lake County Executive Airport (LNN)

 Lorain County Regional (LPR)

 Kent State University Airport (1G3)

 Medina Municipal Airport (1G5)

1.4.1 Geographic Location of Users

The first step in determining which alternate airport a BKL operator could potentially use is to

determine the geographic location of the user’s home or business. This information was primarily

derived using the aircraft identification number (N-Number) and address used to register the

aircraft. For based aircraft at BKL, some stakeholder interviews were conducted to document

proximity to operators’ recreational and/or business activities and facility requirements. For

itinerant users (i.e., users utilizing the airport but not based at BKL), operations data were

examined for the peak month (July 2021). Information such as the date of arrival or departure,

aircraft identification number, and type of aircraft was documented for 782 operations at the airport

for July 2021. Any itinerant user that had a registered address within a 4-hour drive of BKL was

added to the based aircraft user list to form the geographic location of BKL users.

Figure 1-1 illustrates the geographic location of BKL users (based and itinerant) and the location

of alternate airports, as noted above.

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 13

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

1.4.2 Alternative Airport Capacity Analysis

Once the geographic locations of BKL’s users were documented, the next step was to determine

the available airfield capacity and storage availability (i.e., hangars and parking aprons) for

alternate airports mentioned above. Although these airports may have hangar availability, land

for development, or a few FBO operations, most airport reports recognize that additional studies

such as site selection, ALPs, and environmental studies could be necessary before a definite

recommendation can be made. Below is a summary of the inventory and existing conditions at

the alternative airports is discussed below.

Cuyahoga County Airport (CGF)

Cuyahoga County Airport (CGF) is located approximately 20 miles to the northeast of BKL on 640

acres of property. The CGF Airport has one runway that is 5,502’ by 100’ with an ILS approach

to Runway 24. A Pavement Condition Index (PCI) map prepared by ODOT identifies the

pavement conditions and other numerous improvements to the runway, safety areas, and apron

areas have been conducted. CGF currently has a voluntary noise abatement program between

11:00 PM and 7:00 AM. The apron space available is about 700,000 square feet (Sq. Ft.) with a

dedicated tie-down area to the southwest of the apron. CGF has a fire station present at the

airport and the Cleveland Jet Center is the primary FBO. CGF airport currently has 247 based

aircraft, including one helicopter; and accommodated over 26,000 aviation operations according

to the FAA’s 2021 Terminal Area Forecast (TAF) Report. There is one heated hangar on-site as

well as several tie-downs, however, there is a waitlist for new clients to base here. Interviews with

the manager of this airport revealed about 20,000 square feet (two corporate hangar areas) is

available for future hangar development. The southside of the runway is relatively open for future

development but would come at a considerable cost as the area is lower than the runway elevation

and there is no parallel taxiway infrastructure on the south side.

Cleveland-Hopkins International Airport (CLE)

Cleveland-Hopkins International Airport (CLE) is located 17 miles to the southeast of BKL. CLE

is a commercial service airport with three runways and approximately 2.5 million square feet of

apron space. Runway 6L/24R, Runway 6R/24L, and Runway 28 all provide ILS approaches into

CLE during adverse weather conditions. This airport can accommodate large approach category

aircraft and handle high-capacity operations. According to the 2020 Master Plan, CLE had over

70,000 operations. This airport also services several other aviation business fronts that require

runway usage such as cargo services. CLE has two FBOs offering services to the public. One of

the providers, JETS, offers 100LL, Jet A, and Jet A+ fueling services. Atlantic Aviation offers the

same fuel options, as well as rental car options and crew lounges. There is no designated heliport

at the airport and landing fees are present for all aircraft. CLE operates under Class B airspace,

ARFF index C rating, and has approximately 50 Based Aircraft. CLE should be able to

accommodate most of the corporate jet activity that utilizes BKL; however, the reason BKL

subsidies are a part of the CLE airlines rates and charges is to keep most of the general aviation

activity at BKL. According to the CLE Master Plan Update, the FBO has 50,000 square feet of

hangar space at CLE, which currently operates at 175% of capacity. This is possible because the

aircraft stored in the hangar are highly utilized coming and going on a frequent basis. The FBO at

CLE most likely could not accept new tenants until some of the proposed development on the

south side of the airport, recommended in the Master Plan, is realized.

Lake County Executive Airport (LNN)

LNN is 18 miles northeast of BKL on approximately 400 acres of property. This airport has two

runways and 190,000 square feet of apron space available with 82 based aircraft. Runway 5/23

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 14

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

is 5,028 feet by 100 feet, and Runway 10/28 is 4,272 feet by 100 feet. Additionally, LNN is

proposing to add additional T-hangars to satisfy their waitlist and will also focus on constructing

a parallel taxiway, which neither runway has. The airport also would like to re-address its public

space use and availability. The largest facility on the property is a sports complex repurposing an

old aircraft hangar on site, which is used for indoor soccer and hockey. The lease for this property

runs out in 2041, and at that point, the airport could convert the facility to a large hangar. This

conversion would be a crucial addition for LNN because their current capacity is highly saturated.

The airport is open to accommodating corporate jet activity but is limited without a parallel taxiway

because jet traffic must have to back taxi on the runway. The FBO at this airport is the Classic Jet

Center, a full-service FBO that operates some leased tie-down spaces on the property. LNN also

has two fire stations within the property’s boundaries.

Lorain County Regional (LPR)

LPR is located 29 miles southwest of BKL. This facility is owned by Lorain County and operated

and maintained by MRK Aviation, the FBO. There is one runway (Runway 7/25, which is 5,002

feet by 100 feet with an ILS approach to Runway 7) and 460,000 square feet of general aviation

apron and tie-down space. LPR accommodated approximately 15,000 aircraft operations in 2020.

The airport has 15 hangars, 8 private tenants, and approximately 84 based aircraft. The current

capacity at LPR can accommodate more jet activity, with ample acreage to develop facilities

around the airport. According to the ODOT PCI (2021), LPR runways and taxiways are in good

condition. Although several private tenants and hangars are available, the airport has only one

FBO. MRK Aviation services include fueling for 100LL, Jet A, and Jet A+; general maintenance;

courtesy car; and pilot supplies with a crew lounge.

Kent State University Airport (1G3)

Kent State Airport is located approximately 29 miles southeast of BKL, with one runway and

158,500 square feet of apron space. Currently, the university airport acts as its own FBO with 40

based aircraft and over 73,000 recorded operations annually. The city recently approved funding

to build a shared-use fire station at the airport. Moving forward with airport development and

funding, intentions to rehabilitate the current runways, apron, and new hangars are anticipated in

the future. However, even though there is projected development at the airport, they will continue

to focus on the university’s program flight training program. Accommodating potential activity from

BKL if it is closed may be difficult due to the amount of existing flight training activity.

Medina Municipal Airport (1G5)

1G5 is located 25 miles south of BKL on 283 acres of property. 1G5 provides short-term tie-down

options, but the apron space is the most limited of all the alternative airport options, with

approximately 50,000 square feet. 1G5 does not have any existing hangar availability. The FBO,

Flight Services, manages the tie-downs and hangars, which both have a waitlist. The closest fire

station is within 5 miles of the airport. 1G5 is also the most limited airport with respect to runway

length.

Table 1-1 summarizes the alternative airports above by describing the airfield infrastructure and

supporting facility availability (i.e., number of runways and length, taxiway system, apron, and

hangar space, ATCT availability, etc.).

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 15

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

Table 1-1. Airfield Capacity Summary

Airport

Runway(s)

Runway

Dimension

(in feet)

Displaced

Threshold

Landing

Fees

ATCT

Notes

CGF 06 / 24 5,502 x 100 318’ / 500’ No Yes

 Recently reconstructed 20,000 square yards of apron

 Corporate hangar space (20,000 square feet) on the north side of the airport;

however, could impact wetlands

 The south side of the runway is open for development; however, no taxiway

infrastructure is currently present

 Approach lights and ILS

 Taxiway ‘A’ will be relocated to provide standard runway-taxiway separation

 Has ability to absorb some corporate GA traffic

CLE

06L / 24R 9,000 x 150 N/A

Yes Yes

 Recent Master Plan Update has plans for corporate hangar development on

south side.

 Most likely would only absorb the sports teams that utilize BKL and some

additional corporate GA.

