From: Kaplan, Rob <[email protected]>
Date: Sat, May 30, 2026 at 3:37 PM
Subject: [BoulderCouncilHotline] Airport Staff Analysis Before We Get to a Public Hearing
To: HOTLINE <[email protected]>

Colleagues and Staff,

At last Thursday’s meeting, we did two important things. We agreed 8 to 1 that the airport decision deserves a public hearing, not a consent agenda item. Five of us also gave direction to staff to come back with both options:  Scenario 1 (indefinite operation with FAA grants) and Scenario 2 (no grants, with the option to pursue closure after 2040) presented side by side, with the financial research needed to actually compare them. I think that was the right call and I want to make sure the analysis that comes back is complete enough to be useful.

The cost comparison we were presented wasn’t apples to apples. The April 23 packet shows a $28M CIP for Scenario 1 versus $12M for Scenario 2 - a $16M gap. Those two numbers represent fundamentally different things. Scenario 1 includes full pavement reconstruction once across the next 14 years. Scenario 2 only accounts for seal coating, deferring the full reconstruction entirely. That’s not a comparison of two ways to run the same airport, it’s a comparison of full maintenance versus kicking a major capital expense down the road. The packet itself flags the risk: if Scenario 2 doesn’t result in closure in 2040, meaning the FAA fight is lost or takes longer than expected, the city would face the full deferred reconstruction cost on top of the $9M shortfall, not instead of it. I’d like staff to present a true normalized comparison that uses the same maintenance standard for both scenarios, so council can see what the actual policy choice costs rather than comparing full investment against deferred maintenance.

I also think we need to be honest about what the no-grants option actually is. It’s not “close the airport in 2040 and we then have control of the land.” Based on the FAA’s stated legal position, that grant obligations run in perpetuity. The 2040 date is the starting line for a federal lawsuit, not the finish line. The $9.9M maintenance figure only gets us to that point. It doesn’t include legal fees, the potential FAA land payback on the roughly 38 acres purchased with federal funds (estimated at around $118M in 2041 dollars), environmental remediation, site preparation, or the cost of continuing to fund airport operations throughout however long the litigation takes.

Just for reference, Santa Monica is the closest parallel we have. They were in active federal litigation with the FAA from 2013 until they settled in January 2017. It took four years in court, on top of decades of prior disputes. The settlement made headlines under the title “Santa Monica Airport Agreement Clears Runway of Mounting Litigation Costs.” Council Member Gleam Davis said at the time: “All I know is that we have spent millions of dollars trying to close the airport and that it is very likely that, in the future, the legal and other expenses would be in the millions.” Council Member Terry O’Day confirmed the costs “run into the millions.” Davis put it plainly: “I gladly would spend millions more if I were certain that the end result of litigation and conflict would be closure of the airport. No knowledgeable person with whom I spoke could make that guarantee.” And critically, even after settling, Santa Monica was required to keep the airport operational for another 11 years, until December 31, 2028.. I don’t think we should walk into that path without a realistic picture of what it actually costs and how long it takes.

At Thursday’s meeting it was confirmed on the record that the legal question of whether accepting FAA grants is an administrative decision or requires a council vote has not yet been researched. I think we need a clear answer to that before we get to a public hearing, given the long-term implications of accepting these grants.
I’d also like to see the Scenario 1 grant assumptions broken out more clearly. The $26M includes FAA entitlement grants, FAA discretionary grants, and CDOT discretionary grants and those carry very different levels of risk. FAA entitlement grants for compliant airports are formula-based and have been awarded consistently for over 75 years through a dedicated trust fund.  Those are about as reliable as federal funding gets. FAA discretionary grants are competitive and carry exposure to the current federal environment. CDOT discretionary grants are funded by Colorado aviation fuel taxes, not federal appropriations, and are generally more stable and insulated from Washington.

However, council needs to take into consideration of a letter CDOT sent to our Director of Transportation and Mobility on May 27th that has significant implications for Scenario 2. Colorado statute - specifically CRS 43-1-109(2)(C) - prohibits CDOT from funding projects that are eligible for available federal funds. CDOT’s letter explicitly confirms they would not be able to fund projects at Boulder Municipal Airport that the FAA determines to be eligible and for which they would be willing to provide federal grant funding. The critical word is “available”. The FAA’s willingness to fund a project doesn’t disappear just because Boulder chooses not to accept their grants. That means under Scenario 2, the city likely loses access to CDOT capital funding as well as FAA funding, for any project the FAA would otherwise cover. The $9M Scenario 2 subsidy figure assumes no federal grants but doesn’t account for losing CDOT funding too. I would ask staff to recalculate Scenario 2 costs with that reality factored in. I’d like staff to break out all three grant sources clearly so council understands exactly where the $26M comes from and which portions are available under each scenario.
One question that didn’t come up Thursday but probably should have: within Scenario 2, does council retain the option to pivot in two, three, or seven years and decide to start accepting FAA grants again? Technically yes, but there are real consequences to that path that need to be part of the analysis. Any maintenance costs the city pays out of pocket while operating under Scenario 2 cannot be recovered retroactively. FAA rules require costs to be incurred after a grant is executed, so money spent before resuming grants is simply gone. On top of that, every year we operate without grants restarts the 20-year clock from whenever we do resume, meaning a pivot in year five doesn’t buy back those five years. And given that Boulder has already sued the FAA and publicly signaled closure intent, resuming grants after a multi-year pause puts us in arguably the most difficult position of any scenario when it comes to the FAA’s discretion on competitive grant applications. I’d like staff to address the pivot option explicitly, what it would actually cost to resume grants after 2, 5, or 10 years under Scenario 2, and whether our existing relationship with the FAA makes future discretionary grants more or less likely after a period of adversarial litigation.

I want to make sure when we get to a public hearing, council and the community are looking at an honest picture of both options.

