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.

The 2025–2029 NPIAS estimates $67.5 billion in eligible and justified airport development over its five-year period, an increase of $5.1 billion (8%) from the prior NPIAS issued in 2022. Only airports included in the NPIAS are eligible for AIP and BIL grants.

Airport Category	Number of Airports	Share of Development Costs	Estimated 5-Year Need
Large hub	31	~37%	~$25 billion
Medium hub	34	~14%	~$9.3 billion
Small hub	70	~12%	~$8 billion
Nonhub	249	~12%	~$8 billion
Nonprimary	2,897	~28%	~$19 billion

Master Plan Elements

AC 150/5070-6B organizes the master plan into a series of elements. The specific scope varies by airport size and complexity, but a complete master plan for a commercial service airport includes:

1. Pre-Planning

Initial needs determination, request for proposals, consultant selection, study design, contract negotiation, and application for study funding. Federal planning grants provide significant cost-sharing support for eligible airports undertaking master plan and ALP updates.

2. Public Involvement

A public involvement program is established at study outset and maintained throughout the process. Stakeholders include airlines, tenants, fixed-base operators, local government, community groups, and the general public. The public involvement record is required for any subsequent NEPA environmental review.

3. Inventory of Existing Conditions

Data collection covers the airport's physical plant (runways, taxiways, aprons, terminals, hangars, navaids, airfield lighting, utilities), airspace, air service, financial performance, environmental setting, land use, surface transportation access, and socioeconomic characteristics of the air trade area.

4. Aviation Activity Forecasts

Forecasts of passenger enplanements, aircraft operations (by type), based aircraft, and cargo volumes are developed for short-term (5-year), medium-term (10-year), and long-term (20-year) planning horizons. FAA forecast approval is required before the master plan may proceed to facility requirements. The consistency criteria are:

• Towered airports: The baseline scenario must differ from the current Terminal Area Forecast (TAF) by less than 10% at Year 5 and less than 15% at Year 10.
• Non-towered airports: Different thresholds apply; forecasts must be supported by data and accepted forecasting methodologies.

FAA approval is limited to the 10-year outlook period. Forecasts for Years 11–20 may be "accepted for planning purposes" to preserve options for long-term facility needs, but are not formally approved.

5. Facility Requirements

The facility requirements analysis compares forecast demand to the capacity and condition of existing facilities, identifies deficiencies, and determines the timing and scale of new facility needs. The analysis covers:

• Airfield: Runway length requirements, runway/taxiway capacity, design aircraft classification, dimensional standards (runway-to-taxiway separation, shoulder widths, safety areas), pavement condition
• Terminal: Gate requirements (based on design day flight schedule and aircraft turnaround times), holdroom area, ticket counter positions, baggage claim devices, TSA checkpoint lanes, concession space
• Landside: Automobile parking, ground transportation facilities, rental car operations, curbside capacity, roadway access
• Support: ARFF facilities (14 CFR Part 139 index), fuel storage, maintenance buildings, cargo buildings, general aviation hangars, FBO leaseholds

6. Alternatives Development and Evaluation

The master plan develops alternative configurations for each recommended facility improvement and evaluates them against operational performance, environmental impact, cost, constructability, and phasing criteria. The preferred alternative for each facility component is selected based on this evaluation.

7. Airport Layout Plan Drawing Set

FAA Standard Operating Procedure 2.00 (October 1, 2013) specifies the required drawing sheets:

• Cover Sheet
• Data Sheet (airport elevation, reference point, runway data, design standards, wind data, ARC)
• Airport Layout Plan Drawing (plan view of existing and proposed facilities: runways, taxiways, aprons, buildings, RPZs, BRLs, property boundaries, land use)
• Airport Airspace Drawing (14 CFR Part 77 imaginary surfaces and obstruction analysis)
• Inner Portion of the Approach Surface Drawings (enlarged plan and profile views of approach surfaces beyond each runway end)
• Runway Departure Surface Drawing (One Engine Inoperative departure surface analysis)
• Terminal Area Plan (detailed layout of terminal area: gates, aprons, terminal buildings, roadways, parking)
• Airport Land Use Drawing (existing and planned land uses on airport property)
• Off-Airport Land Use Drawing (land uses in the airport environs, including noise contour overlay if applicable)
• Airport Property Map / Exhibit A (property boundary survey with acquisition parcels, easements, and federal interest)

The ALP is not a static document. It is updated to reflect new development proposals, changes in design standards, or revisions to the capital program. An ALP update can be accomplished as a standalone study if the changes are limited.