06R / 24L 9,953 x 150

Runway 6R

- 1,923 ft

10 / 28 6,018 x 150 N/A

LNN

05 / 23 5,028 x 100

Runway 5 –

428 ft

No* No

 Has ability to absorb some corporate GA traffic given runway length

 No parallel taxiway on either runway

 Has an existing waiting list for hangars

10 / 28 4,272 x 100

Runway 28

- 1,124 ft

LPR 07 / 25 5,002 x 100 N/A No No

 Approach lights and ILS

 Available room for hangar development

1G3 01 / 19 4,000 x 60

Runway 1 –

53 ft

No* No

 Hangar rehabilitation needed

1G5

01 / 19 2,868 x 60

Runway 19

– 737 ft

No No

 Smallest apron space available

 Shortest runway

09 / 27 3,556 x 75 N/A

Notes: RWY = Runway; ATC = Airport Traffic Control Tower

*Landing Fees may vary at these locations based and aircraft type and services needed.

Source: Publicly available airport information; FAA Airport 5010, September 2021; CHA 2022

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 16

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

Table 1-2 contains a list of the current BKL based aircraft and itinerant users during July 2021

(peak month) and if the runway at each alternative airport can accommodate these aircraft.

Table 1-2. Runway Capability Summary Table

N Number

Aircraft

Operator

Runway

Length

Required

CGF

1G3

LNN

LPR

1G5

CLE

N100UJ

Dornier

328-300 Jet

Ultimate

JetCharters

LLC

4,485 ft Yes No Yes Yes No Yes

N111PA Helicopter

Preferred

Helicopter

Serv.

Yes Yes Yes Yes Yes Yes

N11UC

Piper PA-

32-301

RCHT LLC 3,200 ft Yes Yes Yes Yes Yes Yes

N127ZA

Cessna

550

Citation

Bravo

B200 LLC 4,160 ft Yes No Yes Yes No Yes

N1531C

Cirrus

SR22

Ramos,

Jose L

3,200 ft Yes Yes Yes Yes Yes Yes

N154AV

Piper

Cherokee

Daviation Inc 3,200 ft Yes Yes Yes Yes Yes Yes

N204BE

Cessna

172N

Skyhawk

Pink Skies

Inc

3,200 ft Yes Yes Yes Yes Yes Yes

N208GT

Cirrus

SR20

GTI

Properties

3,200 ft Yes Yes Yes Yes Yes Yes

N2232E

Cessna

172N

Skyhawk

Pink Skies

Inc

3,200 ft Yes Yes Yes Yes Yes Yes

N23KM

Beech 58

Baron

R H Phillips

Trucking Co

Inc

2,300 ft Yes Yes Yes Yes Yes Yes

N2875B

Piper

Cherokee

RAS

Aviation LLC

3,200 ft Yes Yes Yes Yes Yes Yes

N299JW

Cirrus

SR22

About Time

Aviation

3,200 ft Yes Yes Yes Yes Yes Yes

N356BZ

Embraer

ERJ-135LR

Maxus

Capital

Group LLC

5,774 ft No No No No No Yes

N359SK

Dornier

328-310 Jet

Ultimate

JetCharters

LLC

4,485 ft Yes No Yes No No Yes

N40447

Piper PA-

32R-300

Antares

Aviation LLC

3,200 ft Yes Yes Yes Yes Yes Yes

N405SP

Cessna

172

Flight Wings 3,200 ft Yes Yes Yes Yes Yes Yes

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 17

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

N4649M

Cessna

152

Daviation Inc 3,200 ft

Yes Yes Yes Yes Yes Yes

N4889D

Cessna

172N

Skyhawk

Pink Skies

Inc

3,200 ft Yes Yes Yes Yes Yes Yes

N515GK

Beech E90

King Air

Avintel Mgmt

LLC

2,024 ft Yes Yes Yes Yes Yes Yes

N52MG

Piper

Aerostar

600

N52MG LLC 3,100 ft Yes Yes Yes Yes Yes Yes

N53491

Cessna

172

Rohl, Larry 3,200 ft Yes Yes Yes Yes Yes Yes

N5481M

Cessna

152

Alpha Wings 3,200 ft Yes Yes Yes Yes Yes Yes

N626TM

Cessna

525

CitationJet

JJS LLC 3,210 ft Yes Yes Yes Yes Yes Yes

N6359C

Piper PA-

28-161

RAS

Aviation LLC

3,200 ft Yes Yes Yes Yes Yes Yes

N6521Q

Cessna

152

Alpha Wings 3,200 ft Yes Yes Yes Yes Yes Yes

N65SQ

Hawker

Beechcraft

400XP

Jet Quest

LLC

3,650 ft Yes No Yes Yes No Yes

N680AG

Cessna

680

Cronus680

LLC

3,867 ft Yes No Yes Yes No Yes

N690ES

Cessna

560

INT’L

Aviation

Sales LTD

3,160 ft Yes Yes Yes Yes Yes Yes

N691ES

Cessna

560

INT’L

Aviation

Sales LTD

3,160 ft Yes Yes Yes Yes Yes Yes

N705CG

Cessna

TR182

Turbo

Skylane

Lewis, Scott

3,200 ft Yes Yes Yes Yes Yes Yes

N708CG

Socata

TBM-699

N708CG

LLC

2,153 ft Yes Yes Yes Yes Yes Yes

N714WD

Cessna

152

Daviation Inc 3,200 ft Yes Yes Yes Yes Yes Yes

N736WH

Cessna

TR182

Turbo

Skylane

B & B Island

Aviation LLC

3,200 ft Yes Yes Yes Yes Yes Yes

N738PM

Cessna

172

Daviation Inc 3,200 ft Yes Yes Yes Yes Yes Yes

N78TT

Rockwell

690B

Cove Pointe

Air LLC

1,666 ft Yes Yes Yes Yes Yes Yes

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 18

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

N801MT

Piper PA-

32-301

JMM Air LLC 3,200 ft

Yes Yes Yes Yes Yes Yes

N821BE

Piper

Cherokee

RAS

Aviation LLC

3,200 ft Yes Yes Yes Yes Yes Yes

N8223B

Piper PA-

28RT-201

RAS

Aviation LLC

3,200 ft Yes Yes Yes Yes Yes Yes

N8333T

Piper PA-

28-161

RAS

Aviation LLC

3,200 ft Yes Yes Yes Yes Yes Yes

N88NS

Grumman

A AA-5B

Reidy, Paul 3,200 ft Yes Yes Yes Yes Yes Yes

N89SP

Piper PA-

28R-200

Sky's The

Limit Flying

Club Inc

3,200 ft

Yes Yes Yes Yes Yes Yes

N90FX

Bombardier

Globel

Express

FlexJet LLC 6,190 ft No Yes No No No Yes

N919MS

Beech A36

Bonanza

Straits, Mark 3,200 ft Yes Yes Yes Yes Yes Yes

N9311Y

Beech M35

Bonanza

Enea,

Donald J

3,200 ft Yes Yes Yes Yes Yes Yes

N94589

Cessna

152

Haverlock

Aircraft LLC

3,200 ft Yes Yes Yes Yes Yes Yes

N9609K

Piper PA-

28R-200

MDR Rental

Corp

3,200 ft Yes Yes Yes Yes Yes Yes

N9685Y

Cessna

152

Daviation Inc 3,200 ft Yes Yes Yes Yes Yes Yes

N969MG

Beech

D95A

Travel Air

RAS

Aviation LLC

3,200 ft Yes Yes Yes Yes Yes Yes

N981AG

Citation

560

Amur Eq

Finance

3,160 ft Yes Yes Yes Yes Yes Yes

N985AG

Cessna

560XL

Cosmos560

LLC

3,560 ft Yes No Yes Yes No Yes

N9877G

Cessna

172L

Skyhawk

Rowse,

Larry G

3,200 ft Yes Yes Yes Yes Yes Yes

Source: BKL Operations Data (July 2021); CHA 2022

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 19

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

Table 1-3 identifies the limitations the alternative airports may have with accepting and absorbing the operations and aircraft storage

requirements if a BKL a closure occurs. No single airport can adequately absorb all BKL operations or based aircraft.

Table 1-3. Relocation of Based Aircraft/Itinerant Users

Airport

Operations

Availability

Operation

Limitations

Current

Based

Aircraft

Fixed Base

Operator(s)

Approach

Lighting &

Navigational

Aids

Land Available for

Development

Apron

Space

(Square

Feet)*

Hangar & Tie-Down

Waitlist

CGF

CGF can

accommodate

GA corporate

operations and

would like more

business.