Respectfully, 

Rob Kaplan
[email protected]

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From: Rivera-Vandermyde, Nuria <[email protected]>
Date: Wed, May 27, 2026 at 6:10 PM
Subject: [BoulderCouncilHotline] Re: Way forward with the airport
To: Schuchard, Ryan <[email protected]>, HOTLINE <[email protected]>

Council Member Schuchard –first let me apologize for the delay in response. I'm not sure why but this hotline message is not showing up in my outlook and it has only just come to my attention. 

We appreciate your sharing your thoughts and leave to your colleagues consideration of the same. We note, however, that the information you have outlined may require either a nod of 3 or 5 depending on the breadth of the research and information council would want staff to bring back. Some of these items, particularly around what constitutes local control in this context and funding sources used by airports outside of our jurisdiction, would require more extensive consideration and effort by staff in both Transportation and Mobility as well as the City Attorney's Office.

I’ll also note that staff had an opportunity today to meet with CDOT to clarify their position as to funding.

Attached, please find that letter which speaks for itself. 

Nuria Rivera-Vandermyde
City Manager

(pronouns: she/her/ella) What's This?

O: 303-441-3090
[email protected]

City Manager’s Office
1777 Broadway | Boulder, CO 80302
BoulderColorado.gov

From: Schuchard, Ryan <[email protected]>
Date: Fri, May 22, 2026 at 1:14 PM
Subject: [BoulderCouncilHotline] Way forward with the airport
To: HOTLINE <[email protected]>


On May 28, Council is scheduled to discuss how to proceed with the airport. That discussion follows the April 23 study session, where five councilmembers indicated support for staff to prepare a proposal for official Council action to conclude the multiyear community conversation and provide long‑term direction for the airport.
 
As we prepare for that next step, please let me highlight a few things.
 
First, I have heard councilmembers and staff offer diverging interpretations about whether concluding the process in favor of long term airport operations and acceding to grant covenants from the FAA (which obligate Boulder to the use of land and operate airport services in perpetuity — covenants strengthened in FAA’s favor in 2022 and which Boulder has not yet pursued) represents the status quo, and hence does not require rigorous or even any council action, or rather it is something that merits a thorough formal action by council. Setting aside the different arguments, this question is still open, and council needs to settle it.
 
Second, there is a key policy question that we did not fully address on April 23: what level of local control do we want to strive to retain over the 179 acres of city‑owned land that make up the airport? This is a local control question, and it is foundational to any long‑term airport decision. Because the April 23 discussion moved quickly to the topic of federal funding, we did not have the opportunity to consider a local control pathway alongside other options.
 
And third, since April 23, we have received new information that appears to indicate state aviation funding is in fact available even if the city does not take new FAA grants, per written correspondence from CDOT’s director of aeronautics. This state funding does not involve perpetuity requirements. This would seem to materially improve the feasibility of a local control option, which was not presented or explored at the study session, and warrants an evaluation. 
 
It also means that Boulder now potentially has at least two long‑term funding models available that could support fiscal stewardship:

• An FAA‑funded model, which provides federal dollars but carries strengthened post‑2022 perpetuity covenants and long‑term federal land‑use obligations; and
• A local control model, which preserves maximum city discretion over the land while allowing access to CDOT funding and supporting long‑term leases.

 
Both models appear to be viable, and Council has not yet had the opportunity to consider them side by side.
 
For these reasons, at the May 28 meeting I intend to ask my council colleagues to support the following:

1. Direct staff to bring forward the proposal indicated on April 23 in the form of a public hearing, so Council can take formal action with a complete record.
2. Direct staff to prepare two versions of the policy for that hearing: one authorizing the use of FAA funding, and one reflecting a long‑term airport path that preserves maximum local control and avoids new FAA grants.

 
This approach will allow Council to choose among a hopefully full set of fiscally responsible options at a public hearing.
 
If Council proceeds with a hearing, I will also request that staff provide information on:

• Airports that operate successfully under local control;
• Funding sources utilized by airports that have chosen to not take new FAA grants; and
• The financial and legal implications of accepting FAA grants under the strengthened 2022 covenants, with an assessment of the issues surrounding perpetuity covenants.

 
For transparency, here is my current thinking about the airport itself: I am inclined to support a long‑term commitment to the airport that provides a clear, stable investment environment and aligns with Boulder’s excellence in long‑range planning. At the same time, I want to ensure we strive for local control and avoid long‑term or even perpetual federal obligations on city‑owned land unless they can be shown to fully be in our community’s interest.
 
I look forward to a good discussion on May 28!
 
Ryan
 
Ryan Schuchard (he/him)
Boulder City Councilmember
 

1777 Broadway
Boulder, CO 80302
[email protected]
 
Office hours and newsletter:
www.ryanwithboulder.com

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See the CDOT re: Clarification of CDOT Aeronautics Funding Eligibility and State Grant Assurances here.

From: Rivera-Vandermyde, Nuria <[email protected]>
Date: Wed, May 27, 2026 at 10:48 AM
Subject: [BoulderCouncilHotline] Airport clarification
To: CouncilMembers <[email protected]>, HOTLINE <[email protected]>
CC: Bailey, Blythe <[email protected]>, Davis, Pam <[email protected]>, Vences, Eric <[email protected]>, Tate, Teresa <[email protected]>


Mayor, Mayor Pro Tem, Council Members and Hotline followers -
 
At our last city council meeting, a speaker questioned a statement made from staff during the course of our conversation about the future of the airport site. I committed to reviewing the video to ascertain the full scope of the statement which was whether staff represented accurately information they understood to be CDOT’s position regarding grants in the event the airport’s future operations remained uncertain.

I’ve always been clear that we should own when we’ve gotten something wrong, and this case requires us to provide some clarification. Staff did say it was their understanding that “CDOT has indicated an unwillingness to provide this grant in the future without the city signaling the intention to operate the airport indefinitely." That information had been transmitted to our new staff in the department and not verified directly. Logically, staff believed that if CDOT had a 20-year grant to provide, it would not make sense to award that to a city that was ostensibly operating an airport for only 10-15 years. We should have confirmed that statement prior to speaking to it and for that, we apologize.

