Land Use Issues | Aurora Airport


On December 16, 2020, Oregon’s Land Use Board of Appeals (LUBA) delivered a non-decision on an appeal concerning the master plan for the Aurora State Airport. Specifically, LUBA handed down a dismissal of the appeal claiming that the Board did not have jurisdiction!

Specifically, the Cities of Aurora and Wilsonville, 1000 Friends, Friends of French Prairie and Aurora Planning Commissioner Joseph Schaefer as an individual were appealing a decision made by the Oregon Aviation Board (OAB) in October of 2019. That decision approved “Findings of Compatibility” for the Aurora State Airport Master Plan which the Aviation Board also asserted had been approved and adopted in November of 2011. The Department of Justice attorney for the Department of Aviation (ODA) told the OAB in October 2019 that the decision the board was about to make was “not a land use decision,” in spite of the fact that the master plan in question contemplated taking 55 acres of EFU land south of the Aurora State Airport for expansion. Also ignored were these subjects (assignments of error):

  1. The Aurora Airport Master Plan was never adopted according to minutes of the 11/2011 OAB meeting
  2. ODA tried to skirt Statewide planning goals by contending they did not apply because the master plan was part of the Marion County comprehensive plan
  3. ODA failed to coordinate with required local governments (Aurora, Wilsonville and Clackamas County)
  4. ODA failed to comply with its own State Agency Coordinating rules and coordinate with state agencies
  5. ODA ignored Goal 6 about water discharge and Goal 9 about carrying capacity of the land
  6. ODA ignored Goal 11 in failing to plan for necessary public services
  7. ODA ignored the requirement in Goal 12 by not developing an alternatives assessment
  8. ODA failed to make findings of compatibility before adopting the master plan, not eight years after alleged plan adoption
  9. ODA failed to comply with the goal exception for expansion of urban uses onto farmland and did not assess the impact on local agricultural operations

Does the LUBA decision clear the way for runway extension?

The Aurora State Airport contains both public and privately-owned assets. The state airport portion is composed of a runway, taxiway, aprons and some hangar space owned and operated by ODA. The rest of the property that comprises the “airport” and runs primarily parallel to the runway. That part is privately owned. The biggest proponents and financial supporters of expansion are those who would financially benefit from this expenditure of tax dollars. They are aviation companies, flight schools and real estate developers. They have not only paid for much of the legal work over the years, but are actively promoting LUBA’s dismissal of the appeal as a “win” for the private developers of the Aurora State Airport. They assert that it “clears the way for runway extension,” or “the end of delays in improving the airport,” and are attempting to reframe the argument as a waste of time and local taxpayer money to pursue legal remedies.

The fact of the matter is that the LUBA decision does not “clear the way” for runway extension. That is because setting aside the appeal does not fund and green-light runway extension. ODA has another problem, separate from the legal challenges, and that is the recent ruling. The Federal Aviation Administration ruled that the Aurora State Airport master plan is so old and outdated that it is not considered valid and has to either be updated or re-done. Both are multi-year efforts; without a valid master plan ODA can’t apply for FAA funding or receive permission to proceed on construction. This is evident by the fact that in December ODA announced the withdrawal of an environmental assessment for a small construction project to improve the north runup area… after being informed by the FAA that their master plan was not valid.

What about Oregon’s Land Use laws?

Completely separate from the FAA/master plan matter are the State of Oregon land use requirements—the legal requirements in the state land use system. The FAA is not responsible for land use, and directs airports and aviation departments to understand and comply with their relevant land use laws.

The LUBA appeal of the OAB decision specifically focused on important land use matters and  issues of public process. It also questions the credibility of the OAD to fairly administer the airports in a way responsive to the concerns of surrounding communities. Specifically, the LUBA appeal was not about approving or renouncing the Aurora Airport Master Plan. Rather it was about the legal assertion by the OAB that the master plan which contemplates taking fifty-five acres of agriculture land ‘was not a land use decision,’ and thus the land use system requirement did not apply. These are all examples of problems pertaining to poor management, lax oversight and the deficient operational capacity of ODA. The Portland State University Oregon Solutions division called out these problems in the Aurora State Airport Assessment Report of December 2018.

This is not an arcane or theoretical matter. In the decision to dismiss, LUBA essentially said that if a state agency (here, ODA) can demonstrate that their master plan is compatible with a County Comprehensive Plan, then they are excepted from demonstrating that the comply with the State land use requirements.

Can a County Comprehensive Plan replace the State land use system?

In Marion County, where the Aurora Airport is considered to be “an engine of growth” and the largest campaign contributions for commissioner races over the past decade came from Aurora Airport interests, is it little wonder that a master plan was easily be adopted into the County Comprehensive Plan?

Except, it wasn’t!

What was adopted into the Marion County Comprehensive Plan was the 1976 Aurora Airport master plan, which was updated in 2000, and that was subsequently updated in 2012. The 2012 Aurora Airport Master Plan was not “adopted” into the comprehensive plan and no land use standards were applied to analyze and assess the changes and impacts. Instead, the Board of Commissioners adopted a resolution that “acknowledges and supports the 2012 update to the Aurora State Airport Master Plan.” A resolution of nonbinding support is not a land use decision, especially if it includes no analysis or assessment of impact.

What should be clear to anyone who looks at the history and facts is that this comprehensive plan loophole which LUBA supported is a way to skirt the State land use and public process system, and what actually happened with the dismissal decision was LUBA giving ODA a pass on having to conduct the usual and customary land use impact assessments and the corresponding need to receive exceptions to specific Goals in the land use system.

That is precisely why an appeal (Petition for Judicial Review) to the Court of Appeals is necessary and has been filed—because LUBA elected not to address the assignments of error, but rather to dismiss on the arguable basis of jurisdiction. It is our view that the Court of Appeals will prove to be a court more interested in justice and law and less concerned about protecting the questionable decisions of another state agency.

State agencies have an obligation to serve all taxpayer and citizens, not be a cheerleader for industry interests. It is time for the Governor and legislative leadership of State of Oregon to correct two decades of damaged public process, incompetent management and cronyism by the OAB and the ODA. This conflict has been caused a callous disregard for the local citizens and municipalities and now must be corrected by the appellate court.

Airport developers who are ready to cash in by buying cheap farmland to flip as an urban use may say that this is a victory, On the contrary, it was not a victory. LUBA deepened and prolonged a decades long conflict rather than resolving it. Nor is the LUBA dismissal in any way an approval of the Aurora Airport Master Plan. This self-serving interpretation ignores the recent FAA ruling that the master plan is outdated and no longer valid.

The LUBA decision ignored the substantial legal questions which demand attention by the Court of Appeals.

The fact of the matter is that any assertion that the LUBA dismissal is somehow approval of the Aurora Airport Master Plan is self-serving blindness because of the recent FAA ruling on the state of that master plan. That situation is compounded by the substantive legal questions which LUBA chose to avoid and which now move to the Court of Appeals.


The LUBA Appeal filed by FOFP against the letter from the Director of the Oregon Department of Aviation (ODA) was dismissed by LUBA on Dec. 10, 2019, because “we conclude that the challenged decision is not a land use decision as defined in ORS 197.15(10)(1)(B).” The importance of this appeal though, and the responses to the demand letters sent to the Director of ODA is that it prompted ODA to hold a hearing on compatibility in September, which then led to the Aviation Board (OAB) hearing in Sunriver.

As described previously, the purpose of the hearing was changed after being announced, and was held under the title of Adopt Findings of Compatibility and Compliance in Support of ODA’s State Agency Coordination Program for Aurora State Airport Master Plan Update. That is what the Aviation Board did, even though it was pointed out to them in oral and written testimony that they were violating the ODA master plan process by adopting findings of compatibility eight years after they say the Aurora Airport Master Plan was adopted (they should have been adopted before approval), and they were also violating Oregon’s land use system by seeking to defer to Marion County for “land use decisions” instead of addressing the land use Goals as they exist.

The result of this decision by the Aviation Board prompted a second round of LUBA Appeals filed on November 20 by Joseph Schaefer, City of Wilsonville, 1000 Friends of Oregon and FOFP, specific to the fact that: 1) the Master Plan was, in fact, not adopted by the Board at it’s October 27, 2011 meeting; 2) that adopting findings of compatibility eight years later violated ODA’s own regulations; and 3) that the decision made by the Aviation Board was in fact a land use decision (even though the Agency’s attorney argued that it was not).