N/A 247

(1) Cleveland

Jet Center

Full-service

FBO

HIRL

PAPI-4

REIL

MALSR

20,000 square feet

for hangars are

available.

CGF would like to

develop the south

side of the airport.

729,441

Needs

apron

rehabilitation

Hangars are full and

may need updates.

Tie-downs have no

waitlist.

CLE

Given that CLE

is a commercial

service airport,

the amount of

GA operations

absorbed would

most likely be

limited to sports

teams.

Landing fees

apply to all aircraft

Sequencing with

commercial

aircraft may delay

operations

(1) Jets FBO

Network

(2) Atlantic

Aviation

Full-service

FBOs

ALSF-2

HIRL

PAPI-4

MALSR /

MALSF

REIL

Land and reserved

areas for future

development are

shown on ALP.

2,000,000

According to Master

Plan facility

requirements, the

FBO and CLE need

additional corporate

hangar space

LNN

LNN can

accommodate

operations.

At/Over Capacity

No Parallel

Taxiway

(1) Classic Jet

Center

Full-service

FBO

MIRL

PAPI-4

PAPI-2

REIL

Referring to the

ALP, phasing for

taxiway work and

additional hangars

are anticipated.

190,500

Tie-down space is

limited.

Hangars are at

capacity with a

waiting list.

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 20

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

LPR

LPR can

accommodate

transient

operations.

Ample Apron

Space

Not all Jet aircraft

can land at

maximum weight

due to runway

length

May have

problems

accommodating

high amounts of

Jet operations

due to facility

capacity

(1) MRK

Aviation

Full-service

FBO

MALSR

HIRL

REIL

PAPI-4

There is acreage

available for new

development.

450,000

Most hangars are

private tenants with

airport ground leases.

Both hangars and tie-

down are full and

have a waitlist.

1G5

1G5 can

accommodate

transient

Aircraft.

Apron space is

limited

No full-length

parallel taxiway

(1) Flight

Services of

Medina

Fuel and Lite

Services

Available

MIRL

PAPI-4

REIL

There is land

adjacent to current

facilities available

to be developed but

no funding

availability.

65,000

Tie-down space is

limited, but the

hangars are full.

Short-term tie-down is

available.

1G3

1G3 can

accommodate a

limited number

of piston

operations, but

its mission is

focused on

university flight

school.

Academia focus

1G3 exceeds

75,0000

operations per

year

(1) FBO

University acts

as FBO

Fuel and Lite

Services

Available

MIRL

REIL

VASI-4

Current supporting

facilities on the

property need

rehabilitation before

new land

development

occurs.

Drainage concerns

are present.

150,000

Needs

apron

rehabilitation

Hangars are at the

end of their useful life.

Any updated areas

will be used for

current academic

use.

Hangars and tie-

downs are full.

*Approximate dimension using Google Earth.

Source: Publicly available airport information; FAA 5010, September 2021; CHA 2022.

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 21

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

If BKL were to close, the activity would likely be split to neighboring airports (based on the type of

aircraft and facility offering), such as the alternative airports mentioned in the previous sections.

Activity generated by the City’s sports teams, which often use commercial service, would be

served best by CLE due to passenger processing ability and proximity to sports arenas. Jet

activity generated by BKL’s based aircraft or itinerant users would potentially transfer to airports

that could serve jet activity given service offerings (i.e., FBOs, ILS approaches, runway lengths,

etc.). The airports that could best serve jet activity from BKL include CLE, CGF, and LPR. Piston

aircraft could use any of the alternative airports given their runway length and parking

requirements; however, smaller airports that are accustomed to frequent piston aircraft activity,

including training activity, such as LNN, 1G3, and 1G5, would work best.

Although, there is adequate airfield capacity at the alternative airports, hangar and tiedown

capacity is not currently available to serve displaced users of BKL. As such, a program of hangar

and apron development would be necessary at multiple airports to prevent a significant operations

impact to current BKL users. Unfortunately, funding for aircraft hangar storage is not generally

available or adequate from FAA or ODOT, and thus could be the responsibility of the City of

Cleveland.

1.5 GRANT HISTORY AND LEASE REVIEW

1.5.1 Grant History and Federal Obligations

One potential avenue that could be undertaken to close BKL would be waiting for grant obligations

to expire, which would release the Airport from its grant assurances and federal obligations. A

prerequisite for receiving federal funds provided by the FAA is the acceptance of grant

assurances, which often span 20 years from the acceptance of a grant. However, projects may

have varying grant assurance expiration dates based on the useful life of the project as defined

by the FAA in Order 5100.38D, Change 1: Airport Improvement Program Handbook (AIP

Handbook). For example, buildings have a useful life of 40 years, pavement rehabilitation has a

useful life of 10 years, and ARFF vehicles have a useful life of 15 years. However, any

land/property acquired through federal funds or donation of land does not expire, and obligations

last in perpetuity. These grant assurances require that the Airport maintain and operate its

facilities safely and efficiently and in accordance with specific conditions outlined in the AIP

Handbook.

An assessment of all grants awarded to BKL and the City of Cleveland for the operation of the

Airport (as of October 2022) was conducted to determine when federal grants are anticipated to

expire, assuming that no additional grants are accepted. Presented in Table 1-4 is a summary of

grants awarded to BKL along with the fiscal year, grant number, total funds received, description,

and anticipated year of grant assurance expiration.

Table 1-4. Federal Grant History and Grant Assurance Expiration

Fiscal

Year

Grant

Number

Total Federal

Funds

Received

Description

Grant

Assurances

Expiration

1949

9-33-029-

4901

$100,000

Dike construction and filling of

the western side of Area B

1969

ATTY WORK PROD

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 22

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

1951

9-33-029-

5102

$245,000 Lake Hydraulic fill 1972

1957

9-33-029-

5703

$255,000

Construct and pave taxiways

and Runway 6-24

1977

1959

9-33-029-

5904

$300,000 Terminal building construction 1979

1960

9-33-029-

6005

$124,500

Construct ATCT and aircraft

parking apron

1980

1960

9-33-029-

6106

$193,230 Construct Aircraft Parking Apron 1980

1963

9-33-029-

C407

$90,000

Construct fire-crash and

maintenance building

1983

1965

9-33-029-

C608

$130,293

Extend sewers; aircraft parking

apron

1985

1966

9-33-029-

D709

$248,162

Construct, mark, and light

Runway 6L-24R, Taxiway A – E

1986

1967

9-33-029-

D810

$48,700

Expand and light connecting

taxiway

1987

1968

9-33-029-

D911

$22,189

Extend south aircraft parking

apron

1988

1969

9-33-029-

D912

$28,082

Construct and light holding

apron - east end

1989

1972

8-39-0022-

$159,900

Reconstruct portions of, overlay,

sealcoat, and mark parallel

taxiway

1992

1979

8-39-0022-

$1,440,000

Overlay, mark, and groove

runways and taxiways

1999

1982

3-39-0022-

$287,845

Overlay holding apron and

Taxiway G

1992

1993

3-39-0022-

$1,220,508

Install guidance signs and

rehabilitate the electrical system

for Runway 6R/24L and G

2008

1994

3-39-0022-

$839,700

Remove obstructions in

approach to Runway 24L and

24R

2014

1998

3-39-0022-

$1,496,180 Rehabilitate Runway 6L/24R 2008

2003

3-39-0022-

$527,448 Rehabilitate Taxiway 2013

2007

3-39-0022-

$497,648

Rehabilitate Apron, Rehabilitate

Taxiway

2017

2010

3-39-0022-

$146,249

Update Airport Master Plan

Study (Phase 1)

2030

2011

3-39-0022-

$496,508 Rehabilitate Apron 2021

2012

3-39-0022-

$1,021,152

Improve Runway Safety Area

[Environmental/Design (#16-19,

21-22)] - 06L/24R

2032

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 23

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

2012

3-39-0022-

$734,420

Improve Runway Safety Area

[Design (#16-19, 21-22)] -

06L/24R

2032

2012

3-39-0022-

$4,779,888

Improve Runway Safety Area

[Construction (#16-19, 21-22)] -

06L/24R

2032

2013

3-39-0022-

$9,775,388

Improve Runway Safety Area -

06L/24R

2033

2014

3-39-0022-

$224,068

Update Airport Master Plan

Study

2034

2018

3-39-0022-

$263,756 Rehabilitate Taxiway 2028

2020

3-39-0022-

$157,000 CARES

2024

2020

3-39-0022-

$116,735 Rehabilitate Taxiway 2030

2021

3-39-0022-

$705,787

Acquire Aircraft Fire Fighting

Vehicle

2036

2021

3-39-0022-

$34,162 CRRSA Contract Tower 2025

2021

3-39-0022-

$57,000 CRRSA Funds

2025

2021

3-39-0022-

$148,000 General ARPA

2025

Note: 1 Per FAA guidance, CARES, CRRSA, and ARPA funds only follow FAA grant assurances if used for airport development

projects. However, at a minimum, the grant assurances remain in effect for four years from the date of acceptance of the grant offer,

which is consistent with the FAA budget period.