We have also heard from community that we did not provide you with sufficient information as to the feasibility of operating the airport without federal funds. Staff’s scenario 2 is precisely that scenario where staff speaks to operating the airport without the use of federal subsidies from the FAA. Scenario 2 does not negate the city’s opportunity to seek grants from CDOT, for example, as we have already successfully shown we are willing to seek grants that do not exceed our current grant assurance period. CDOT grants, however, still require the city to make a matching or additional investment that will require us to use monies under the Transportation or the General Funds. It is this fundamental financial situation staff was bringing to light as the decision to continue to use the airport for its current use – or not – leads us to entertain different funding scenarios.

I hope that provides some clarity and again, apologize for misspeaking about what we understood to be CDOT’s position.

Nuria Rivera-Vandermyde
City Manager
(pronouns: she/her/ella) What's This?

O: 303-441-3090
[email protected]

City Manager’s Office
1777 Broadway | Boulder, CO 80302
BoulderColorado.gov

The City of Boulder acknowledges the city is on the ancestral homelands and unceded territory of Indigenous Peoples who have traversed, lived in and stewarded lands in the Boulder Valley since time immemorial. Those Indigenous Nations include the: Di De’i (Apache), Hinono’eiteen (Arapaho), Tsétsėhéstȧhese (Cheyenne), Nʉmʉnʉʉ (Comanche), Caiugu (Kiowa), Čariks i Čariks (Pawnee), Sosonih (Shoshone), Oc'eti S'akowin (Sioux) and Núuchiu (Ute).​

We honor and respect the people of these Nations and their ancestors. We also recognize that Indigenous knowledge, oral histories, and languages handed down through generations have shaped profound cultural sustained and celebrated to this day.​

The City of Boulder recognizes that those now living and working on these ancestral lands have a responsibility to acknowledge and address the past. We must not only acknowledge our past but work to build a more just future. We are committed to taking action beyond these words. We pledge to use this land acknowledgment to help inspire education and reflection and initiate meaningful action to help support Indigenous Nations, communities and organizations.​
READ THE FULL STAFF LAND ACKNOWLEDGMENT: https://bit.ly/staff-acknowledgment

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From: Laura Kaplan <[email protected]>
Date: Sun, May 24, 2026 at 10:14 AM
Subject: Re: Did CDOT say that Boulder airport will not receive future grants without "signaling an intention to operate the airport indefinitely" ?
To: Nuria <[email protected]>
Cc: Winer, Tara <[email protected]>, <[email protected]>, Brockett, Aaron <[email protected]>, <[email protected]>, <[email protected]>, Benjamin, Matt <[email protected]>, Wallach, Mark <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, Ryan Schuchard <[email protected]>


Hi Nuria, 

Thank you for your response to my testimony at council last Thursdsay night. I hope you've had (or will soon have) a chance to review the meeting video around the 21:30 mark and verify the quote from staff that I mentioned. As Dave Ulane noted in his email to me, this statement that CDOT will not provide grants "without the city signaling an intention to operate the airport indefinitely" is inaccurate, and an indefinite commitment is only required if CDOT funds are used for land acquisition. I am grateful to Dave Ulane for his speedy clarification; he answered my email within about 2 hours despite his out of office responder saying he was on vacation. 

If this misperception is the reason why staff did not analyze available CDOT funding, hopefully that can be corrected in staff's next steps. Fiscal responsibility was a major rationale cited by several council members for their straw poll (now "non-binding nod of 5") preference on April 23.  

It has not yet been demonstrated how the city could pursue Scenario 2 in the most fiscally responsible way possible, including CDOT grants and other on-airport funding mechanisms. This is necessary for council to make a wise decision when one of the options has perpetual, irreversible consequences. 

Boulder's staff's amazing resourcefulness and creativity should be brought to bear to develop the most workable plan for funding pursuit of Local Control in scenario 2 with no FAA grants, avoiding reliance on the city general fund, and minimizing any extension of grant commitments. When the alternative is a commitment in perpetuity, some extension of the grant obligation timeline is a reasonable option for the city to consider. 
 
CDOT funding can be a major source of revenue. Per the CDOT grants table copied below, grants the city would pursue for Scenario 2 come with obligations from 0 years for temporary fuel infrastructure to 20 years for pavement reconstruction or other construction projects. 

Looking at the detailed inventory of airport project needs provided in the 2024 Financial Report for Scenario 2 (see below), it looks like:

• Roughly $6 million of the airport's needs between now and 2040 are periodic seal coating/crack sealing that comes with a 3 year obligation timeline from CDOT. This is the same grant CDOT provided to Boulder this year for $450K. 
• About $2 million would be a fuel farm that Eric emphasized needs to be constructed soon. A fuel farm comes with a 15 year obligation timeline from CDOT, which would put the city slightly past 2040. 
• About $1.15 million is one pavement reconstruction project scheduled for 2029 that would have a 20 year timeline until 2049. Of course, the city could bank other funding for that reconstruction need, or decide it's worth it to push out the obligation timeline, without committing to perpetuity. 
• I believe some of the equipment listed has already been acquired, but equipment and vehicles come with a 10 year obligation. 

Nothing here looks prohibitive for pursuing Scenario 2 and avoiding a perpetuity commitment. The project types and amounts are typical of CDOT Discretionary Aviation grants.

The financial outlook would be even further improved by considering other airport-specific funding sources. CDOT and the Colorado Aeronautical Board who administer the grants consider it a plus in a grant application if they see a local sponsor is maximizing on-airport revenue. These methods could include: 

• bringing airport rates and charges up to present market rate and instituting landing fees (estimated revenue increase of about $100K-200K+/yr), and 
• either selling or leasing the airport land west of Hayden Lake for non-aeronautical commercial uses as described in the 2024 financial report. This use is not dependent on the main airport. 