Of note, while contending that a final decision was made by the Aviation Board at the Sunriver hearing, the agency has not published a decision, and when asked said they had no plans to publish a written decision! While there have been motions to intervene in favor of that airport (Aurora Airport Improvement Association, Wilsonville Chamber of Commerce and Marion County) and in favor of the Appellants (Clackamas County), the majority of the intervening time has been spent on determining what comprised the record for this appeal.

ODA has argued that the Aviation Board hearing in Sunriver on Oct. 31 was a stand-alone event, and that all documents prior to the “final” published version of the 2012 Master Plan for the Aurora Airport should not be in the record. That means they are trying to exclude the versions of the master plan as it was being developed, as well as the documents and plans prepared by ODA and its aviation consultant. On May 12, 2020 LUBA issued an Order on the Record in which they stated that they “we reject OAB’s premise that the 2011 and 2019 proceedings are not the same proceeding for purposes of determining the content of the record.” They went on to agree that other materials including “the minutes and audio files of those meetings, and public notices of Aviation Board meetings and purported decisions” should also be in the record. There is still a record matter to be settled, concerning ODA staff and consultant reports and PowerPoint slides, etc. for master plan meetings.

Once this final matter on the record is settled, the appeal should move to the filing of briefs. What is apparent, though, is that both ODA and the Aviation Board conducted a master planning process for Aurora that was characterized by lack of transparency and public process, and that behavior has continued as they have had to address the current LUBA appeal of the so-called approval of the Aurora Airport Master Plan.

A very good overview article by Bill Poehler appeared in the Statesman Journal on June 26. [Download it here}


The 2020 Wilsonville election for City Councilor and Mayor will undoubtedly go down as one for the record books! At least in terms of the amount of outside money coming in and the brazen manner in which Aurora Airport interests are funding candidates to take control of the City Council.

Most, but not all, of the money is flowing through Jobs Political Action Committee (ID#16428) set up and run by lobbyist JL Wilson of Public Affairs Counsel. In addition to local airport real estate interests (who have been pushing for airport expansion for a decade) financial supporters include politicians like Sen. Betsy Johnson and Knute Buehler.

Follow the Money Flowchart, Wilsonville Council Election, Updated October 2020

The amount of outside money has caught the attention of at least one major news outlet, namely OPB, who’s Jeff Mapes did the first story on it. This was followed by local coverage in the Wilsonville Spokesman by Corey Buchanan (articles in PDF at bottom of page). On top of the amount of money being spent to flip the City Council, is the absolute brazenness with which the funders, the lobbyist and the candidates talk about it in public and to the media.

Here are the eight most eye-opening facts and disclosures in this campaign so far:

  1. As documented in the State’s campaign finance reporting system, almost $20,000 is contributed to the campaigns of Ben West, John Budiao and Imran Haider by JL Wilson’s Jobs Political Action Committee, funded by contributions received from TLM Holdings (Ted Millar), Aurora Aircraft LLC (Bruce Bennett), MB Holdings (Maletis brothers), and Senator Betsy Johnson.
  2. As Jeff Mapes wrote in an OPB story on the campaign: “West has received at least $14,000 from airport interests, more than a third of the $39,000 he’s raised. In the last contested mayor race, in 2012, current Wilsonville Mayor, Knapp raised less than half that, $16,000. His opponent that year didn’t show any fundraising. This year, Budaio received at least $5,000 in airport-related money – also just over a third of his fundraising – and Haider received at least $2,000, which represents almost all the money he’s raised.” One special interest is dominating the funding of these three candidates.
  3. Mapes also reported that “Bennett and Millar said they hired Salem lobbyist J.L. Wilson, who controls JOBS PAC, to work with them on airport issues. And they gave Wilson the flexibility to decide how to direct the money to the three candidates. Such campaign-finance maneuvers are legal under Oregon law.” But it raises ethical issues about undue influence by a lobbyist for a special interest with legal and policy decisions pending before a governing body.
  4. In spite of Bennet and Millar’s denials about airport expansion bringing in more, larger aircraft, Mapes asked Senator Johnson the question: Would the runway expansion make Aurora a major corporate jet airport? Her answer: “I hate to break it to you,” said Johnson, the state senator, “but it already is.” Still, she also downplayed the notion of a big increase in private jet traffic, saying the facility just isn’t big enough for that.”
  5. Corey Buchanan reported in a Wilsonville Spokesman article on the campaign finances that “The treasurer of the Jobs PAC, James Wilson, is a principal of the Public Affairs Counsel and one of his clients is the Aurora Airport Improvement Association, which recently started a Friends of the Aurora Airport initiative designed to highlight the positive contributions of airport businesses. Wilson was also involved with a failed attempt to get the runway extension funded through a Federal Aviation Administration grant program.” Are oversized campaign contributions to a local city council race an acceptable practice when that body makes land use decisions which benefit that lobbyists clients? This strategy threatens all future local control of Oregon’s Land Use system.
  6. Buchanan also reported that JL Wilson stated, “We want positive change in Wilsonville. That hasn't been a top-of-mind objective until now…airport leaders had been a ‘dormant group’ that ‘let the naysayers run over them’ until becoming more active recently.” Alternatively, local citizens have asked their city council to protect their interests, now outside interests are trying to take control of that city council to get the development policies the outsiders want.
  7. During a Candidate Forum sponsored by the Wilsonville Chamber of Commerce and the Wilsonville Spokesman, in response to a question asking candidates to explain their campaign contributions and “what ties to business, special interest or PACs they have,” and “should citizens be comfortable with candidates getting big donations?” Both Ben West and John Budiao described the contributions they’ve received from family, friends and small local businesses, but neither said a word about the larger and policy changing aims of Wilson’s Jobs Political Action Committee contributions.
  8. In answer to that same question, Imran Haider said, “When I first signed up to run for City Council, I received a call asking, ‘Hey, would you support possible extending the runway at Aurora Airport since it might create jobs. I said, Yeah!’” The result was $2,000, as Mapes reported, almost all the money his campaign has raised. This statement is an admission of a quid pro quo and should concern all citizens who care about transparency in government.

It is worthy of note that in the previous 2018 City election, the major campaign donations to Ben West and John Budiao came from Ted Millar (TLM Holdings), and that resulted in Ben West being elected to City Council where he has been the standout “No” vote on all decisions concerning involvement of the City in expansion of the Aurora Airport—where the City has a real interest due to the absence of infrastructure like transportation, storm water, sewer and water.


One of the interesting events to observe in the past three years has been the number of times that the Wilsonville Chamber of Commerce, and the leadership of the Aurora Airport Improvement Association, along with Ted Millar of TLM Holdings (owner of Southend Airpark and the old church camp development) have appeared before the Wilsonville City Council to excoriate them. And what was the message: we’re the good guys just trying to run our businesses, and you (the City of Wilsonville) have no business getting involved in the expansion of an airport outside your city.

It doesn’t matter that most flights fly over Charbonneau and Wilsonville, or that increased traffic at the Aurora Airport directly impacts city traffic on I-5, or that the airport has inadequate infrastructure like sewer and water. The city should mind its own business and leave us alone to do what we want.

And after the last election cycle saw Ted Millar as the largest campaign contributors to Ben West and John Budiao, which assisted Ben West get elected to the Council where he has uniformly voted against Council actions to limit airport expansion, now as the next election looms even more outside money is pouring in. Ben West said “The Aurora Airport is a gift to Wilsonville” at a city council meeting. The ‘gift’ appears to be generous campaign contributions to Ben West and John Budaio!

It started on Friday, Sept. 18, with a fundraiser for John Budiao that featured Sen. Betsy Johnson as the keynote speaker, lined up next to airport developers and conservative politicians.

John Budiao Fundraiser Invitation

It goes without saying that it is unusual for a Senator from Scappoose, who is also Co-Chair of the Ways and Means Committee, to be dropping into a local city election, and leaving big contributions to a city Mayor and Council race. But, oh wait! Sen. Johnson used to be Aurora Airport Manager, has been the most ardent legislative supporter of funding Aurora Airport expansion, and describes the commercial interests there as “The Family!”

In the past few months the Aurora Airport Improvement Assoc. has launched a public relations campaign on behalf of the Aurora Airport, a classic example of “greenwashing” the airport issue. The ‘Friends of the Aurora Airport’ is operated by Public Affairs Council, JL Wilson’s lobbying company, who also operates the I Love Aurora Airport Facebook page for their client.