Source: Cleveland Burke Lakefront Airport Grant Information, March 2022; CHA 2022.

After a review of federal grants awarded, no land was explicitly described as acquired by federal

donation of surplus land or grant funds. However, the first grant awarded to BKL in 1949 (9-33-

029-4901) was $100,000 in federal funds to construct a dike and fill portions of Lake Erie for the

Airport. Regarding the five early grants reviewed, any obligation to the FAA as to the projects

included in these grants is beyond the 20-year obligation timeframe; thus, it is understood that

they have expired. Noteworthy, these five grants do not describe funds to be used for the

purchase of land, which could then obligate the City to the FAA for so long as the Airport is

operational and until released from the obligation by the FAA.

Based on the grants awarded after 1949, the last expiration date of the Airport’s grant assurances

would be 2036. However, per FAA guidance, CARES, CRRSA, and ARPA funds (COVID Funds)

follow FAA grant assurances if used for airport development projects. Once COVID funds are

used, they would then follow the standard FAA grant assurances as detailed in the AIP Handbook

and as noted previously. COVID funds used to pay debt service, operation, and/or maintenance

of an airport do not follow FAA grant assurances. COVID funds also do not void preexisting grant

assurances made in prior grant agreements. For COVID funds received, at a minimum, the grant

assurances remain in effect for four years from the date of acceptance of the grant offer, which is

consistent with the FAA budget period.

The Airport would be released from its grant assurances by 2036 as no perpetual land agreements

are found to exist, no additional federal grants are accepted, and COVID funds are not used to

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 24

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

fund development projects. Presented in Table 1-5 is a summary of the unamortized federal grant

obligations at the time of the report.

Table 1-5. Outstanding Federal Unamortized Grant Obligations

Fiscal

Year

Total

Federal

Funds

Received

Description

Grant

Assurances

Expiration

Unamortized

Grant

Obligations

2010 $146,249

Update Airport Master Plan Study

[Phase 1]

2030 $43,875

2012 $1,021,152

Improve Runway Safety Area

[Environmental/Design (#16-19, 21-

22)] - 06L/24R

2032 $408,461

2012 $734,420

Improve Runway Safety Area

[Design (#16-19, 21-22)] - 06L/24R

2032 $293,768

2012 $4,779,888

Improve Runway Safety Area

[Construction (#16-19, 21-22)] -

06L/24R

2032 $1,911,955

2013 $9,775,388

Improve Runway Safety Area -

06L/24R

2033 $4,398,925

2014 $224,068 Update Airport Master Plan Study 2034 $112,034

2018 $263,756 Rehabilitate Taxiway 2028 $105,502

2020 $157,000 CARES

2024 $0

2020 $116,735 Rehabilitate Taxiway 2030 $70,041

2021 $705,787

Acquire Aircraft Fire Fighting

Vehicle

2036 $564,630

2021 $34,162 CRRSA Contract Tower 2025 $8,541

2021 $57,000 CRRSA Funds

2025 $14,250

2021 $148,000 General ARP

2025 $37,000

TOTAL $7,968,981

Source: Cleveland Burke Lakefront Airport Grant Information, March 2022; CHA 2024

Per FAA guidance, CARES, CRRSA, and ARPA funds only follow FAA grant assurances if used for airport development projects.

However, at a minimum, the grant assurances remain in effect for four years from the date of acceptance of the grant offer, which is

consistent with the FAA budget period.

1.5.2 State Grant History and Obligations

Upon execution of a state grant provided by ODOT, like federal grants, standard assurances are

incorporated and become part of the grant contract. Pursuant to the ODOT grant program, the

airport sponsor guarantees the compliance of seventeen grant assurances. In particular, the ones

associated with an airport closure are grant assurances 9 and 10. Grant assurances 9 and 10

require an airport to pay back the total amount of ODOT funds received either for facilities or

equipment if within 20 years from the date of the grant contract. For the release of real property

acquired by way of an ODOT grant, the airport sponsor agrees to return the appraised fair market

value at the time of sale.

ODOT grants are only available to non-primary general aviation airports that do not receive FAA

Air Carrier Enplanement funds. As BKL has had periods in which air carrier service was

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 25

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

unavailable, ODOT grant availability/history only includes three grants. At the time of this report,

BKL does not have air carrier service. If this were to continue and BKL were to accept future

ODOT grants, payback would be required if within 20 years of closure. A history of ODOT grants

received is provided in Table 1-6, including the grant assurance expiration date. If BKL does not

accept additional ODOT grants, grant assurances are set to expire in 2039. If the Airport were to

close prior to 2038-2039, it would owe approximately $1.5 million for grants received from ODOT.

Table 1-6. ODOT Grant History and Assurance Expiration

Fiscal

Year

ODOT Project

Number

Total ODOT

Funds

Received

Description

Grant

Assurances

Expiration

2018 18-03 $601,296

Pavement: Rehab RW 6R-

24L, Phase I

2038

2019 M19-14 $15,992 Rehabilitate Taxiway 2039

2019 19-04 $850,803

Pavement: Rehabilitation of

RW 6R/24L, Phase II

2039

TOTAL $1,468,091

Source: Ohio Department of Transportation (ODOT), September 8, 2022.

1.5.3 Lease Review

A review of the current lease structure at BKL was completed to determine

challenges that could occur from the closure of BKL prior to their expiration.

Signature serves BKL as the single FBO but has two separate leased areas. Signature subleases

the easternmost hangar and adjacent office space to the Aitheras Aviation Group. According to

Signature, that lease is set to expire at the end of 2022. The second lease, which is set to expire

in 2043, covers the ground lease for their new FBO facility constructed in 2016 and the old FBO

hangar located to the east of the existing FBO. At the expiration of the ground lease, the buildings

and improvements not owned by the City on the leased property revert to the City.

1.6 AIRPORT CLOSURE OPTIONS

The preceding sections laid the groundwork for determining routes the Airport could take to close

the Airport if chosen as the preferred alternative in the ALP update. A thorough review of the

Airport environment, stakeholder interviews, past airport closures, alternative airport capacity, and

federal and state requirements is critical to inform future decision-making. Each closure option is

presented with potential opportunities and constraints that may occur if chosen as a closure

option. It shall be noted that additional unforeseen challenges may be present no matter the

TRADE SECRET

ATTY WORK PROD

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 26

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

closure option since an airport closure is rare due to logistical complications, legal hurdles, and

financial implications.

1.6.1 Option 1 – Wait Out Grant Obligations

At a minimum, BKL is federally obligated to remain operational until the expiration of federal grant

assurances in 2036. ODOT grant assurances don’t preclude the airport closure, but any

outstanding grants would require payback for funds received if less than 20 years of grant

contract. The federal grant expiration date of 2036 is contingent on the Airport having no perpetual

land grant assurance agreements and not accepting additional federal funds for improvement and

maintenance of the Airport after grant 3-39-0022-20. The city would have to continue to pay for

all operational and maintenance costs for BKL for 14 years to ensure compliance with federal and

state requirements, in which a yearly budget deficit at the Airport already exists. Based on annual

operations & maintenance budget, additional expenditures are projected to cost $2,500,000

million over 14 years until closure in 2036 (not adjusted for inflation). This does not account for a

rehabilitation of Runway 6L-24R that will most likely be needed before 2036. Historical airport

closures have shown that once the expiration of federal grant assurances occur, only a 30-day

notice to the FAA is required to legally close the airport. However, as previously mentioned, this

assumes no airport property is federal obligated without expiration. Early coordination with the

FAA should be undertaken to confirm expiration of grant assurances

Although grant assurances could expire in 2036 for federal grants and 2039 for state grants, that

does not supersede the city’s legal obligations .

. Determining the extent of legal

actions that the Airport would be subject to is not possible; however, going through the legal

process would require a financial commitment and could delay the closure of the airport.