The airport property west of Hayden Lake is physically disconnected from the main airport's runways and roads. In the photo below, these parcels are out of view to the left. The 2024 financial report estimated these parcels could bring in about $267,273 in lease revenue per year in 2024 dollars, starting in about the year 2030 (July 25, 2024 council meeting packet,  https://documents.bouldercolorado.gov/WebLink/edoc/187418/07.25.24%20City%20Council%20Special%20Meeting%20Agenda.pdf?dbid=0&repo=LF8PROD2 , page 407). Presumably investors would need extended ground leases of 20-30 years, but this type of non-aeronautical commercial use west of Hayden Lake presumably could be continued even if the main airport land use changed at some unspecified point in the future.

It's worth noting that the analysis provided by staff regarding landing fees and airport rents appears to also have some unfortunate information gaps and inaccuracies. I'll send more information in a separate communication. 

It's also worth revisiting the confusing assertion that a big bill would come due to the city if the city performs no pavement reconstruction through 2040 and subsequently learns in court that the FAA's claim to perpetuity is upheld. Why would that bill for pavement reconstruction then fall solely upon the city? Is there a reason why the city would not simply pursue FAA grants (and possibly also CDOT grants) for pavement reconstruction at that time, if the pathway to ending FAA grant obligations is clearly closed by the courts? 

Thank you for reading. Hope you've had / are having a good holiday weekend.

REFERENCES

The figure below is from the 2024 Financial Report p. 357 prepared by the previous airport manager, John Kinney, and consultants. Staff did not provide an itemized accounting of what was changed to update the scenarios for the meeting in April but the total dollar amount staff projected for Scenario 2 ($9 million) was reasonably close to the 2024 projections ($9.9 million, some of which has been accomplished since 2024), so I'm using the 2024 itemized list for reference. p. 357 https://documents.bouldercolorado.gov/WebLink/edoc/187418/07.25.24%20City%20Council%20Special%20Meeting%20Agenda.pdf?dbid=0&repo=LF8PROD2 

and the CDOT grants chart below from Dave Ulane's email, which surely the city is familiar with since Boulder received two grants from CDOT within the past year. 

From: Schuchard, Ryan <[email protected]>
Date: Fri, May 22, 2026 at 1:14 PM
Subject: [BoulderCouncilHotline] Way forward with the airport
To: HOTLINE <[email protected]>


On May 28, Council is scheduled to discuss how to proceed with the airport. That discussion follows the April 23 study session, where five councilmembers indicated support for staff to prepare a proposal for official Council action to conclude the multiyear community conversation and provide long‑term direction for the airport.
 
As we prepare for that next step, please let me highlight a few things.
 
First, I have heard councilmembers and staff offer diverging interpretations about whether concluding the process in favor of long term airport operations and acceding to grant covenants from the FAA (which obligate Boulder to the use of land and operate airport services in perpetuity — covenants strengthened in FAA’s favor in 2022 and which Boulder has not yet pursued) represents the status quo, and hence does not require rigorous or even any council action, or rather it is something that merits a thorough formal action by council. Setting aside the different arguments, this question is still open, and council needs to settle it.
 
Second, there is a key policy question that we did not fully address on April 23: what level of local control do we want to strive to retain over the 179 acres of city‑owned land that make up the airport? This is a local control question, and it is foundational to any long‑term airport decision. Because the April 23 discussion moved quickly to the topic of federal funding, we did not have the opportunity to consider a local control pathway alongside other options.
 
And third, since April 23, we have received new information that appears to indicate state aviation funding is in fact available even if the city does not take new FAA grants, per written correspondence from CDOT’s director of aeronautics. This state funding does not involve perpetuity requirements. This would seem to materially improve the feasibility of a local control option, which was not presented or explored at the study session, and warrants an evaluation. 
 
It also means that Boulder now potentially has at least two long‑term funding models available that could support fiscal stewardship:

• An FAA‑funded model, which provides federal dollars but carries strengthened post‑2022 perpetuity covenants and long‑term federal land‑use obligations; and
• A local control model, which preserves maximum city discretion over the land while allowing access to CDOT funding and supporting long‑term leases.

 
Both models appear to be viable, and Council has not yet had the opportunity to consider them side by side.
 
For these reasons, at the May 28 meeting I intend to ask my council colleagues to support the following:

1. Direct staff to bring forward the proposal indicated on April 23 in the form of a public hearing, so Council can take formal action with a complete record.
2. Direct staff to prepare two versions of the policy for that hearing: one authorizing the use of FAA funding, and one reflecting a long‑term airport path that preserves maximum local control and avoids new FAA grants.

 
This approach will allow Council to choose among a hopefully full set of fiscally responsible options at a public hearing.
 
If Council proceeds with a hearing, I will also request that staff provide information on:

• Airports that operate successfully under local control;
• Funding sources utilized by airports that have chosen to not take new FAA grants; and
• The financial and legal implications of accepting FAA grants under the strengthened 2022 covenants, with an assessment of the issues surrounding perpetuity covenants.

 
For transparency, here is my current thinking about the airport itself: I am inclined to support a long‑term commitment to the airport that provides a clear, stable investment environment and aligns with Boulder’s excellence in long‑range planning. At the same time, I want to ensure we strive for local control and avoid long‑term or even perpetual federal obligations on city‑owned land unless they can be shown to fully be in our community’s interest.
 
I look forward to a good discussion on May 28!
 
Ryan
 
Ryan Schuchard (he/him)
Boulder City Councilmember
 

1777 Broadway
Boulder, CO 80302
[email protected]
 
Office hours and newsletter:
www.ryanwithboulder.com

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From: Winer, Tara <[email protected]>
Date: Thu, Apr 30, 2026 at 9:09 AM
Subject: [BoulderCouncilHotline] CAC request re: Study Sessions and Straw Polls
To: CAC <[email protected]>
Cc: HOTLINE <[email protected]>


Dear Staff, Council Colleagues, and Hotline Followers,
 
I have concerns regarding our recent use of study sessions and straw polls.
I would like to request CAC schedule a Council discussion to establish clearer criteria for their future use.  
I believe both the Council and the community would benefit from clarification on their appropriate scope and limits.
 