Now we see that JL Wilson has organized a public action committee called Jobs Political Action Committee, and an awful lot of outside money is now running through that PAC to fund the campaigns in Wilsonville. The goal: take over the City Council and make it airport friendly.

Follow the Money Flowchart, Wilsonville Council Election

Citizens of Wilsonville and Charbonneau, as well as the surrounding area, need to understand that most of the money funding these campaigns is coming from corporate interests who own business or operate aircraft at the Aurora Airport and who are trying to keep their names hidden by contributing through this PAC. This lack of transparency in contributions and expenditures is an attempt to conceal donors and interests, is not just about electing fresh faces to the Wilsonville City Council. It is about flipping the Wilsonville City Government to change city policy about the Aurora Airport.

This is about taking over the City Council and installing airport friendly politicians who are financially dependent on airport contributors!


On Wednesday, August 11, in the second Special Session of 2020, the Legislature faced with a $1.2 Billion deficit due to lost revenue from the COVID-19 economic downturn cut the budgets of many important State government programs.. As reported in The Oregonian, most of that funding was originally designated for social services and PERS deficit reduction.

What was not questioned and passed with no public input (or debate) in the Capital Construction Budget bill was funding for the Run Up Area and Taxiway Improvement construction at Aurora State Airport!

  • Run Up Area capital construction budget = $205,000
  • Taxiway Improvement construction budget = $113,000
  • TOTAL = $318,000 for Aurora Airport construction

But Wait, There’s More! In order to proceed with the Run Up Area and Taxiway construction, Dept. of Aviation needs to receive approval from the FAA for their Environmental Assessment workup. August 5 was the close day for public comments on the Draft Environmental Assessment submitted by ODA and their consultant (Century West) to the FAA.

Among those commenting on the Draft EA were: City of Wilsonville, City of Aurora, Friends of French Prairie and Charbonneau Civic Affairs.

Here’s a short list of the deficiencies pointed out and objections made to the FAA:

  • In multiple places within the Draft EA, the 2012 Aurora Airport Master Plan is referenced, but not once did ODA disclose that appeals have been filed against that master plan at Land Use Board of Appeals (LUBA) and in circuit court. In other words, “litigation is pending” and it was not disclosed to the FAA.
  • The Draft EA contends that a noise study was not required because total operations do not exceed 90,000 per year, yet elsewhere in the report they estimate 94,935 total annual operations.
  • In the area of infrastructure, while the Draft EA does appear to address storm water management deficiencies, it makes no mention of the lack of a viable sewer system for the airport.
  • In spite of the acknowledgment that Run Up area expansion and improvement of the taxiways is needed to accommodate future growth of the airport, the Draft EA argues that air emissions will not increase above minimal thresholds and will not “significantly impact or alter air quality.”

As a reminder, in January of 2019, Oregon Solutions released an Assessment Report on the Aurora State Airport—commissioned by the Legislature when ODA was seeking approval to apply for $37 million to expand the airport—and their findings included:

  • A master plan process characterized by “broken public process” compounded by “lack of clarity . . . about the purpose of an airport master plan”
  • “Significant questions have been raised about the Department [of Aviation] capacity and capability to carry out its mission . . .”
  • “The airport has a noise abatement procedure, but it is voluntary and frequently violated and the noise problems for Aurora, Charbonneau and Wilsonville promise to worsen not improve.”
  • “No assessment of air pollution impact due to expansion have been conducted.”

Yet here we are a year and a half later, and the very same concerns identified by Oregon Solutions have not been addressed, but are now present in the Draft Environmental Assessment to begin the airport expansion.

All this in addition to the driver of the current LUBA appeal, which was the assertion made by the Aviation Board at its October 31, 2019 hearing on the Aurora Airport that “if compatibility with a local comprehensive plan can be demonstrated, then Statewide Planning Goals do not apply,” and that a decision to expand the Aurora Airport was essentially not a land use decision.

How is it that in the face of major State budget problems we can cut programs, but fund capital construction that benefits less than 2% of the population? Why is the Governor’s Office turning a blind eye, and the Legislature continuing to fund this problem-filled expansion project?


Dept. of Aviation held a hearing on “land use compatibility” regarding the Aurora Airport Master Plan in Salem on September 24. Following the hearing, testimony was consolidated by ODA staff and sent to the Aviation Board for their meeting on October 31 in Sunriver—240 miles away from the Aurora Airport. That Aviation Board meeting became a hearing on the Aurora Airport Master Plan…until it wasn’t.

Meaning, that when it was first announced, the hearing had the following Action Item “Adopt the Aurora Master Plan, Airport Layout, Findings of Compatibility, and Findings of Compliance.”

Then, after being challenged by the City of Wilsonville attorney over how they could “adopt” a master plan that they contend was already adopted in 2011, they changed the hearing and Action Item to “Adopt Findings of Compatibility and Compliance in Support of ODA’s State Agency Coordination Program for Aurora State Airport Master Plan Update.”

In other words, a legal mechanism to “adopt” the master plan without formally adopting the master plan.

What was most striking to anyone familiar with the Oregon state land use system and the statewide planning goals, was listening to the ODA attorney brief the Aviation Board during the hearing, attempting to make the case that that the master plan was exempt from Statewide planning goals:

  • The 2012 Aurora Airport Master Plan is an update of the 1976 Master Plan, which has already been adopted into the Marion County Comprehensive Plan
  • OAB is governed by Administrative Rules (same as ODOT rules) and the only jurisdiction with planning authority is Marion County
  • The Findings of Compatibility & Compliance confirm that they are fully compliant with the Marion County Comprehensive Plan
  • If compatibility with a local comprehensive plan can be demonstrated, then Statewide Planning Goals do not apply.
  • You are confirming a plan already approved and approving compatibility findings: no land use decision is being made

It does boggle the mind because the master plan contemplates expanding onto 55 acres of EFU ag land south of the airport. Further, the Findings of Compatibility & Compliance were supposed to have been finalized and adopted before final approval of the master plan, and the concept that Statewide Planning Goals do not apply is both beyond the pale and calls into question the role of the land use system when it comes to airports and aviation.

Is the aviation system exempt from the land use laws all the rest of us have to follow?

According to the Dept. of Aviation and the Aviation Board, the answer is a resounding YES!

Adding further outrage to the undertaking was the assertion that the only “affected jurisdiction” is Marion County. Not Wilsonville. Not Aurora. Not Clackamas County. Only Marion County, and thus only they have a say.

FOFP, City of Wilsonville, City of Aurora and Charbonneau all provided written testimony in opposition to the proposed action item. It passed unanimously.

You can download a copy of the FOFP opposition testimony in PDF here.


Using recently available ACTUAL objective data from the FAA Air Traffic Activity Data System (ATADS) FOFP is now able to compare projected growth in Total Operations and Based Aircraft found in the 2012 Aurora Airport Master Plan with what has actually occurred. These forecasts, along with Constrained Operations data, constitute the justification for lengthening the runway and expanding the airport at Aurora, and can now be seen as not just willful misrepresentations but falling as much as 40% short of forecast.

The much-heralded Constrained Operations Study commissioned by ODA in 2018 turns out to be based on a highly suspect survey of pilots. Stretching credulity, it claims a 33% increase in Constrained Operations since 2012, in spite of the fact that actual Total Operations are running an average of 44% below forecast, and based aircraft are down by 8.2%.

Download the White Paper


Based on the legal opinion that the recant letter sent by Director Betty Stansbury on August 21, 2019 constituted the “land use decision” on the 2012 Aurora Airport Master Plan, FOFP has filed a LUBA appeal. The letter ostensibly sought to clarify and correct Director Stansbury’s previous statements about the status of the 2012 Aurora Airport Master Plan by denying them and claiming the Master Plan had been adopted.

In contrast to and in conflict with a series of statements during the period of 2012 to 2017 from the Dept. of Aviation that the 2012 Aurora Airport Master Plan had not been “approved” and that it had not been “legally adopted” by the Aviation Board, this new statement attempts to claim that it had been approved and adopted, and constitutes continued efforts to avoid compliance with State land use laws and agency coordination.