TRADE SECRET

ATTY WORK PROD

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 27

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

Table 1-7. Wait Out Grant Obligations – Opportunities and Constraints

Opportunities

Constraints

 Waiting provides a legal means to

close the Airport without federal

action (executive or legislative).

 If the land is not considered a

perpetual agreement, closure would

only require a 30-day notice to the

FAA once grant assurances expire

in 2036.

 Waiting would not require providing

documentation of a net benefit to

aviation.

 The Airport would be required to wait

14 years until 2036 to close.



 The Airport would be required to pay

back ODOT grants received before the

20-year assurance expiration ($1.5

million).

 The City of Cleveland would be

responsible for the development,

repair, and maintenance of BKL

without federal and/or state assistance

through 2036.



1.6.2 Option 2 – Apply to FAA for Closure

An airport sponsor can apply and seek approval at any time to close an airport. FAA approval

would require that the airport prove a net benefit to the aviation system, not the economic benefit

of the community. In part, this report and the analysis performed in the alternative capacity

evaluation show that other airports within the region can support activity transferred from BKL if

future corporate hangar, T-hangar, and apron development were to take place to accommodate

users. Although other airports (CLE, CGF, LNN, 1G3, 1G5, and LPR) can support activity from

BKL, given their existing capacity and potential for additional development to support additional

activity, the FAA could determine that there is no substantial net benefit to the aviation system.

Moreover, the FAA designates BKL as a regional GA due to its support to the regional airport

system and high activity levels and existing available facilities. Other GA alternative airports (LNN,

1G3, 1G5, and LPR) would require new aircraft storage facilities and support for higher activity

levels than BKL to show a net benefit.

In addition, the Airport would be required to pay all unamortized federal grants that have not

reached their useful life or the 20-year timeline for most projects. For state grants, closure before

2038-2039 would amount to approximately $1.5 million. Ultimately, if chosen as an option, the

amortized amount would depend on the closure date and the outstanding grant obligations. At

the time of this report, the federal grant repayment amount would be approximately $10 million.

Although this option could be pursued at any time, it is unlikely to succeed, as the FAA strongly

discourages the closure of airports. Furthermore, with the infrastructure provided by BKL, the

TRADE SECRET

ATTY WORK PROD

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 28

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

Airport’s importance to the region, use level, and capacity, demonstrating a net benefit to civil

aviation would be a challenge.

Table 1-8. Apply to FAA for Closure – Opportunities and Constraints

Opportunities

Constraints

 The application for closure can be

submitted to the FAA for approval at

any time.

 The Airport would be required to pay

unamortized amounts of outstanding

federal grant obligations ($7.9 million

at the time of this report).

 The Airport would be required to pay

back ODOT grants received before the

20-year assurance expiration ($1.5

million).

 Additional financial commitment may

be required to improve alternative

airports to show net benefit to civil

aviation.



1.6.3 Option 3 – Federal Legislation

Pursuing federal legislation through the U.S. Congress can be a means to bypass FAA

requirements to close an airport. Working with the legislative branch of the government, legislation

can be passed directing the FAA to close the Airport.

TRADE SECRET

ATTY WORK PROD

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 29

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

Table 1-9. Federal Legislation – Opportunities and Constraints

Opportunities

Constraints

 Federal legislation can be submitted

for approval at any time.

 This option can be used to bypass

FAA requirements for closing an

airport.

 Could eliminate the cost of federal

grant payback.

 This option requires substantial

support from elected representatives.



 The Airport would be required to pay

back ODOT grants received before the

20-year assurance expiration ($1.5

million).

1.7 FINANCIAL ANALYSIS

As part of the closure alternative investigation, a financial analysis was conducted by

JacobsenDaniels (JDA). The complete financial report examining the financial impact of closing

BKL is included in This section includes a high-level examination of the

financial impacts of closing BKL:

 Elimination of operating and maintenance expenses

 Lease buyout impacts

 Grant assurance-related costs

 Debt service

1.7.1 BKL Economic Impact

BKL was included in the 2014 ODOT Office of Aviation Ohio Airports Economic Impact Study,

which measured the value provided by airports and aviation-related activities in Ohio. The study

showed how aviation helps Ohio’s economy and many other benefits provided by the state’s

system of airports. The study included 104 airports and found that, in 2013, these airports

supported nearly 123,500 jobs, generated nearly $4.2 billion in annual payroll, and produced more

than $13.3 billion in annual economic output.

TRADE SECRET

ATTY WORK PROD

TRADE SECRET

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 30

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

BKL is classified in the study as a GA Level 1 Airport, which is the highest level of general aviation

airport (one step below air carrier) and defined as airports that “are intended to meet nearly all

the needs of general aviation turbine powered aircraft, including corporate jet aircraft, and their

users. This facility classification can also support recreational general aviation activities and flight

training.” According to the report, BKL’s total economic impact supported 953 jobs, generated

nearly $34.5 million in annual payroll, and produced approximately $107 million in annual

economic output.

1.7.2 Financial Performance

Utilizing data provided by the City of Cleveland, the following subsections provide an overview of

BKL’s overall financial situation, revenue generation, general operating expenses, staffing, and

debt service.

1.7.2.1 Overall Financial Performance

BKL does not generate the level of revenues produced by commercial service airports (i.e.,

terminal fees, landing fees, concessions, vehicular parking, rental cars, etc.). On a standalone

basis, BKL typically operates at an annual loss, as shown in Table 1-10. As shown in the latest

available audited data from 2015 to 2021, BKL recorded an average annual loss of approximately

$0.9 million. The net losses at BKL are generally included as an expense line item in calculating

airline rates and charges for commercial airlines operating at CLE. In terms of employees, BKL

indicated that they employ 15 City of Cleveland staff members as of August 2022 (this does not

include the employment of airport businesses):

 Four (4) Airport Maintenance Employees

 Three (3) Airport Operations Agents II

 Two (2) Airport Operations Agents I

 Two (2) Custodial Employees

 One (1) Airport Operations Superintendent

 One (1) Heavy Duty Mechanic

 One (1) Administrative Manager

 One (1) Electrical Employee

Table 1-10. BKL Revenues and Expenses

Year

2015

2016

2017

2018

2019

2020

2021

Revenues

Concessions

$774 $795 $603 $896 $713 $180 $562

Rentals

$361 $402 $487 $330 $407 $421 $488

Landing Fees

$154 $185 $190 $190 $170 $100 $211

Other

$101 $221 $211 $241 $219 $181 $244

Total Revenues

$1,390

$1,603

$1,491

$1,657

$1,509

$882

$1,505

Expenses

Salaries and

Wages

$926 $950 $683 $896 $866 $845 $1,365*

Employee

Benefits*

$370 $352 $367 $260 $284 $308 -

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 31

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

City Central

Services

$406 $472 $298 $250 $230 $426 $125

Materials and

Supplies

$239 $385 $298 $251 $230 $426 $191

Contractual

Services

$629 $526 $311 $486 $553 $403 $711

Total Operating

Expenses

$2,570 $2,685 $1,957 $2,143 $2,163 $2,408 $2,392

Net

Surplus/(Deficit)

($1,180) ($1,082) ($466) ($486) ($654) ($1,526) ($887)

*Employee Benefits were a separate line item until 2021, when the audit combined them with Salaries and Wages.

Sources: City of Cleveland, Ohio Department of Port Control Divisions of Cleveland Hopkins International and Burke Lakefront

Airports, Report on Audit of Financial Statements, years ending December 31, 2015 to 2021.

1.7.2.2 Revenue Generation

BKL staff provided additional information regarding the Airport’s revenue streams, as shown in

Figure 1-2. It should be noted that the categories provided in this report differ from those in the

audited financial statements. Revenues generated by the Airport include the following:

 Airline revenues, which include landing fees and terminal rentals

 Non-airline revenues, which include rental car revenues, concession revenues, security

badging fees, space rental/fees, special event fees, and utility reimbursement

 Parking and roadways, which includes automobile parking, employee parking, rideshare

fees, and commercial vehicle fees

 Airfield area, which includes fixed base operators, fuel flowage fees, in-flight catering,

hangars and other areas, and utility reimbursement/other

Most revenues generated by the Airport have historically been parking and roadways, primarily

automobile parking, which typically accounts for approximately 40% of all airport revenues. The

second largest revenue stream has historically been non-airline revenues, accounting for

approximately 29%, mainly space rentals and fees. Airfield area fees, mostly FBO and fuel

flowage fees, normally account for approximately 19% of revenues. Lastly, airline revenues,

mainly landing fees, typically account for approximately 13% of all revenues.