8. Environmental Considerations

The master plan identifies potential environmental impacts of recommended development and determines whether a Categorical Exclusion (CATEX), Environmental Assessment (EA), or Environmental Impact Statement (EIS) will be required under the National Environmental Policy Act (NEPA) for each project. The master plan itself is not a NEPA document; it is a planning study that precedes and informs the NEPA process.

9. Implementation Plan and CIP

The implementation plan sequences recommended projects into short-term (0–5 years), medium-term (6–10 years), and long-term (11–20 years) phases. The short-term program feeds directly into the airport's 5-year Airport Capital Improvement Plan (ACIP), which is the basis for AIP grant applications.

10. Financial Feasibility Analysis

The financial feasibility analysis demonstrates that the sponsor can finance the recommended CIP. It identifies funding sources (AIP/AIG grants, PFCs, bonds, airport cash, state grants), projects revenue and expense trends, and evaluates the impact of proposed capital spending on airline rates and charges, debt service coverage, and overall financial health.

FAA's Role: What It Approves and What It Does Not

The FAA reviews the entire master plan to confirm that sound planning techniques have been applied. However, the FAA only formally approves two elements:

1. Aviation activity forecasts — The forecast must be reviewed for consistency with the TAF and approved before subsequent planning elements proceed.
2. The Airport Layout Plan — ALP approval indicates conformance with design standards and that proposed development is safe and efficient.

The FAA does not approve the financial plan, the implementation schedule, the alternatives evaluation, or the narrative report. Those are the sponsor's planning products. The sponsor retains full discretion over which projects to build, when to build them, and how to fund them — subject to its own governing body's authorization and, where applicable, airline consent provisions in use agreements.

Relationship Between the Master Plan and Capital Funding

The master plan is the gateway document for airport capital funding:

Funding Source	Master Plan / ALP Role
AIP grants	Projects must be shown on an FAA-approved ALP to be eligible
BIL AIG grants	Same AIP eligibility criteria apply
BIL ATP grants	Terminal projects must be consistent with the ALP and the airport's CIP
PFC authorization	FAA reviews PFC applications for consistency with the ALP; PFC-eligible projects must be airport development as defined in 49 U.S.C. § 40117(a)
Revenue bonds	The master plan's CIP and financial feasibility analysis form the basis of the plan of finance in bond Official Statements
TIFIA loans	TIFIA application includes the project's relationship to the airport's capital plan and ALP

An airport that lacks a current ALP or has development not reflected on the ALP cannot receive AIP grants for that development. The ALP is, in practical terms, the prerequisite for accessing federal airport capital funding.

Analytical Considerations

Several areas present planning and financial implications for airport sponsors undertaking master plan updates:

• Forecast vintage. FAA forecast approval is based on consistency with the currently published TAF at the time of review. If the TAF is updated during the master plan study, the forecast must be re-evaluated against the new TAF. Airport sponsors may wish to time their forecast submittal to occur either well in advance of or after the TAF's annual update in late January.
• Section 743 implications for non-aeronautical development. The 2024 Reauthorization's limitation on FAA authority over projects outside its ALP jurisdiction — and the prohibition on using grant assurances as an indirect regulatory mechanism for such projects — creates new flexibility for airports evaluating non-aeronautical land development on sponsor-owned, non-federally-acquired property. The boundaries of this flexibility are still being defined through FAA guidance.
• NPIAS development estimates vs. actual need. The NPIAS estimates $67.5 billion in eligible development for 2025–2029. ACI-NA's separate 2025 Infrastructure Needs Study estimates $173.9 billion for the same period. The difference reflects that the NPIAS captures only AIP- and BIL-eligible development as identified through the airport capital planning process, while the ACI-NA figure includes all airport infrastructure investment regardless of federal eligibility.
• ALP and bond covenants. Airport bond indentures require the sponsor to maintain the airport in conformance with federal requirements, which includes maintaining a current ALP. A lapsed or non-conforming ALP could create a technical covenant issue under some indenture structures, even if no operational deficiency exists.