Download LUBA Appeal in PDF


Oregon Dept. of Aviation announced they are holding a meeting on Sept. 24 in Salem, from 3:00 to 5:00 PM to gather "information on the compatibility of the Master Plan with applicable land use plans and statewide planning goals." Written testimony will be accepted, but verbal testimony is limited to two minutes. ODA will then "present findings of compatibility" to the Aviation Board at its October 31 meeting in Sunriver.

Download announcement in PDF

On September 6, 2019, FOFP through its land use attorney, submitted a Protest Letter about the prejudicial nature of this meeting, and chronicling the land use violations and irregularities that have characterized this master plan from the outset.

Download protest letter in PDF


On August 21, 2019, Betty Stansbury, Director of the Dept of Aviation sent a letter to FOFP’s land use attorney in which she "clarified and corrected" all her previous statements about the Aurora Airport Master Plan, now claiming that it had, in fact, been approved and adopted by the Aviation Board in 2012.

Essentially, she and the Department, and by extension the Aviation Board, are now trying to claim that:

  • The Aurora Airport Master Plan was approved by the Aviation Board in 2011 - although no Aviation Board meeting in 2011 had an agenda item to do so, and thus no public notice of this intended action was provided.
  • That the Aurora Airport Master Plan was properly modified and updated, though the Planning Advisory Committee was disbanded, and final versions were not presented to the PAC.
  • That the Aurora Airport Master plan process resulting in the 2012 Master Plan was compliant with public notice and comment requirements, though none occurred

This in spite of her previous statements which confirmed that the 2012 Master Plan, as posted on the ODA web site, was not approved and was never formally adopted by the Aviation Board.

Download letter in PDF


In advance of the August 1 Oregon State Aviation Board meeting, a new document appeared as part of the read-ahead material for Aviation Board members. That document, the new Dept. of Aviation Master Plan Process flowchart, aims to define agency master planning so it conforms to the agency’s newly adopted State Agency Coordination Program.

Aurora Airport Runway Extension with Aurora City Boundary

The flowchart is not attributed and does not contain an effective date, but nonetheless appears to summarize how the ODA will do airport master planning in the future. What is immediately striking is how many significant deviations from this defined process occurred during the Aurora Airport Master Plan process from 2010 to 2012.

Claiming that this new process is part of ODA’s new State Agency Coordinating (SAC) Program and did not apply at the time of Aurora Airport master planning is not acceptable in that ODA was at the time under the Dept. of Transportation SAC program, which is essentially identical to the new program adopted by the ODA, and which should have been followed at the time.

Therefore, Friends of French Prairie has submitted a letter to Director Betty Stansbury at ODA citing these deviations, and demanding that ODA “start that process over, with a properly constituted Planning Advisory Committee and a good faith commitment to public participation in the process.”

To confirm, the Aurora Airport Master Plan posted at the ODA web site did not follow the master plan process required at the time, was not approved, was never legally adopted. It is nothing more than a draft plan that needs to be scrapped and replaced with the output of a properly conducted master plan process.

Download the FOFP letter and flowchart here.


Following the recent public disclosures made by the Dept. of Aviation that the so-called master plan for the Aurora Airport resulting from the recent master plan process has not been legally adopted by the State Aviation Board, the City of Wilsonville sent a position statement letter to the Dept. of Aviation on June 14. Its central thrust is:

…the City of Wilsonville has had serious concerns about the lack of a meaningful public process in past Aurora State Airport Master Planning processes… Under both the previously binding ODOT State Agency Coordination Program and the more recently adopted program, Wilsonville is both an impacted and interested party with respect to future Aurora State Airport Master Planning and the potential expansion of a runway… Substantial changes have been made to the draft Aurora State Airport Master Plan since the public process closed in 2012. For whatever reason, however, Wilsonville and Clackamas County were effectively excluded from that process in the past… [W]hen the Master Plan process is reopened we are confident that…the ODA will seek participation and input from Wilsonville and Clackamas County.

The absence of a legally adopted master plan comes on top of the other recent discovery, that the Dept. of Aviation by law should have been operating under the State Agency Coordinating Agreements from the Dept. of Transportation (the agency it was split off from) until its own Agreements were finalized. Those ODOT agreements (as well as the soon-to-be-adopted ODA agreements) require the inclusion of all effected jurisdictions (such as City of Wilsonville and Clackamas County). This means that ODA violated its own rules when it entered into an inter-governmental agreement (IGA) with Marion County in 2008. That IGA included an “impact area” map that stopped at the County line and effectively excluded Clackamas County and City of Wilsonville from an active role in the master planning process.

Download the City of Wilsonville letter in PDF here.


Recent efforts by the Oregon Dept. of Aviation (ODA) to expand the Aurora State Airport through a $37 million grant application to the Federal Aviation Administration (FAA) in October 2018 has raised again an underlying, open question unanswered for several years: Is there is a legally adopted master plan for the Aurora State Airport justifying ODA’s application for federal and/or state funds?

Determining the legal status of the Aurora State Airport Master Plan is crucial for many reasons:

  1. The ODA’s $37 million application to the FAA referenced the Aurora State Airport Master Plan as an underlying authority for the grant request, implying that the Plan was legally adopted;
  2. The most recent version of the Aurora State Airport Master Plan dated 2013 available on the ODA website identifies just over $7 million as the total cost for runway extension and related projects — far less than the $37 million requested of the FAA;
  3. The airport master plan is the guidance document for development and operations at the airport, and the absence of a standard public-review process and approval that complies with state law raises question about policies and practices within ODA and the appointed overseeing State Aviation Board;
  4. If the high-profile master plan for the Aurora State Airport was not legally approved, then this raises questions if any ODA airport master plan is a legal document upon which state or federal funding applications may be made.

Friends of French Prairie was informed in 2016 by ODA that the 2013 Aurora State Airport Master Plan produced from the 2009-2013 master-planning process had not been formally adopted by the State Aviation Board. The reason given was that the Dept. of Aviation did not have the required State Agency Coordinating Agreements and Administrative Rules in place to conduct a legal plan adoption.

Then, in March 2017 Friends of French Prairie was informed by ODA that the required State Agency Coordinating Agreements and Administrative Rules had been completed and approved by the State Aviation Board—again without any kind of public notice or comment opportunity.

Since 2017 ODA refuses to answer the question, “Has the master plan for the Aurora Airport been approved and legally adopted?” In this case “legally adopted” means in compliance with Oregon state law, as opposed to “approved by the FAA.”

To resolve this question, in January 2019 Friends of French Prairie retained a land-use attorney, who on Jan. 28 delivered a letter to ODA asking:

Has a draft master plan for the Aurora State Airport been submitted to the State Aviation Board for approval & adoption?

  • Has the Board in fact adopted or approved a master plan for the Aurora Airport? If so, when?
  • If no master plan has been submitted to the Board, what is its current status?
  • What is the status of the Department’s state agency coordination efforts with respect to the master plan? Have these been carried out? If not, how and when will they be carried out and completed?
  • What citizen involvement efforts have been undertaken with respect to the master plan? What further citizen involvement efforts are planned or being planned?

On April 29, FOFP’s attorney received a response from ODA, including the following:

  1. The last Aurora Airport Master Plan was completed in December 2012 but it has not been submitted to the board for adoption.
  2. The State Aviation Board has not adopted a master plan for Aurora.
  3. ODA is awaiting certification of its State Agency Coordinating agreements, and “Adoption of the 2012 Aurora State Master Plan is on hold until this process is complete.

Regarding citizen involvement and public transparency, the ODA letter said:

Once ODA's SAG program is certified, ODA will comply with any applicable requirements in the SAC program when adopting the airport master plan.

The last statement is critical because it turns out that ODA should have been operating under the SAC program it inherited from ODOT (the state agency from which it was crated in 1999), and the ODOT program required:

  • Involvement of all “affected” municipalities
  • Compliance with Statewide Land Use Goals

Therefore, the IGA between ODA, Marion County and City of Aurora which excluded City of Wilsonville and Clackamas County from the Aurora Airport Impact Zone (i.e. affected area) should never have been created, and the absence of any public process around the 2012 Master Plan constitutes violation of the intent of compliance with statewide land use goals.

We await the necessary corrective actions by the Dept. of Aviation to these violations of the rules and regulations they should have been operating under while they conducted the most recent master plan for the Aurora Airport.

Download the ODA letter here.