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 32

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

Figure 1-2. Airport Revenues

Source: BKL Financial Data Request Form 2015-2022 YTD (as of June 2022)

1.7.2.3 Airport General Operating Expenses

Each fiscal year, the City of Cleveland publishes its budget to include the Division of Airports,

Airport General Operations, which covers BKL expenses. The budget is divided into the following

categories:

 Other Training and Professional Dues, which includes dues, subscriptions, and travel

 Utilities, which includes gas, water, and electricity

 Contractual Services, which includes professional services

 Materials and Supplies, which covers a variety of equipment and supplies needed for the

Airport

 Maintenance, which includes equipment, vehicles, and tools

 Interdepartmental Service Charges, which includes charges from water, property, and

waste collection

$1,389,808

$1,602,796

$1,490,623

$1,657,118

$1,537,798

$890,784

$1,513,902

$575,768

$200,000

$400,000

$600,000

$800,000

$1,000,000

$1,200,000

$1,400,000

$1,600,000

$1,800,000

$2,000,000

2015 2016 2017 2018 2019 2020 2021 2022 YTD

Total Airline Revenues Total Non-Airline Revenues Total Parking and Roadways

Total Airfield Area Total Airport Revenues

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 33

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

The total budgeted amount and actual expenditures for each category can be found in

Most expenditures have historically been from utilities (normally 44%);

however, in 2021, interdepartmental service charges accounted for 51% of expenditures.

Materials and supplies generally account for 19% of actual expenditures, followed by

maintenance and contractual services at 15% and 10%, respectively. Other training has

accounted for less than 1% of total actual expenditures.

1.7.2.4 Debt Service

The City of Cleveland has no outstanding general obligations bonds used in part to fund airport

improvements at BKL or the airport system. However, BKL staff indicated that there is an airport

system revenue bond debt outstanding of approximately $650,000 related to the installation of an

ILS, master plan and environmental study, HVAC upgrade, and overlay of Runway 6L-24R, which

were completed in approximately 1999. A portion of these project costs was financed with the

proceeds from the City of Cleveland, Ohio, Airport System Revenue Bonds Series 1997, and the

$650,000 of total remaining debt service will be paid off in the next few years.

1.7.3 Airport Leases

The city provided lease information for BKL

, separated by the city as a Lessee and the City as

the lessor. Four Lake Erie Submerged Land Leases (SLL) are related to BKL.

1.7.3.1 City as a Lessee

Three of the SLLs are between the city and the State of Ohio (State) through its Department of

Natural Resources. They are to lease and use submerged lands and artificially filled areas of Lake

Erie for all purposes in support of BKL airport operations. The SLLs are listed in Table 1-11.

Table 1-11. BKL Submerged Land Leases

File Number

Term

Rent/Consider

ation

SUB-428-CU

(use of 4 submerged water intake

systems owned by the city)

11/1/85-10/31/35

Option to renew for 50 years;

allows for assignment of lease to

purchaser of the

adjoining/upland property.

$1.00/year

SUB-0514-CU

(lease of submerged land for

airport expansion and confined

disposal facility)

8/1/92-7/31/42

$1.00/first 5 years;

thereafter

recalculated

pursuant State law

SLL SUB-0546-CU (replaces lease SUB-0546-CU dated 10/24/91) relates to a lease of submerged lands for a floating restaurant

and parking. The parties to this SLL are the State of Ohio and Hornblowers Limited Partnership. The term of the SLL is 10/01/01-

9/30/51 with ability to apply for new lease. Also, the lessee has the option to terminate the SLL pursuant to the lessee’s requested

termination agreement. Rent under this SLL is $758.00/first 5 years for the floating restaurant and parking area; thereafter rent is

recalculated pursuant to State law. While the City is not a party to this SLL, this SLL is noted given that the filled areas contiguous to

BKL.

TRADE SECRET

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 34

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

SUB-0070-CU

(lease of submerged land for

development including

Aeronautical Facilities, as defined

in the lease)

6/1/14-5/31/2113

Two (2) 50-year renewal options;

the City has option to terminate

pursuant to City’s requested

termination agreement.

Base rent pursuant

to State law

Sources: BKL and CHA

The SLLs obligate the City to provide rental payment to the State of Ohio per the rental terms of

each lease. SLL SUB-0070-CU includes a provision allowing the City to terminate the lease before

lease expiration subject to a lease termination agreement between the State and the City. The

other two SLLs do not include a similar lease termination option for the city. While SLL SUB-428-

CU does not include the City’s option to terminate the SLL per a lease termination agreement with

the State, in the event of a sale of the adjoining/upland property, it does allow for the City to apply

to the State to assign the SLL to the purchaser of the adjoining/upland property. Given that the

lessor is the State of Ohio, each SLL reserves to the State its right of eminent

domain/condemnation pursuant to State law.

BKL is built entirely on artificially filled areas of Lake Erie. SLL SUB-0514-CU only covers the

northern half of the airport property; therefore, the City is currently preparing an application to

encumber the remaining airport property under another SLL. Given that BKL completely operates

on filled areas of Lake Erie, the SLLs are understood to be necessary to establish the apparent

rights of the City regarding its specific interest in the property of BKL. The SLLs establish the

City’s interest in and over the filled areas of BKL as leasehold or ownership interest in the actual

filled areas, with the State of Ohio holding trust in the waters of Lake Erie and the land underneath

the lake, which would include the land under the artificially filled areas that makes up the airport

property for purposes of BKL

1.7.3.2 City as a Lessor

Leases held by the City as the lessor primarily relate to the lease of space or use of space at BKL,

including office space in the BKL terminal and lease of real property. Some lease agreements are

captioned as “Lease by Way of Concession,” which include the lease of terminal space or allow

an airport operation activity with the requirement of payment by the lessee/tenant to the city. Some

leases are between the City and another governmental entity. A number of these leases have

expired, and to the extent a lessee has not vacated leased premises under an expired lease, the

lessee can generally be considered under lease on a month-to-month basis or a holdover tenant.

In these instances, notice to the holdover tenant from the city can be provided for the lessee to

In the executed Addendum to the Cooperative Agreement for Harbor Services between City of Cleveland

and Port Authority entered into March 1, 2013, Port Authority agreed the City is the littoral landowner: The

City hereby designates the Port Authority to act as its representative, at no cost to the City, in dealings with

the U.S. Army Corps of Engineers (“Army Corps”) and other interested parties with respect to the

improvement, operation and maintenance of the Confined Disposal Facilities (CDF’s) located immediately

north of Burke Lakefront Airport (“BKL”) owned by the City as littoral landowner and tenant under a

submerged land lease with the State of Ohio (SUB0514-CU), including the signing of any right-of-entry or

other agreements on behalf of the City with the Army Corps related to the CDF’s.

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 35

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

vacate the premises. Thirty-seven (37) leases were provided for review and are shown in

As noted above, several leases appear to be expired, or it is currently unknown if the city has

exercised option periods. If lessees remain in the leased space and the lease is expired, efforts

can be made to have the lessee vacate the premises.

For those leases that remain current, primarily the FBO lease, if the city seeks to terminate the

leases, efforts can be made to seek an agreement with the current lessee to vacate the leased

premises with a likely lease buyout by the city. For the purposes of early lease termination by the

city, Signature Flight (successor to Burke Lakefront Services/Landmark/Millionaire for operations

under the BKL FBO agreements) recently undertook improvements at the Airport, including the

construction of a new hangar facility with investments costing approximately $16 million. The FBO

investment costs would need to be addressed should the city proceed with a termination of the

FBO lease.

In addition, an FAA Memorandum of Understanding (MOU) for the Airport’s navigational aids

(NAVAIDs) is effective through 2062. It is understood that recent improvements to the airfield

systems were undertaken at FAA’s cost as part of the Runway 6L-24R Safety Area Improvement

project completed in 2012. The FAA’s costs related to recent airfield system improvements would

need to be addressed should the city proceed with a termination of the FAA MOU.

1.7.3.3 Terminal Office Space Leases

In addition to the lease review, BKL provided the most recent rent roll from 2018 through a

Terminal Building Lease analysis, as shown in Table 1-12. It should be noted that Ultimate Air

ceased operations during the pandemic and is no longer located at BKL.