I would also like us to define what constitutes 'relitigation' in the aftermath of a study session.
 
The need for this has become particularly clear after our recent study session on the airport.
 
I would like us to schedule this discussion as soon as possible.
 
Sincerely,
Tara Winer
Mayor Pro Tem
Boulder City Council
 

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From: Wallach, Mark <[email protected]>
Date: Wed, Apr 29, 2026 at 6:58 AM
Subject: [BoulderCouncilHotline] More Airport
To: HOTLINE <[email protected]>


At last Thursday’s study session we took steps to permanently remove the Boulder airport from consideration as a site for affordable and middle-income housing or, for that matter, from any alternative use of the property. In exchange for a few potential (emphasis on “potential”) FAA grants we have acceded to the FAA’s bullying tactics and bent the knee to a federal agency that does not have the interests of Boulder at heart, merely a desire to protect its aviation empire. We should stand up to bullies, not yield to them, but the policy of the City of Boulder appears to be otherwise.

At the outset, I must say that the presentation we received from staff was, in my opinion, not an even-handed analysis of the issues surrounding the airport, but an advocacy brief for the purpose of obtaining those few, meager grants, and at the cost of committing to operate the property as an airport in perpetuity. The facts presented on Thursday were poorly researched, incomplete and served little purpose other than to push us into making the decision that was desired all along. 

Let’s begin by being very clear about what this vote represented. We are selling a property worth hundreds of millions of dollars to the FAA for the mere prospect of a few grants to cover the inability of the airport to pay its own way. You doubt the characterization of this decision as a sale? Consider this: we will, permanently, lose all control over the property. We will never have the right to change its use, to sell it to another party or to do anything with it that the FAA prohibits. That is the essence of conveyance, even if we do not grant the FAA a deed and formally transfer title. A deed is not necessary; in every respect that matters the FAA will own the land. And we will be selling 179 acres at a price (the grant funds) we could have obtained by selling 5 acres on the open market. I suggest that selling a property of this value for such minimal consideration is highly inappropriate. 

And we should be aware of the collateral effects of this decision, which include the following:
In taking this step we have abandoned all those who are experiencing excessive noise pollution; our “voluntary” noise limits have no effect whatsoever. We will never have the right or ability to address them in a manner not approved by the FAA. I am always amused when I hear someone state that there should be no remedy for those impacted by airport noise on the theory that they moved into a neighborhood near the airport; they should have expected these conditions and deserve what they get. There is no other issue in Boulder that is dealt with so callously, especially by those who are not impacted. 

We have also abandoned the lower income families and children in Vista Village and San Lorenzo to continued airborne lead pollution. Not a word was said about this, and no weight was given to the airport’s continuing negative environmental impact, an impact that will now continue on unless the FAA at some point bans the use of leaded fuel.  That wait may be long indeed. It is almost impossible to call Boulder an environmentally progressive community in light of the calculus we have made to elevate a few federal grants over the health and welfare of our citizens. This is the choice we are making.

And finally, without even a by-your-leave, we have disenfranchised 3,400 signatories to a citizens’ petition calling upon us to alter the use of the facility. A petition that was withdrawn, as we all remember, so as to not interfere with the City’s own lawsuit against the FAA.  Upon receipt of the first grant funds that petition is dead and buried, and cannot be resuscitated. This is our famous adherence to the concept of community input? I think our new policy can only be described as seeking  community input, except when we find it inconvenient. Community input apparently comes and goes at our discretion. 

This is the most consequential land-use decision I can remember, and we made it without a hearing, public testimony or any semblance of input from the community.  At the end of the discussion the majority recognized the inappropriateness of making this decision at a study session and promised a more formal resolution to be placed on the Consent Agenda (Really?), but that will not make the process we have adopted any more acceptable. 

I would argue that taking a vote to consider taking FAA grants does not imply that we must immediately do so. My colleague Ryan Schuchard has raised the issue of placing some guardrails around taking such grants, and I agree. As we are clearly in a better position if we can get the work done without resorting to grant funding, he has argued that taking that step should be the last resort, not the first, and only after we have exhausted all possibilities, among which are the use of CCRS funds, funds that would become available if we expand the City’s debt limits in November, funds that become available every time we do an Adjustment to Base, funds that may become available from an improving economy or from the impact of the Sundance Film Festival. These guardrails should also include close consultation with this Council before action is taken. Treating the ability to apply for such grants as a mere administrative matter that is the exclusive purview of staff is absurd, when the effect is to effectively give away hundreds of millions of dollars of real estate value.

And, finally, none of this has anything to do with the continued operation of the airport. We would do that for the next 14 years, at a minimum. We would do it in perpetuity if our court case is unsuccessful or if that turns out to be the will of the community. But by holding out our hands for federal grants we are making the judgment by ourselves, and binding every council that follows us to the decision we make now. Receipt of the first grant funds will make the perpetuity obligation a reality.  I suggest that the price of those funds is so high as to be unacceptable, and it is a pity that the Council majority finds that it is a Devil’s bargain worth making. 
Given the majority’s view of the optional nature of a public process for this decision there may well be no remedy for this situation. But future generations will look back on this action in disbelief at the rationale with which we took these steps, the minimal benefits we received in exchange for taking them and the extraordinary amount of real estate value we so casually gave away in a straw poll at a study session. It is cold comfort to be in the minority that will not be responsible for this action; as a Council we will be judged in our entirety, and that judgment will be harsh.
 