AURORA, OR; January 18, 2019

On Dec. 12, 2018, Oregon Solutions (College of Urban and Public Affairs at Portland State University) delivered to the Legislative Emergency Board a requested Assessment Report regarding the Aurora State Airport. The legislative request was made in response to the significant opposition presented to the Emergency Board on Sept. 24 when the Department of Aviation requested of the legislature “retroactive permission” to apply to the FAA for $37 million in funds to expand the Aurora Airport. This permission to apply for FAA funds is in conflict with the current Master Plan for the Aurora State Airport, (about which there is significant concern that it was not legally adopted) which describes a future 1,000 foot runway extension estimated to cost $7.1 million.

Oregon Solutions was engaged to conduct an “impartial assessment” including:

  • A civil and accurate dialog by conducting an assessment of local governments, community members, and key stakeholders of the airport
  • Frame the key issues of the diverse stakeholders around the expansion
  • Identify information and process needs

The resulting document, Aurora State Airport Assessment Report (December, 2018) was a comprehensive assessment by an objective and well reputed third-party organization.

In the Findings section of the Assessment Report, Oregon Solutions identified sixteen Substantive Issues:

  • Cost of the Aurora State Airport Runway Extension: the escalation from $7.3M in the 2012 Master Plan to the $37M in the FAA application with lack of clarity as to what the money buys. [page 15]
  • Safety: improving aviation safety has become the major stated justification, but the safety problems are self-created due to basing corporate jets at Aurora that are beyond the airport’s design specifications. [page 15]
  • Noise: the airport has a noise abatement procedure, but it is voluntary and frequently violated and the noise problems for Aurora, Charbonneau and Wilsonville promise to worsen not improve. [page 16]
  • Surface Traffic (Motor Vehicle): essentially no traffic impact assessments have been done and few surface road improvements, and ODOT has opposed airport expansion due to traffic impacts on the I-5 Boone Bridge which is already beyond capacity and causing serious congestion in Wilsonville. [page 16]
  • Land Use: Annexation/Zoning/County Comprehensive Plan
    • Annexation: the airport’s sewer and water problems likely cannot be solved without annexation by City of Aurora which the airport opposes.
    • Farmland / EFU: airport expansion will have significant impact on surrounding EFU farmland in terms of 1) property purchased for the expansion, and 2) development pressure on surrounding farmland.
    • Marion Co. Land Use Decision: the 2012 Master Plan with runway extension was not “adopted” by Marion County, but was “acknowledged” in terms of the County comprehensive plan. [page 17]
  • Public Process: a “broken public process” compounded by “lack of clarity about the distinction between the function and purpose of an airport master plan that is under the guidance of the FAA and ODA, versus land use impacts that are under the jurisdiction of local governments and the State of Oregon.” [page 18]
  • Interagency Coordination: significant questions exist about the validity of ODA’s state agency coordinating agreements (carried forward from ODOT) until creation and approval of their own SACs. [page 19]
  • Constrained Operations: a critical data point to secure FAA funding and one subject to manipulation by the consultant doing the study and ODA granting waivers to oversized aircraft. [page 19]
  • Air Pollution: No assessment of air pollution impact due to expansion have been conducted. [page 20]
  • Airport as an Emergency Operation Location: though the expansion continues to be sold in terms of emergency response, the State’s geology maps show the southern half of the existing airport subject to liquefaction in the event of a major earthquake, and thus its unavailability for emergency or disaster response. [page 20]
  • Employment: the range of job growth based on airport expansion is extremely large (1,200 to 4,000 jobs) and no assessment has been done of local and regional impacts (infrastructure, traffic, etc.). [page 20]
  • Dept. of Aviation Capacity: significant questions have been raised about the Dept. capacity and capability to carry out its mission with its staffing levels and lack of permanent leadership. [page 20]
  • Trust: the identified broken public process and appearance of expansion for the benefit of the few at the expense of the many have resulted in a significant lack of trust. [page 21[
  • Communications: Public communication is widely seen as being characterized by a lack of clarity regarding the process, purpose and outcomes and characterized by communication and coordination gaps between and among decision making agencies and jurisdictions. [page 21]
  • Who Benefits: Significant concern exists about who benefits including which business interests and jurisdictions, and at what expense does expansion occur, especially in terms of the state’s goal to preserve farm land. [page 22]
  • >Community Solidarity: A significant level of community solidarity exists in spite of the challenges and frustrations, but taking advantage of this will require constructive deliberation to inform future decisions. [page 22]

The Assessment Report also includes specific Process Recommendations including:

  • Information, Facts and Procedural Requirements: These include the provision of third-party experts, review of land use rules and conducting a seismic review. [page 23]

  • Communications and Engagement: important identified communications requirements include meaningful public engagement, resources, clarifying facts and fair information sharing. [page 23]

  • Noise abatement:  significant differences exist regarding effectiveness of the current noise abatement program and opportunities for improvement exist. [page 24

  • Long Term Vision: Lack of clarity about a long-term vision has contributed to the conflict and is compounded by the absence of how the Aurora Airport fits into the regional aviation system. [page 25]

We encourage all parties interested in the Aurora State Airport, regardless of position on expansion, to read this report in its entirety and consider the implications of the number of significant issues which this outside, third-party assessment identified.

Download the complete Assessment Report in PDF


On Thursday, Oct. 23, Mayor Tim Knapp, Mayor of the City of Wilsonville sent a “letter to correct the record” to Legislative Leadership and members of the Legislative Emergency Board to address and rebut the wild and incorrect information made at the Emergency Board hearings on Sept. 24 and 26—by both members of the Committee and those he gave testimony.

The subject areas of the letter are outlined below:

Letter to Correct Record of Sept. 26 E‐Board Meeting and Provide Information on Long‐Running Public Controversy over Aurora State Airport Expansion

I am also compelled to correct the record regarding certain incorrect information presented at the E‐Board meeting on September 26. By this letter, I will also clarify Wilsonville’s position on the long‐running controversy at the Aurora State Airport and raise important public‐policy issues of concern to the greater community and state and federal leaders.


  1. The City Did Not Violate Public Meetings Laws:
  2. Aurora State Airport Rated Lowest Priority in Oregon Resilience Plan for Cascadia Subduction Zone Earthquake:
  3. Wilsonville’s Concerns with the proposed Aurora State Airport Expansion Is A Regional Issue, Not a NIMBY Problem:


  1. Aurora State Airport Expansion Without Transparency, Public Notice or Intergovernmental Coordination:
  2. Operations at the Aurora State Airport Directly Impact Clackamas County and Wilsonville:
  3. Family‐Wage Jobs for Marion County Residents:
  4. Unrealistic Expectations for an Expanded Aurora State Airport:
  5. Controversial History over Aurora State Airport:
  6. Aurora State Airport Does Not Take “Pressure” Off Portland International Airport (PDX):
  7. What Is the Real Motivation for the Aurora State Airport Expansion:


  1. Clackamas County and City of Wilsonville Seek Public Dialog and Planning for Involvement:
    • Surface Transportation Impacts:
    • Lack of Alternative Transportation Options:
    • Unfair Competition to Adjacent Jurisdictions:
    • Environmental Concerns Are Significant
    • Potential Harm to the Important Agriculture Economic Cluster


  1. Withdrawal of the ODA application to FAA
  2. Development of an Inclusive IGA with all of the Relevant Local Jurisdictions
  3. Development of a New Aurora State Airport Master Plan
  4. Development of an Oregon Aviation Airports Master Plan

Needless to say, this is both a comprehensive rebuttal of inaccuracies from the Emergency Board hearings, as well as a very thorough documentation of the many problems associated with the Aurora Airport Master Plan and the current effort to secure $37 million in FAA funding to expand the airport.


As an Oregon nonprofit, Friends of French Prairie takes seriously our non-profit status with the State of Oregon and with the IRS, and that includes avoiding endorsing candidates and actively being involved in political campaigns. We are a “public benefit” advocacy organization, mainly focused on educating the public about land use issues.

Where that position approaches politics is when candidates are engaging in behavior that has significant land use implications, but are hiding it or lying about it, or worse yet taking money from parties who are pushing significant land use issues. That is the case in this election.

Marion County: the major land use issue is expansion of the Aurora Airport, and Commissioner Kevin Cameron has publicly denied his previously printed statement that lengthening the runway at the Aurora Airport is his “first priority.” Additionally, he has taken a $5,000 campaign donation from Ted Millar, owner of Southend Airpark and the largest developer at Aurora—who is also the major force behind airport expansion. Colm Willis has repeatedly denied knowing anything about the “Aurora Airport expansion issue” even though he was present at a Farm Bureau briefing in February, would not reply to inquires about his position, and accepted a $2,500 contribution from Ted Millar!.