Table 1-12. 2018 Extracted Rent Roll

Room

Tenant Name

Vacant

Spaces

Monthly Lease

Annualized

Income

105 KAZ Radio N/A $162.50 $2325.00

106-106A CPD Aviation Unit N/A $1,500.00 $8,092.00

115-116 MarKenCami, LLC N/A $238.75 $6,864.00

127 Ultimate Air – Office* VACANT $0 $0

150

Ultimate Air – Passenger

Lounge*

VACANT $0 $0

151

Ultimate Air –

Concourse*

VACANT $0 $0

149-152 Zone Aviation N/A $1,948.33 $23,958.00

161 Weather Forecast N/A $288.17 $4,256.00

162 Top Gun N/A $256.25 $3,280.00

165-169 &

179

IWASM Offices N/A $2,665.10 $38,992.00

166 Cleveland Air Show N/A $1,573.25 $26,652.50

174 CBP N/A - $8,721.00

178-194

CPD Hit Skip – Accident

Investigation

N/A $1,724.91 $14,352.00

180 VACANT VACANT $0 $0

181 CPD N/A - $10,448.00

TRADE SECRET

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 36

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

182 Wargo Law Office N/A $696.00 $8,347.00

184 T&G Flying Service N/A $1,681.33 $27,160.00

189

CPD Employee

Assistance

N/A - $8,944.00

193

CPD Employee

Assistance

N/A $291.66 $4,480.00

200 CHA Consulting, Inc. N/A $5,800.00 $71,775.00

220 VACANT VACANT $0 $0

TOTAL

$23,347.59

$322,902.50

*Note: Ultimate Air ceased operations in 2021 so it is assumed that their spaces are vacant.

Source: Burke Lakefront Terminal Building Lease Analysis (O. R. Colan Associates, 2018)

1.7.4 Financial Impacts of Closing BKL

The financial impacts of closing BKL are derived from a review of airport finances, including

revenues and expenditures, as well as reviewing leases, grants and assurances, and other

information provided by the Airport. The overall financial impacts include:

 Reduction of costs and loss of revenues: BKL recorded an average annual loss of

approximately $0.9 million from 2015 to 2021, which is included as an expense line for

CLE. Assuming BKL would continue to operate with a net negative financial statement in

the future, closing BKL would eliminate this financial burden. Some costs associated with

labor could be expected to remain within the Department of Port Control, as BKL staff may

be relocated to CLE, slightly reducing the amount of savings. However, the overall impact

would be positive from a cost vs. revenue perspective. In addition, removing the BKL

operating loss from CLE could potentially lower CLE rates and charges, as the need to

recover these costs from the airlines will no longer be needed.

 SLLs: One SLL includes a termination provision, while the other two do not. Terminating

these leases would require coordination with the State of Ohio since each SLL reserves

to the State its right of eminent domain/condemnation pursuant to State law. Though not

specified, there may be costs associated with terminating the SLLs (i.e., cost of outside

legal support, consultants, etc.). The existing SLLs have land use restrictions on them, as

only airport operations or CDF operations are permitted.



 Reimbursements to FAA: Receiving grants from the FAA typically requires a 20-year

obligation commitment. However, projects may have a different obligation period based

on their useful life. Based on the grants awarded after 1949 and the 20-year assumption,

the last date of expiration of the Airport’s grant assurances would be 2036. Unamortized

grant obligations are approximately $7.9 million.

 Reimbursements to ODOT: Based on the three grants from ODOT and the 20-year

assumption, the last date of expiration of the Airport’s grant assurances would be 2039.

Grant obligations of approximately $1.5 million would need to be reimbursed if the Airport

closed before this date.

 Cost of coordinating the closure: While this amount cannot be quantified now,

coordinating the cost of closure would require potential legal fees, staff time, consultant

fees, etc.

TRADE SECRET

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 37

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

 Cost of physically closing the Airport: This cost requires pavement removal,

restoration, and building demolitions at a minimum and may require additional costs for

altering lighting, signage, and relocation and/or disconnection of facilities. CHA provided

cost estimates which total $15.3 million.

1.7.5 Financial Summary

When evaluating closing BKL, there are many factors to consider. Table 1-13 summarizes the

opportunities and constraints associated with closing BKL.

Table 1-13. Opportunities and Constraints Associated with Closing BKL

Item

Cost of Closing

Airport Operations

 Relocation of approximately 40,000 operations and 35 based

aircraft

 Potential revenue generation at CLE for any operations and

based aircraft that relocate there

Economic Impact

 According to the 2014 ODOT Office of Aviation Ohio Airports

Economic Impact Study, BKL’s total economic impact supported

953 jobs, generated nearly $34.5 million in annual payroll, and

produced approximately $107 million in economic input. These

economic impacts would be lost.

Financial Impacts

 Net gain to the City since BKL is operating at a deficit and

compensated as an expense item at CLE

Submerged Land

Leases

 Potential costs associated with terminating SLLs

 Would involve coordination with the State

Terminating

Leases



Reimbursements

to FAA

 Portion of reimbursements of approximately $7.9 million for

closing BKL within a 20-year grant obligation timeframe

Reimbursements

to ODOT

 Approximately $1.5 million for closing BKL within a 20-year grant

obligation timeframe

Coordinating the

Closure

 Costs associated with potential legal fees, staff time, consultant

fees, etc.

TRADE SECRET

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 38

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

Physically Closing

the Airport

 Costs associated with building demolition of approximately $4.5

million

 Costs associated with pavement removal of approximately $7.6

million

 Contingency costs for additional unknowns of approximately

$2.4 million

 Total costs of approximately $15.3 million (refer to

Sources: CHA and Jacobsen|Daniels, 2022

1.8 CONCLUSIONS

Closing of a public-use federal obligated airport is possible, but the process is intricate as most

airports have accepted federal funds to develop the airport and keep it operating safely. If the City

of Cleveland decides to close BKL, one of the three options discussed in Section 1.6 may be

selected as the preferred method of closing. According to FAA Order 5190.6B, Section 22.20, an

airport sponsor may request the release of obligations for an entire airport; however, the FAA

Associate Administrator for Airports (ARP-1) concurrence is required before granting any release

that would enable the disposal of an entire airport for non-aviation purposes. In addition, each

request to release an entire airport is considered by ARP-1 on a case-by-case basis and at the

complete discretion of ARP-1.

 Title 49 United States Code 46319 states that a public agency (as defined in section

47102) may not permanently close an airport listed in the NPIAS under section 47103

without providing written notice to the Administrator of the FAA at least 30 days before the

date of the closure. The FAA will take into consideration factors such as the following:

 Past and present owner’s compliance record under all its airport agreements and its

actions to make available a safe and usable airport for maximum aeronautical use by the

public

 Evidence that the owner has taken or agreed to take all actions possible to correct

noncompliance situations at the airport

 Reasonableness and practicality of the owner’s request in terms of aeronautical facilities

that are needed and the priority of need

 Net benefit to be derived by civil aviation and the compatibility of the proposal with the

needs of civil aviation

 Consistency with the guidelines for specific types of releases

Advantages and disadvantages are discussed in the following subsections to assist the City of

Cleveland in deciding whether to close BKL or not.

1.8.1 Advantages to Closing BKL

1.8.1.1 Allows the Port Authority and USACE to operate autonomously without FAA oversight

According to the Port Authority, the Cleveland Harbor supports $3.5 billion in annual economic

activity, provides 20,000 jobs, and manages more than 13 million tons of cargo. Cleveland Harbor

is a hub for international and Great Lakes maritime commerce, is critical to the State’s economy,

and, as the 45th largest port in the nation, is a critical supply chain hub of the United States. The

TRADE

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 39

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

Cuyahoga River and Cleveland Harbor are dredged twice a year to sustain commercial

navigation. This dredge operation collects material (silts and sands) that is deposited over time

into the navigation channel in the river and the harbor entrance. The Port of Cleveland’s Sediment

Processing & Management Facility (SPMF), which is operated on the surfaces of Confined

Disposal Facilities (CDFs) 9, 12, and 10B (future), is vital in sustaining navigation within the

harbor. The USACE has identified these CDFs (located on and adjacent to BKL property) as the

only short- and medium-term solutions within Cleveland Harbor to facilitate the upland

management of dredge sediment as part of their Dredge Material Management Process. The

USACE would also like to enter into a multi-year placement agreement with the Port Authority for

the continued operation of the SPMF (a 217 agreement referencing the specific provision of the

Water Resources and Development Act enabling such agreements). Without the operation of the

Port Authority’s facility, the USACE would be unable to fulfill its federal obligation, thus putting the

harbor, maritime commerce, and the thousands of jobs that rely upon the timely dredging of the

harbor at risk.