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From: Bailey, Blythe <[email protected]>
Date: Thu, Apr 23, 2026 at 1:25 PM
Subject: [BoulderCouncilHotline] [BoulderCouncilHotline], Re: Recent Airport Questions
To: Schuchard, Ryan <[email protected]>, Wallach, Mark <[email protected]>, Marquis, Tina <[email protected]>, HOTLINE <[email protected]>
Cc: Vences, Eric <[email protected]>, Davis, Pam <[email protected]>, Rivera-Vandermyde, Nuria <[email protected]>, Tate, Teresa <[email protected]>, Toro, Luis <[email protected]>, Watson, Valerie <[email protected]>

Good Afternoon, Council and HOTLINE followers,
 
Thank you to Councilmembers Marquis, Wallach, and Schuchard for your input and questions. We have consolidated the questions staff were able to respond to in advance of the meeting below, and for purposes of efficiency and in some cases, we have shortened the language of the questions. We look forward to additional discussion and answering further questions at this evening’s study session. Condensed questions are italicized below for reference, with each staff response immediately following.
 
1. The last two of the three questions council is being asked to provide feedback on could feel as if they are in conflict. If enough council members don’t feel that they have enough information to provide direction on whether or not to accept grants (Q2), will we provide direction (Q3) at a later time or would staff like direction this Thursday? 
 
Staff agrees that the wording of questions in the memo is overly complex and plan to replace the three questions in the memo with the two below to focus on the specific direction sought:

1. Does Council have any questions regarding the information presented on the current or future state of the airport?
2. Does Council have feedback to support scenario one (indefinite operation of BMA) or two (maintain closure opportunity)?

We note specifically that we are not asking city council whether the city should apply for state or federal funding. Those decisions are administrative in nature and we would not place city council in that position. Rather, the question revolves on whether the current site at the airport should remain designated for airport use. If the answer is yes, then staff would consider a variety of funding sources including the receipt of Federal Aviation Administration (FAA) funds to minimize the impact on existing city funds. If not, we would continue to ensure the current airport site meets our minimum compliance requirements while looking to alternate funding sources that do not obligate us to maintain airport operations past 2040.  We do not expect such alternatives to fully meet all of our capital needs and want to be clear we would need to consider subsidizing with other existing city funds depending on needs and urgency.
 
2. Is there a third option to commit to continue to operate the airport indefinitely but consider not taking federal grants in the near future? Are there alternative ways to fund our airport and provide little to no subsidy as described in Scenario 1? In addition, I am curious if there is an option to run the airport independently and create a better relationship with our airport users and broader community.
 
Staff did not analyze a scenario in which we maintain airport operations indefinitely without FAA grants.  Tradeoffs with this approach include either further delaying deferred maintenance projects or seeking financial assistance as early as 2027 from another city fund. Additionally, there are disadvantages to prolonged uncertainty about the long-term future of the airport. Development and leasing opportunities have been hampered by the current uncertainty and we have heard from many existing and potential tenants at the airport that individuals and companies are unlikely to expand or invest at the airport without certainty of the airport’s future. In addition, some impacts are tangible already—this uncertainty has led to vacancy of two large hangars which is negatively impacting existing revenue streams.
 
Staff have been, however, looking at a variety of available funding options. We have already begun taking CDOT grants that have more limited time assurances. Many of CDOT’s larger grants, however, carry grant assurances that span up to 20 years, so we have not availed the city of those opportunities. As scenario 2 shows, operating without federal grants is very difficult, and the level of fee increases that would be required to avoid running a deficit would likely push users to other airports, exacerbating the vacancy issue. Staff have also considered such possibilities as landing fees, discussed in more detail below. In 2025, Longmont City Council rejected an ordinance to establish landing fees at $5 per 1,000 pounds of landing weight.
 
We have addressed the question about enhanced city autonomy over the airport in a below response.
 
3. What are the current fees or other expenses that we charge airport users and how do they compare to other amenities in the city, like golf course fees and recreation center passes? I realize they are not apples to apples comparisons but would like to learn more. Also, are fees different if you are just touching down/visiting at our airport?
 
Lease Rates
 
The city conducted a rent study in 2025 informing a rent increase that went into effect in January 2026 for our T hangars (airplane storage units that are available for lease at the airport). Our rates are comparable to other airports locally, and for some tiers of T hangars, higher than those charged nearby at Rocky Mountain Metropolitan Airport (RMMA). Table of those compared fees is here
 
BMA T Hangars RMMA T Hangars 
Type 1 40’ doors     $350     Tier 1      39’ doors$364.07
Type 2 40’ doors    $400     Tier 2     41’ doors$372.45
Type 3 40’doors     $450      Tier 3     55’ doors$702.86
 
For more perspective on city fees, as requested, additional information on parks and recreation fees can be found at this link, https://bouldercolorado.gov/parks-and-recreation-fee-schedule. Relatedly, Parks and Recreation fees are set based on the 2023 Fee Policy. Fees are established based upon the actual cost of delivering the service and degree of community benefit. Services that provide community benefit, such as open access to parks, are subsidized. Services that are more individual in benefit, such as private lessons, have fees that support full cost recovery. Airport leadership endeavors to follow the same theoretical model in compliance with grant assurances.
 
Landing Fees
 
The last part of this question refers to the option of landing fees—a fee airport users would pay for every individual touchdown. A typical landing fee in Colorado is $1.85-$9.09 per 1,000 pounds, and typically exempt aircraft below 6,000-8,000 pounds and in some cases, like Alamosa, CO, are waived for general aviation entirely. Colorado Pilot Association has collected all for quick glance.
 
BMA has greater than 95% of based aircraft below the weight thresholds listed above. If we self-perform the administration of those landing fees, it is likely the cost for staff time to administer the process approaches the same value of the fee revenue. Non-based flight training aircraft are also below those weight thresholds. It is also common for airports to receive less than 100% of the fees, due to difficulty identifying certain aircraft for billing purposes. Landing fees were studied as part of the June 2024 analysis and had $35,000 revenue projected with assumptions called out in the footnotes ($2.50 per operation and ¼ capture of total operations per year). Currently pending legislation, the Aircraft and Pilot Privacy Act, would disallow the use of ADSB (automatic dependent surveillance broadcast) data in collecting fees on aircraft, making the effort and administration of landing fees more time intensive and outweigh the potential revenue presented in the original analysis. Vendors that offer landing fee collection systems base their systems on a mix of ADSB data and FlightAware data, but FlightAware does not capture all flights as flight plans are not required for VFR (visual flight rules) flights.
 