House District 18: Rep. Rick Lewis consistently denies that the bill he put forward in the last Legislative session, which was co-sponsored by Rep. Rich Vial (HD 26) would have changed the State land use system. However, it would have allowed expansion of the Aurora Airport (and only the Aurora Airport) onto Exclusive Farm Use (EFU) land as an outright allowable use. That is circumventing the land use system at the State and County levels.

City of Aurora: The current Mayor not only supports expansion of the Aurora Airport, but earlier this year he was outed in a conflict of interest as founder and president of a non-profit corporation based at the Aurora Airport, an involvement he did not disclose to the City or public. It turns out that Ted Millar and Bruce Bennett (airport expansion proponents) serve on this company’s Board of Directors. Most of the current City Council have followed Graupp’s lead in supporting airport expansion in various ways—in spite of overwhelming citizen opposition!

City of Wilsonville: Ben West and John Budiao began their campaigns in synch with the Wilsonville Chamber’s support of Aurora Airport expansion (the Chamber Director testified in favor of the Lewis bill), but then went silent when they realized how controversial it is. Now they won’t say if they support airport expansion or not, and dodge the issue. But, that didn’t stop both of them from accepting a $1,500 campaign contribution from Ted Millar.

These are major developments which we believe the voting public needs to know of and understand, because the land use decisions around Aurora Airport expansion will effect all residents in Wilsonville, Charbonneau and north French Prairie. The consequences of a $37 million (YES, you read it correctly!) expansion to the Aurora Airport will transform the region and mainly (we believe) in negative ways.

Because of that, FOFP has felt compelled to run the following educational advertisements in the Wilsonville Spokesman and the Woodburn Independent with the intent of educating the voters at large about the issues and the candidates (stated and unstated) positions on them

The Aurora Airport expansion issue and the loss of farm land, consequent increase in traffic, gridlock, reduced quality of life and reduced residential property values has become a major land use issue in this election.

Remember: the knowledgeable voter is the better voter!

Wilsonville Spokesman ads

Click each ad to see a larger view.

Woodburn Independent ads

Click each ad to see a larger view.


By way of background, on June 20 the Statesman Journal ran an opinion piece by Ben Williams, President of Friends of French Prairie, about two airports: the Salem Airport and the Aurora Airport. The point was that expansion at Aurora will likely come at the expense of the Salem Airport—one which already has a long runway and all the required urban services. In the piece Williams quoted Commissioner Cameron as saying in his first campaign communication that “my first priority is the extension of the Aurora Airport runway ...”

On October 4th, City of Aurora held a joint City Council and Planning Commission meeting to discuss the Inter-Governmental Agreement concerning the Aurora Airport between Department of Aviation, Marion County and Aurora. Commissioner Kevin Cameron was present representing Marion County, and after his testimony he was asked a question by Planning Commissioner Tim Shea: “You are on record as saying your number one priority is to get this airport going. What do you see as the benefit to the citizens… Why are you, or what do you see as the benefits of extension?”

Commissioner Cameron responded in a tirade, saying: “I’m not sure where Mr. Williams came up with that comment and put in an Opinion Piece. I think that’s what you’re referring to. People can write things but … I never said that that was my number one priority and I’m sorry that people write things and say things in the newspapers….but I’ve never said this was my number one priority as Mr. Williams quoted, so …it’s a wrong quote.” When asked again about his priorities for the Aurora Airport he said, “…Mr. Williams lied in that article.”

Commissioner Cameron has long been a supporter and booster of expanding the Aurora Airport, and has testified before the Legislature about it. What we now know is even more striking: four days after he called Ben Williams a liar and denied ever saying that the Aurora Airport was his number one priority, he received a $5,000 campaign contribution from Ted Millar, owner of Southend Airpark, the largest developer at Aurora Airport and the major force behind airport expansion!

This contribution may be coincidentally associated with Cameron’s lying in public about his priorities as commissioner, but it raised the stakes for the current campaign and upcoming election. Ted Millar is the biggest developer at Aurora Airport, who besides owning Southend Airpark also bought the property formerly know as The Reef Missionary Center on Airport Road….and deforested it last year getting ready for development. He has also been the major behind-the-scenes force driving Rep. Lewis’ bill in the last legislature to expand the airport, pushing the Aviation Board to get more aggressive in seeking aviation expansion funding and now besides donating $5,000 to Kevin Cameron’s campaign, he also donated $1,500 to John Budiao’s campaign for Wilsonville City Council. Oh, and he’s a major funding source for the Wilsonville Chamber of Commerce.

Marion County residents should keep this in mind when they vote for Commissioner Position 1, and Wilsonville residents should keep this in mind when they vote for City Council positions.



It was clear from the intent of Rep. Rick Lewis’ bill in the last Legislative session that the special interest developers and the Oregon Dept. of Aviation had something larger in mind than just the 1,000 foot runway extension found in the last Master Plan. The Master Plan that was rigged by the Aviation Board to remove the recommendation of “No Build” but rather to extend by 1,000 feet! The expansion goal was evident in the intent to acquire more property than the master plan contemplated south of the airport to extend the runway protection zone and install navigation equipment.

Now we know what is being planned because of details that have emerged from ODA about their application for FAA funds to expand the airport. They’re going after $37.7 MILLION dollars, of which over $4M is for property acquisition! That’s a lot of land south of the airport. Clearly the goal is to make Aurora into the State’s largest corporate jet airport.

At the beginning of August, ODA notified Legislative leadership that they had submitted a Letter of Intent to apply for FAA funds and would be submitting the full application in mid-September, and would be appearing before the Emergency Board on Sept. 26 to seek RETROACTIVE permission to do so. Enough vocal concern was raised that in advance of the Emergency Board hearing, testimony for and against was taken at the General Government Sub-committee on Sept. 24, and they the Emergency Board heard the matter. The testimony was strong, for and against and mirrored all the testimony given about the Lewis bill before the Transportation Committee early in the year.

The result? Sen. Betsy Johnson suggested that given the level of opposition and the argument by Clackamas County and City of Wilsonville that they had effectively been excluded from the process, that the request be tabled and that Oregon Solutions (a conflict resolution organization led by Karmen Fore) be engaged to mediate between the jurisdictions in advance of the next Emergency Board meeting in December.

What we have now come to find out, from the transcript of the July 19 Oregon Aviation Board meeting, is that Karmen Fore has been a vocal proponent of aviation expansion, glowingly put forward by Ted Millar (owner of Southend Airpark and developer at Aurora Airport) as the kind of advocate needed to expand aviation. Which begs the question: how objective would an Oregon Solutions intervention actually be? In the meantime, the FAA funding application has been submitted WITHOUT approval and is going through the assessment process at the FAA. This is not due or appropriate process, and that application must be withdrawn. Here is FOFP’s assessment of the situation.


Betsy Johnson and the Oregon Solutions Set Up

The week of September 24 was pretty normal for most Oregonians, but not for certain legislators. The Legislative Emergency Board and its General Government Subcommittee (which meet to make legislative funding decisions between actual Legislative sessions) held hearings, and among the agenda items was the Aurora Airport.

What was being requested of both bodies came from the Oregon Department of Aviation, and it was to receive retroactive permission to file an application with the Federal Aviation Administration for $37 Million in Airport Improvement Funds to lengthen the runway and expand the airport.

For those who have been following the Aurora Airport saga, yes—there are at least two eye-openers here. First, $37M is a dramatic increase over the amount estimated at the end of the 2013 Aurora Airport Master Plan where lengthening the runway was forecast to cost under $8M. Second, is the retroactive part: ODA notified legislative leaders that they had submitted a Letter of Intent to apply for these funds on July 29, and then submitted the application in early September, and now were asking for permission after the fact!

That may be normal operating procedure for typical year-to-year funding projects like highways or social services, but expansion of the Aurora Airport has become one of the most contentious issues at the Legislature in the past two years, and is characterized by a major problem: the two most impacted jurisdictions (Clackamas County and City of Wilsonville) were purposefully excluded from the planning process early on—that’s the Inter-Governmental Agreement (IGA) that would have involved them in land use, zoning, transportation and infrastructure decisions.