In March 1972, the City of Cleveland passed Ordinance Number 653-71, authorizing the City of

Cleveland, Director of Port Control to accept a permit from the USACE that authorized the

construction of a bulkhead to enclose the open water of Lake Erie on the eastern side of BKL,

which ultimately become CDF 12. Since then, for reasons unknown, that property has been shown

on the BKL property map as “federally obligated airport property.” The Port Authority currently

operates the SPMF on the surfaces of the CDFs under historic agreements with the City of

Cleveland and the USACE. More specifically, the Harbor Services Agreement and the Port

Authority’s local sponsorship agreement with the USACE for the construction, operation, and

maintenance of CDF 12. To enter into a multi-year capacity placement agreement with the

Federal Government (217 agreement), the Port Authority needs certainty on access, land use,

capital infrastructure investments, risk mitigation, and the ability to operate uninterrupted for the

term of the 217 agreement. Keeping the SPMF as a non-aeronautical operation on Airport

obligated property under FAA approval results in the following impacts on the Port Authority:

 Airport lease agreements contain terms incompatible with the proposed 217 agreement

and the historic agreements in place for the construction, operation, and maintenance of

the CDFs

 Airport lease agreements contain non-aeronautical rent terms for sustained access and

use of CDFs

 Irreconcilable permit and regulatory environment that limits the Port Authority’s ability to

plan into the future and make timely capital investments (USACE 408 Authorizations &

On-Airport 7460 Airspace Determinations)

 Increased safety and operational risks resulting from combined land use (aeronautical and

CDF)

 Preserves the current state of maritime use of CDFs as an optional non-aeronautical

construction project within the Airport that is inconsistent with existing submerged land

leases, which attempt to create parity between aviation and maritime land use.

 The inability of Port Authority to directly communicate with FAA

 Operational uncertainty, which leads to price volatility and increased costs

According to the Port Authority, the long-term operation of the CDFs within the Airport limits on

obligated Airport property is unsustainable, specifically with the direction the USACE wants to

head with establishing a multi-year 217 Agreement. A BKL closure would allow the Port Authority

AIRPORT LAYOUT PLAN (ALP) UPDATE NARRATIVE REPORT

PAGE 41

BURKE LAKEFRONT AIRPORT | AIRPORT CLOSURE ALTERNATIVE

1.8.2.2 Reimbursements to FAA & ODOT

As stated previously, a prerequisite for receiving federal funds provided by the FAA is the

acceptance of grant assurances which often span 20 years. These grant assurances require that

the airport maintain and operate its facilities safely and efficiently and in accordance with specific

conditions outlined in the AIP Handbook. The assessment of all grants awarded to BKL and the

City of Cleveland for the operation of the Airport (as of October 2021) was conducted to determine

when federal grants are anticipated to expire with the assumption that no additional grants are

accepted. In addition, a state grant analysis was conducted. If the City decides to close BKL and

apply for closure in 2022 (Option 2), approximately $9.3 million would have to be paid back to the

FAA and ODOT.

1.8.2.3 Ongoing Maintenance Responsibility

If the City chooses to close BKL but wait out grant obligations (Option 1), the Airport would be

required to remain operational until the expiration of federal grant assurances in 2036. ODOT

grant assurances do not preclude the Airport closure, but any outstanding grants would require

payback for funds received if less than 20 years of the grant contract. Under this option, the city

would have to pay for all development and maintenance costs at BKL for 14 years to ensure

compliance with federal and state requirements. Based on the annual operations and

maintenance budget, additional expenditures are projected to cost $2.5 million over 14 years until

closure in 2036. This amount does not account for a rehabilitation of Runway 6L-24R that will

most likely be needed before 2036, which could be an additional $2.5 million.

1.8.2.5 Costs to Demolish Airport Facilities

There would also be a cost to demolish existing airport facilities. To develop the site for an

alternative land use, all runway, taxiway, and apron pavement would be removed and restored

with fill material and grass. In addition, all existing buildings would be demolished. These costs

are estimated at $15.3 million . The city may also need to financially support

development of replacement facilities (e.g. hangars) at alternate airports, which has not been

determined or quantified but would be negotiated with FAA during the closure process.

1.8.2.6 Potential Legal Actions

Past airport closures have involved various legal actions/lawsuits by airport user and associated

groups. While it is not known what actions would be taken against the city, history has shown this

to be a likely, costly, and time-consuming possibility.

TRADE SECRET

www.chasolutions.com

Total Number of Redactions in Document: 42

Redaction Reasons by Page

Page

Reason

Description

Occurrences

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

ATTY WORK

PROD

The records were redacted as attorney

work product under Stanton v. University

Hospitals Health Systems, Inc. 166 Ohio

App.3d 758 (Eighth App. Dist. 2006).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

ATTY WORK

PROD

The records were redacted as attorney

work product under Stanton v. University

Hospitals Health Systems, Inc. 166 Ohio

App.3d 758 (Eighth App. Dist. 2006).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

ATTY WORK

PROD

The records were redacted as attorney

work product under Stanton v. University

Hospitals Health Systems, Inc. 166 Ohio

App.3d 758 (Eighth App. Dist. 2006).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

ATTY WORK

PROD

The records were redacted as attorney

work product under Stanton v. University

Hospitals Health Systems, Inc. 166 Ohio

App.3d 758 (Eighth App. Dist. 2006).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

ATTY WORK

PROD

The records were redacted as attorney

work product under Stanton v. University

Hospitals Health Systems, Inc. 166 Ohio

App.3d 758 (Eighth App. Dist. 2006).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

ATTY WORK

PROD

The records were redacted as attorney

work product under Stanton v. University

Hospitals Health Systems, Inc. 166 Ohio

App.3d 758 (Eighth App. Dist. 2006).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

Redaction Date: 9/16/2024 10:52:51 AM

Redaction Log

Page

Reason

Description

Occurrences

ATTY WORK

PROD

The records were redacted as attorney

work product under Stanton v. University

Hospitals Health Systems, Inc. 166 Ohio

App.3d 758 (Eighth App. Dist. 2006).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

ATTY WORK

PROD

The records were redacted as attorney

work product under Stanton v. University

Hospitals Health Systems, Inc. 166 Ohio

App.3d 758 (Eighth App. Dist. 2006).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

ATTY WORK

PROD

The records were redacted as attorney

work product under Stanton v. University

Hospitals Health Systems, Inc. 166 Ohio

App.3d 758 (Eighth App. Dist. 2006).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

ATTY WORK

PROD

The records were redacted as attorney

work product under Stanton v. University

Hospitals Health Systems, Inc. 166 Ohio

App.3d 758 (Eighth App. Dist. 2006).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

Redaction Date: 9/16/2024 10:52:51 AM

Redaction Log

Redaction Reasons by Exemption

Reason

Description

Pages

(Count)

5(1)

29(2)

31(2)

8(1)

ATTY WORK PROD

The records were redacted as attorney work

product under Stanton v. University

Hospitals Health Systems, Inc. 166 Ohio

App.3d 758 (Eighth App. Dist. 2006).

2(1)

6(1)

24(2)

4(1)

8(1)

28(2)

29(2)

30(1)

31(2)

32(1)

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

2(1)

3(1)

4(1)

5(1)

6(2)

8(1)

13(2)

28(2)

29(2)

30(1)

31(3)

32(2)

43(2)

44(1)

Redaction Date: 9/16/2024 10:52:51 AM

Redaction Log

Total Number of Redactions in Document: 8

Redaction Reasons by Page

Page

Reason

Description

Occurrences

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

Redaction Date: 9/16/2024 11:26:20 AM

Redaction Log

Redaction Reasons by Exemption

Reason

Description

Pages

(Count)

41(1)

5(1)

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

32(1)

36(1)

38(1)

41(1)

44(1)

5(1)

Redaction Date: 9/16/2024 11:26:20 AM

Redaction Log

Total Number of Redactions in Document: 4

Redaction Reasons by Page

Page

Reason

Description

Occurrences

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

Redaction Date: 9/16/2024 12:09:24 PM

Redaction Log

Redaction Reasons by Exemption

Reason

Description

Pages

(Count)

14(1)

TRADE SECRET

Records constituting “trade secrets” have

been withheld under O.R.C. 1333.61(D).

14(1)

39(1)

40(1)

Redaction Date: 9/16/2024 12:09:24 PM

Redaction Log