4. Is the Transportation Maintenance Fee revenue being considered to be used for the airport or roads accessing the airport?
 
No, the TMF specifically is directed to transportation assets within the public right of way, primarily street pavement maintenance.
 
5. The FAA now takes the position that if we take grants they do not burn off in 20 years; they are a commitment on the part of the municipality to operate the airport in perpetuity.
 
As staff shared in the discussion with City Council in 2024, the FAA asserted this position on grant assurances beginning in 2022. They reiterated this position again in 2025. We do not currently have a grant contract with the 2022 or 2025 grant provisions. Given this condition, staff awaits council direction on the intended long-term use of the airport prior to pursuing FAA grants or any other grants that have grant assurances beyond 2040.
 
6. One of the main concerns with BMA is lead pollution over the surrounding area. But please note that they are not spewing lead on Mapleton Hill or Lower Chautauqua. Rather, it is being sprayed over Vista Village and San Lazaro, manufactured home parks largely occupied by people of lower income and people of color. And despite our efforts to encourage the use of unleaded fuel, there is nothing we can do to compel that usage, and there is nothing to prevent lead-generating planes from other airports from landing and taking off at BMA. Page 9 of the staff memo describes the equity analysis that was conducted in connection with this subject but does not describe the conclusions reached by that analysis. What were they and do they reflect concern for this problem?
 
The engagement work described in the Equity Analysis section of the memo was performed during the 2023 Airport Community Conversation. Through those efforts community members participated in two citywide open houses, two citywide online and in-person questionnaires in English and Spanish, a Community Working Group, bilingual community meetings, and individual interviews, alongside targeted outreach to directly impacted and historically underrepresented populations such as the nearby communities of San Lazaro and Vista Village. To that end, staff created materials in Spanish and provided dual language meetings for the Airport Community Conversation to ensure inclusion of those communities' perspectives. Their input helped shape the full range of airport future scenarios that were presented in 2024, as well as our near-term efforts, particularly around unleaded fuel.  As for conclusions, the process did not produce a single unified position from these nearby communities.  Some participants emphasized the airport’s value as a community asset—supporting business activity, emergency response, and aviation services—while others raised significant concerns related to aircraft noise, the continued use of leaded fuel, and the opportunity cost of maintaining approximately 140 acres of land in a high-demand housing market. Further information on the engagement efforts were provided as an information packet that is available in the meeting materials for the Feb 1, 2024 council meeting.

We did hear concerns about lead exposure. Attached to this email is information (lead messaging.pdf) from the State of Colorado and Boulder County about lead that were shared with community during the Community Conversation. In summary, the information indicates that lead-based aviation fuel can be a source of lead exposure for residents, particularly children, who live near airports, but describes it as one of multiple potential sources. The information also offers remedies for reducing exposure and encourages blood lead testing as the best way to determine if or how lead is affecting one’s family.  While the City of Boulder doesn’t have the authority to ban the use of lead-based fuel for aircraft, we are committed to achieving the goals of our unleaded transition plan which commits us, upon federal regulatory approval of a fleet-wide drop-in, to full unleaded transition by the end of 2030.
 
7. 15-minute neighborhoods. This is a major policy of our prospective Comp Plan, but where are those neighborhoods going to go? It is at least worth noting the potential of this property for developing precisely that type of neighborhood, a potential that can only be reached if we decline to take federal grant funds; and
8. Middle-income housing that is not in Aurora. We have built almost no for-purchase middle income housing in Boulder. The core purpose in potentially converting the BMA to residential is to do precisely that. Is that not one of the tradeoffs we must consider?
 
Staff have not yet received clear direction to pursue studying the viability of alternative land uses. If council wished to consider this site for different land use in the future, and specifically one aimed at additional housing, staff would need to do more analysis in this area. Airport funds and staff could not be used for this effort and a new workplan item would need to be resourced differently.
 
9. The funding gap. At last week’s meeting we were given a written analysis of ways to reduce the projected funding gap through increased fees if we do not pursue FAA grants. Has there been any review of this document? Has there been any independent analysis by staff as to how we might reduce our financial gap through any other measures? Of the anticipated expenditures, how many are discretionary vs. required? And if we do nothing creative and realize a $9MM gap over 15 years, that amount represents .0012% of the total funds we are likely to budget and spend over that time (assuming an annual budget of $500MM/year). In addition, that $9MM represents .0025% of the value of the land at $2MM/acre, a figure that is likely to be far higher by 2040. 
 
Staff was recently provided with the written analysis provided by a community member, but have not been able to yet thoroughly review. A cursory read-through suggests some complexities and elements that staff disagree with, for example, the assertion that implementing landing fees poses no cost to BDU.  
 
Regarding land value, staff asked the Colorado Group to perform a Broker Opinion of Value which was produced late last week. This updated professional opinion will be presented at the study session.  
 
For information on the rent study and T hangar lease charges see the lease rates section, as well as landing fees, listed earlier in the response.
 
10. Environmental remediation. The staff memo states that in the event of a potential change of use of BMA, remediation of the property from prior contamination is estimated to be $10-30 million, but it could go as high as $100 million. I point out that when Stapleton Airport was deconstructed and remediated it was done for $120 million. But Stapleton was 4700 acres, not 179 acres, and had 6 runways handling large jets. And I want to note that in February of 2025, in response to a question from a Council member, the then-Director of Transportation noted that Chandler Airport in Arizona, a facility of 500 acres and the 6th busiest airport in that state, would incur a $7 million remediation expense and further noted that “staff believes this would exceed remediation costs for Boulder Airport.” And this number has changed why?
 
