Airport Master Planning and ALP Requirements
Scope & Methodology
This article examines the federal regulatory framework governing airport master plans and Airport Layout Plans (ALPs), including statutory requirements, FAA review authority, capital funding prerequisites, and analytical considerations arising from 2024 legislative amendments. Sources include 49 U.S.C. §§ 47101–47175, FAA Advisory Circular 150/5070-6B, the FAA Reauthorization Act of 2024 (Section 743), and implementation guidance issued October 2024.
Bottom Line Up Front
Master plans and ALPs are the gateway documents for airport capital development. The ALP is a condition of federal grant eligibility: projects must be shown on an FAA-approved ALP to receive AIP or BIL funding. While the FAA does not mandate master plans, it strongly recommends their preparation. The 2024 Reauthorization curtailed FAA authority over non-aeronautical projects, creating new flexibility for airport land development outside the traditional ALP approval scope.
What an Airport Master Plan Is
An airport master plan is a comprehensive planning study that evaluates the airport's ability to meet current and projected aviation demand and presents a phased development program to address identified facility deficiencies over a 20-year planning horizon. The master plan produces four core deliverables: an Airport Layout Plan (ALP) drawing set, a Capital Improvement Program (CIP), a financial feasibility analysis, and a narrative report documenting the technical basis for recommended development (FAA AC 150/5070-6B, July 29, 2005).
AC 150/5070-6B identifies nine objectives that a master plan should meet, including: documenting the issues proposed development will address; justifying development through technical, economic, and environmental investigation; establishing a realistic implementation schedule; proposing an achievable financial plan; and setting the framework for continuing planning process.
The FAA does not require airports to prepare master plans — it "strongly recommends that they do so" — but master plans and ALP updates are prerequisites for AIP grant eligibility. Proposed development must be shown on an FAA-approved ALP to receive AIP funding. The FAA recommends that airports update their master plans every 5–10 years.
Legal and Regulatory Framework
The ALP Requirement: 49 U.S.C. § 47107(a)(16)
Every airport that has accepted AIP grants is required, as a condition of those grants, to "maintain a current layout plan of the airport" (49 U.S.C. § 47107(a)(16)). This is Grant Assurance 29, codified in statute and repeated in the AIP Grant Assurances for Airport Sponsors.
The ALP must show:
- Boundaries of the airport and all proposed additions
- The location and nature of all existing and proposed airport facilities and structures (runways, taxiways, aprons, terminal buildings, hangars, roads)
- Proposed extensions and reductions of existing airport facilities
- The location of all existing and proposed non-aviation areas and improvements
- All proposed and existing access points used to taxi aircraft across the airport's property boundary
FAA Approval of the ALP
FAA approval of an ALP indicates that the existing facilities and proposed development depicted on the plan conform to FAA airport design standards in effect at the time of approval, and that the FAA finds the proposed development to be safe and efficient. No airport alteration may proceed that does not conform to the approved ALP if the Secretary of Transportation determines that the alteration adversely affects the safety, utility, or efficiency of aircraft operations or of federally financed property.
The 2024 Reauthorization: Section 743
Section 743 of the FAA Reauthorization Act of 2024 (Pub. L. 118-63, signed May 16, 2024) amended the scope of FAA's ALP review authority. Key changes:
- Scope of FAA authority. FAA retains authority to review and approve only those ALP changes that (1) materially impact the safe and efficient operation of aircraft, (2) adversely affect the safety of people or property on the ground as a result of aircraft operations, or (3) adversely affect the value of prior Federal investments to a significant extent.
- Project-based framing. Section 743 is framed in terms of "projects" rather than "uses," codifying FAA practice.
- No partial-project jurisdiction. If FAA has ALP authority over only a portion of a project, it may not extend that authority to non-aeronautical portions of the project.
- Federally assisted property retained. FAA retains jurisdiction over any property acquired with federal assistance — without exception.
- Notice of intent process. Section 743 replaces the prior "Section 163 determination" with a streamlined notice process: if the Secretary fails to object within 45 days of receiving notice of intent, the project is deemed outside FAA authority.
- Limitation on indirect regulation. FAA may not "directly or indirectly regulate or place conditions on" any project for which it lacks ALP approval authority, "through any grant assurance."
The NPIAS: Which Airports Are in the System
The National Plan of Integrated Airport Systems (NPIAS), published by the FAA every two years, identifies the airports that are part of the national airport system and are eligible for AIP and BIL grants. The 2025–2029 NPIAS, published September 30, 2024, identifies 3,287 existing public-use airports and five proposed nonprimary airports anticipated to open by 2029.