The principal maestro at the two hearings that week was Sen. Betsy Johnson. Yes, that one—the former manager of Aurora Airport, Senator from Scappoose who with her husband owns an aviation company at that airport, and has been actively promotion expansion at Aurora for years. The same Betsy Johnson that in 2007-2008 was caught out by the media in ethical problems for not disclosing the profit on the sale of 35 acres of land next to the Scappoose Airport, and for proposing legislation to create airport taxing district bills from which she and her husband would directly benefit. As Willamette Week reported in 2007, the other major benefactor of this law would be Ted Millar, owner of Southend Airpark and other property around the Aurora Airport.

The hearings over the ODA application were contentious, with Clackamas County and City of Wilsonville arguing against such funding until all the impacted parties were involved in the process and making the case for a complete and transparent process, while the proponents argues that acting now was critically important to create high-paying jobs. The solution to the impasse? Sen. Betsy Johnson puts forward the proposal that both sides engage in a mediation approach moderated by Oregon Solutions under the leadership of Karmen Fore, the former Sustainable Communities and Transportation Policy Advisor to the Governor—and now Director of Oregon Solutions.

The irony (or is duplicity) of this proposal, to which the majority of the Emergency Board agreed, only comes to light when you read what Ted Millar said about this before the Oregon Aviation Board in July:

The only thing I’m asking the Board, especially when you’re setting policy, is that, well, Karmen Fore, you know, the lady that was at the Governor’s Office before, said here at the Tillamook ORAVI [Oregon Aviation Industries] meeting last year that the Department of Aviation needs to be more aggressive in promoting, protecting, and improving airports, and they need to be much more aggressive in going after funding and doing the support necessary to place aviation at a higher level in the transportation system.

Which, of course, begs the question of how objective and unbiased any mediation led by Karmen Fore would be.

And that of course, gets us back to the original question of requesting retroactive permission to submit the funding application to the FAA. Since it was submitted without Legislative permission, and since the Aurora Airport expansion is such a contentious issue impacting multiple counties and cities, to say nothing of the negative impact on quality of life and land use and property values in and around Aurora, our position is simple: ODA should be instructed to withdrawn their FAA application until the problems with the IGA and the broken planning process at Aurora Airport are fixed.

Prepared by Friends of French Prairie



The super siting bill to expand the Aurora Airport, sponsored by Reps. Rick Lewis and Rich Vial and Senator Fred Girod has been released and it is worse than previously indicated.

Language of the bill


  1. As used in this section:
    1. “Runway area” means a runway, taxiway, access road, safety area or runway protection zone.
    2. “State airport” means an airport or air navigation facility owned or controlled by the State of Oregon.
  2. If a state airport has at least 350 based aircraft, as reported to the Federal Aviation Administration, the Oregon Department of Aviation, as authorized by the State Aviation Board, may extend a state airport runway area on land zoned for exclusive farm use under ORS 215.283 (1)(z).
  3. A state airport runway area extension under this section may include new or expanded facilities for aviation-related equipment that support runway areas.


  1. A local government shall amend its comprehensive plan and land use regulations to conform to the provisions of section 1 of this 2018 Act.
  2. Notwithstanding ORS 197.251 and 836.610, a local government amending its land use regulations under this section or approving a state airport runway area extension is not:
    1. Subject to the post-acknowledgement procedures under ORS 197.610 to 197.651;
    2. Required to demonstrate compliance with any statewide planning goal; or
    3. Required to obtain an exception to any statewide planning goal.


There are some signal elements. First, even though in all the advance work the proponents of this bill talked exclusively of the need to expand the taxiway by taking EFU ag land, the bill centers on the definition of “runway area” which includes runway, taxiway, access road, safety area or runway protection zone. That is to say all of these become an outright use for the Aurora Airport on EFU land—so the taxiway expands, Keil Road closes, and ag land south of the airport may be used for the safety zone and runway protection zone.  Note: land acquired for the safety zone does not have to remain as EFU ag land!  Further, paragraph (3) also includes “new or expanded facilities for aviation-related equipment that support runway areas.”  What does that mean – most likely instrument navigation equipment—facilities set off from both ends of the runway, which they would want to be on land controlled by the airport, not on leased land open to access. 

Further, if this bill passes, the “local government” portion means that Marion County shall proceed to amend its comprehensive plan to implement these changes, and no State land use Goal exception or Conditional Use Permits need to be received.


All the land south of the current airport taxiway and runway down to Ehlen Road are positioned to be converted from EFU ag land to land (probably owed) for these various aviation uses.  Then, what happens to the remaining ag land east of the airport to the Aurora City limit? The current Master Plan calls for Kiel Road to be stubbed south to Ehlen Road somewhere near the location of Vans Aircraft, so the remaining ag land gets cut in half.  It is then “subdivided” by a highly trafficked road serving the airport, and the ag land is isolated from other ag land surrounding the airport.  It is now perfectly positioned to be re-zoned as aviation-related commercial or light industrial. 


Another Legislative session is upon us, so there has to be a new effort to change land use laws in Salem for the benefit of developers at the Aurora Airport, right? Sure enough there is! This time, though, instead of enlisting the old diehards Senator Fred Girod, the developers have enlisted freshman Representative Rick Lewis of Silverton (who was appointed to replace Vic Gilliam).

Situation Analysis: even after attending a Constituents Meeting at the Butteville Store to meet and learn his constituent concerns, where he received unanimous concern about the Aurora Airport and opposition to Airport expansion, Rep. Lewis (the next day!) made public his decision to introduce a bill in the upcoming Legislative Session (one of his two) to enable expansion of the Aurora Airport. He is strongly in league with Sens. Betsy Johnson and Fred Girod, the Legislators responsible for the so-called “pottys for pilots” bill in the last Legislative session that exempted Aurora and Madras State Airports from annexation in order to expand urban services of water and sewer.

What’s in the Bill? This bill proposes changing Oregon Land Use Law to make runway expansions at State Airports at which 300 or more planes are based to be an outright allowable use on Exclusive Farm Use (EFU) lands. In other words, the proponents would not have to go through the required process of obtaining a Goal 14 exception. That makes it very similar to the bill from the last legislative session (see below) which changed State land use laws to allow cities to provide sewer and water services to two airports (Aurora and Madras) without annexation. Only one State airport qualifies under Rep. Lewis’ proposed bill: the Aurora State Airport. Of the 432 aircraft based at Aurora only 21 jets would benefit from a longer runway. Most of Aurora fleet of 312 Single Engine, 59 Multi-engine, 35 Helicopter, 1 glider and 4 unknown aircraft do not require and would not benefit from this runway extension.

What’s driving this bill? Ted Millar, owner of Southend Corporate Jet Park along with other aviation interests and Kevin O’Malley from the Wilsonville Chamber of Commerce have organized the Aurora Airport Economic Development Council have assembled a professional lobbying team including J.L. Wilson, a professional lobbyist and Wendy Kellington, a major land use attorney. They are actively out to “sell” the benefits of the bill. The public can be assured that incurring the costs of professional lobbyists and attorneys would only happen if the financial return to the investors is significant. This is the next example in a series of Federal and State tax dollars being spent to benefit a very few (the 21 jet owners) and the business owners at Aurora Airport who sell jet fuel and build/lease hangars.

Who supports this Bill? Aurora Airport Economic Development District, along with Senators Fred Girod and Betsy Johnson support the bill. The City of Aurora’s position is not clear at this time but Mayor Graupp voiced support at a meeting of local government officials mid-November. The Wilsonville Chamber of Commerce will certainly support the bill, as they have been a 100% airport development booster for some years now.

What’s the pitch? Wendy Kellington’s first public pitch of the bill was at a meeting of local government officials in November, where she positioned it as a win/win in as much as she said that the current runway length is inadequate and unsafe which is totally false—if it were unsafe the FAA would have shut the Airport down. 2) She said the runway is too short for modern day aircraft which is also totally false—lots of jets take off and land every day. 3) she went on to assert that all that is sought is a modest lengthening of the taxiway to accompany runway lengthening—yet the area 'required' is not specified in the bill. 4) the bill proposes allowing the taxiway extension/ expansion outright onto EFU land rather than requiring the legal effort to obtain a Goal 14 exemption. Getting an end run on a Goal 14 exemption means no public process, and likely no environmental impact process, and a precedent to just take EFU land when they next want to expand the Aurora Airport.