While difficult to predict this far in advance, national comparisons suggest mitigation costs could range widely. The staff memo uses a preliminary assumption of $10–30 million, which was itself intended to reflect wide variability across different unknowns and is slightly higher than the Kimley Horn conclusion from the 2024 study, of $7 million.  Staff used publicly available information for other airport redevelopment projects and concluded, while it seems reasonable that our site could be simple and low-cost relative to other bigger and more complicated sites, there are too many unknowns to be certain of a range. From staff research, the range of remediation costs could be as low as $50k/acre but as high as more than $500k/acre, with some examples citing a number higher than that. Since detailed environmental analysis has not been done, staff felt it was helpful to give a representation of the possibility of the range but calling out a reasonable and low-end initial assumption.  
 
11. The 2-runway conundrum. A former airport manager told me in no uncertain terms that the second runway at BMA was non-compliant with FAA standards and that the easiest way to deal with this condition would be to shut the runway down for safety reasons. Is this option available? If not, why not? Have we even examined the possibility? Would it not diminish the funds required to operate the facility? 
 
There are operational and safety impacts in keeping or removing the glider runway. FAA has reviewed and permanently authorized current airfield layout including separation distances of both of Boulder’s runway and taxiway centerlines. Staff cannot at this time definitively quantify the revenue or expense tradeoffs of a single runway closure.
 
12. Airport Economic Impact Study. It is a 2025 study produced by CDOT purportedly measuring the economic impact of BMA. Except it does not measure the economic impact of BMA on Boulder: every category is based on alleged impacts in the State of Colorado; it has nothing to do with Boulder. So if the airport provides payroll of $10MM, but 2/3 of the employees live elsewhere, the payroll impact is listed as $10MM and then escalated upwards based on multipliers that are entirely obscure. The point is that this survey does not reflect the economic benefits of BMA to Boulder and is almost certainly not an accurate picture of BMA’s economic impact on Colorado.
 
The economic study conducted by the State of Colorado was based on direct inputs from the City of Boulder. Slides 9, 10, and 11 of the attachment are all Boulder-specific.  When preparing for this study session, staff also reviewed the inputs for this study and discovered that Shotover, headquartered at 5660 Airport Blvd., with a based aircraft at BMA has 100 employees worldwide with 50 local employees, and were not included. In the future, staff hope to partner with the Chamber of Commerce when collecting data to ensure accurate reporting at the time of the next update in 2030.
 
13. What is the estimated funding we are counting on from the FAA in Scenario 1 (continue the airport) through 2040, and what needs would it cover?
 
$26M in grant funding assumptions were made to fund pavement replacements and maintenance, aviation navigation infrastructure replacements, and projects such as airport road and fuel facility replacement.
 
14. What is the estimated funding we would need to seek from sources other than the FAA in Scenario 2 (discontinue the airport at 2040) through 2040 — to replace what we would have otherwise sought from the FAA — and what needs would it cover?
 
Staff assumed differences between Scenario 1 and 2 that eliminated pavement replacements for Scenario 2, reducing capital program costs. The remaining projects were deemed necessary improvements for basic grant assurance requirements through 2040. The cost of combined remaining capital projects in Scenario 2 is $12M that would need to be funded by other means. Staff notes that if the city were to try to maintain an airport past 2040 without FAA grants, they would need to re-assess these assumptions as the intensity of deferred maintenance challenges would likely have increased.
 
For both scenarios, staff used the financial projections from the 2024 study, updated figures per the actual budget in ’24 and ’25, and removed some additional capital projects that were deemed non-critical. As a result of this updated analysis, staff projects a total deficit of $14.7m for scenario 2 by 2040, funding for which would be sought from other sources. Our projections also include the same revenue assumptions for hangar development and lease revenue from the ’24 study.
 
15. Beyond the FAA, what alternative funding sources have been considered for a potential capex gap? CDOT, user fees, and direct investment from the electric aviation industry, for example?
 
Consultant led analysis in 2024 studied landing fees and administrative fees among other revenue and operating assumptions. See landing fees section above for details. For administrative fees, the analysis notes that administrative fees could include document preparation for lease development and updates, performing hangar safety inspections, and similar. Unfortunately, the amount of revenue that could be generated from administrative fees is relatively small compared to the overall airport budget. Although several thousands of dollars could be generated annually, it is an insignificant amount and would not change the overall budget outlook. Additional creative funding opportunities staff identified include the Energy and Mineral Impact Assistance Fund and other State programs that are not aviation-specific for advanced industry such as aerospace which could be used to offset some capital expenses and achieve community goals of meeting spaces or incubator space on airport.   
 
16. My understanding is that existing FAA grant agreements (through 2040) and any future agreements restrict our ability to impose our own environmental regulations, such as phasing out leaded fuel or establishing our own noise requirements — and that outside those agreements (i.e., after 2040 if we sign no more FAA grants), we’d be free to enact our own rules. Is that right?
 
Regardless of whether the city took additional federal funds, if we operate an airport we are subject to FAA regulations.  They have sole authority over civil aviation activity and are responsible for developing air traffic rules, assigning the use of airspace and controlling air traffic. As such, the city does not now have, nor would it have, jurisdiction over noise and fuel regulations. Operating an airport after 2040 without federal resources would not free us from federal requirements.
 
By way of example, the FAA has recently promulgated rules about unleaded fuel. As they are looking to move forward to what they have termed a “lead-free aviation system,” they have explicitly said airports cannot ban leaded fuel until suitable alternatives are more widely available and in no case would that be earlier than December 31, 2030. Even after our grant assurances, the city would likely need to seek FAA approval for certain modifications such as with regard to noise and types of aircraft.

If any additional questions arise, don’t hesitate to reach out. We look forward to the discussion this evening.

Sincerely, Blythe Bailey
Director
he/him/his


C: 720-762-3525
[email protected]
Transportation & Mobility Department
1101 Arapahoe Avenue | Boulder, CO 80302
bouldercolorado.gov



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