Aurora Airport Runway Extension with Aurora City Boundary

What’s the problem? As described so far there are no sidebars to restrict this as a onetime event specific to the described slice of land to lengthen the taxiway…so it could be used later for other expansion purposes. Further if what is in view is such a modest and benign expansion why would a State-wide precedent be set for this one airport to bypass and end run State land use law?

Related problems are those that were brought up and minimized during the recent Master Planning process: inadequate road, sewer and waste water infrastructure. Inadequate road infrastructure includes: I-5 and Boone Bridge, Arndt Road, Airport Road, Ehlen Road and the Aurora/Donald I-5 interchange. Additionally, the fact that the most impacted municipalities (Clackamas County and City of Wilsonville) were purposefully excluded from the process by virtue of an Impact Map that was part of the Inter-Governmental Agreement between Oregon Dept. of Aviation and Marion County to secure funding for air traffic control tower construction.

Besides the immediate problem of a State-wide super-siting precedent in this bill, it expands the footprint of the airport onto EFU land. This sets in motion lengthening the runway, and the high probability that all the EFU ag land south of the Aurora Airport to Ehlen Road, and from Hwy. 551 to the Aurora City boundary will come under significant aviation-related development pressure. Virtually all future “economic development” that would occur at the Aurora Airport in the form of “new jobs” would require the re-zoning of all the ag land south of the airport into commercial and/or light industrial to locate new aviation related businesses.

Sen. Fred Girod, SB 534 and Aurora Airport Expansion

At the beginning of the current 2015 legislative session, Sen. Fred Girod (R-Silverton) put forward Senate Bill 534, which will enable cities to provide water and sewer to airports without annexation into the city. This bill is not only unnecessary because provision of these services is possible under current land use laws (provided a need is shown), but it is a specific gift to the Aurora Airport and has state-wide implications.

FOFP met with Sen. Girod, and he made it quite clear that the Aurora Airport asked for the bill, and he made light of the probability of it passing. When asked about who would pay for the urban services to be provided, Senator Girod stated that the cities entering into the agreements would have to create a financing mechanism!

The bill subsequently went to the Senate Business & Transportation Committee, where it was treated as a “transportation bill” and promoted by Sen. Betsy Johnson. It passed the Senate almost unanimously (one opposing vote) and was moved to the House Committee on Rural Communities, Land Use and Water.

The implications are significant:

  1. The first issue is municipal governance. In the case of the Aurora Airport, it sits in Marion County, and with the provision of water & sewer is in position to develop without any municipal oversight!
  2. Most general aviation airports across the state that are outside city limits sit on farmland or forest lands. Development at these airports threatens both!
  3. Sewer and water are expensive urban services to provide, and the bill's proponents are relying on the cities to develop the means to finance providing these services via municipal bonds, etc. If something goes wrong, it is the local taxpayers who are on the hook!
  4. If provision of urban services drives significant commercial development at airports, that development could very well come at the expense of nearby cities!

On May 12 the Committee on Rural Communities held a hearing for the bill, which saw oral opposition testimony from City of Wilsonville, City of Aurora, Clackamas County Farm Bureau, Charbonneau Country Club, Friends of French Prairie and 1000 Friends of Oregon. Additionally, written opposition was submitted by City of Canby, Friends of Family Farmers,

The proponents of the bill tried to characterize it as a “jobs bill” and made light of the potential negative consequences, positioning it as a bill “to provide bathrooms for pilots!” However, none of them could discuss the bill without acknowledging that it had a significant potential to drive airport-related development, and Marion County Commissioner Kevin Cameron even positively described the “industrialization” it would bring about at the Aurora Airport.

Of note, there was some confusion during the proponent’s testimony about whether the bill as written would prevent cities from annexing in the future the airport to which services were being provided. Chair Clem sought a legal interpretation from legislative counsel and received it during the hearing: the bill does prevent any future annexation of the airport to the City providing the services after an agreement has been reached and services provided.

FOFP's position on this bill was:

  1. It is unnecessary, and sets a bad precedent by removing municipal governance from the provision of urban services necessary for development.
  2. Provision of these services should not be allowed if the development that follows requires the rezoning of high value farm land or forest land.
  3. If these services are to be provided by cities, the entire cost of providing them (including capital and operating costs) should be paid for by the airports, not financed by the local taxpayers.
  4. Provision of these services should require the approval of all cities within three miles of the airport to prevent negative impact on the cities through development.

Given the near unanimous passage in the Senate, the Rural Communities committee was under significant pressure to move the bill forward, and to their credit, considered amendments proposed by City of Wilsonville and Friends of French Prairie. These amendments would have required airports to pay for all water and sewer costs, would have prevented loss of farmland due to airport development, and required municipalities within three miles to agree. At a work session on May 25, again under a lot of pressure from proponents, the Rural Communities committee again discussed the bill. Chair Clem announced that he had sought legal interpretation from DLCD regarding whether the bill would have any impact on the “exception process” requirements in current land use law. He reported that DLCD’s opinion was that it did not change the exception process. Download the DLCD letter here

The Rural Communities Committee passed the bill, having determined that it was better to pass the bill as is, given that the exception process still applies, rather than fight for the proposed amendments and risk having another amendment put forward that would change the applicability of the exception process. The bill went to the House Rules committee, where there was also no traction to add amendments. The bill went to the full House on July 3 and passed with 50 Ayes and only 9 Nays (Reps. Barnhart, Barton, Buckley, Holvey, Lininger, Nosse, Smith Warner, Taylor, Williamson). Of note, Rep. Clem requested that the DLCD letter be read on the House floor so all understood that the bill addressed annexation specifically and did not impact state land use law. Thus it became part of the Legislative record. Download the legislative chronology on this bill here

We asked Mary Kyle McCurdy of 1000 Friends to explain the importance of this re: land use law.

SB 534, in its entirely, reads:

Be It Enacted by the People of the State of Oregon:
A city and an airport may enter into an agreement pursuant to which the city provides sewer and water services to the airport without requiring the annexation, or consent to eventual annexation, to the city of the territory on which the airport is situated.
This 2015 Act being necessary for the immediate preservation of the public peace, health and safety, an emergency is declared to exist, and this 2015 Act takes effect on its passage.

This bill is about annexation to a city; it is not about land use. Annexation laws have been around much longer than Oregon's land use program, and deal with the municipal governance boundaries of a city. The land use laws and annexation laws are awkward together because they grew up over different time periods and for different reasons. City boundaries were initially drawn over a hundred years ago. City boundaries are not co-terminus with the UGB. Usually, the UGB is larger than the city boundary because the UGB contains a 20-year land supply. Cities normally annex land within the UGB over time, as they provide municipal services to those lands. So normally (but not always), a city would not extend urban services to lands without first annexing them into the city boundaries.

Land use law (in particular, Goal 11 and its administrative rule) prohibits cities from extending urban services (water, sewer, storm water) outside a UGB unless (1) DEQ declares a health hazard and makes the city come in and solve the problem (failing septic systems, for example, but this is not frequent), or (2) the city & airport justify an "exception" to the land use goals that would otherwise apply - which in this kind of case would be Goals 3 and 11. To get an exception, the entity applying for it (the county must grant the exception and it is subject to appeal to LUBA) must demonstrate that there is a really good "reason" for the exception, and that there are no good alternatives to the extension of the urban services across EFU land. If the applicant can demonstrate this, the service extension would be limited to the use and reason that was the basis of the justification, and there could be requirements to take the route that is least damaging to farmland.

Here, as I understand, the Aurora Airport is outside both the city limits and the UGB, and it would require running pipes through EFU land to serve the airport or the area around it with water and/or sewer service. The bill says nothing about the exceptions process; it is just about annexation. So the requirement for an exception is still the law.


The Oregon Dept. of Aviation, under the oversight of the Oregon Board of Aviation, have been overseeing an update to the Master Plan for the Aurora State Airport. This multi-year process is separate from the Federal Aviation Administration decision to place an air traffic control tower at the Aurora Airport for safety reasons. The process has been fraught with politics and special interest pressures, and significant changes of direction as can be seen in the Plan Chronology and in the Master Plan Process Summary prepared by Tony Holt (Civic Affairs at Charbonneau).

Aurora Airport Master Plan Chronology – November 2009 to present

Nov. 3, 2009 Oregon Department of Aviation (ODA) initiates Master Plan update for Aurora Airport with selection of WH Pacific as consultant. Public Kick-Off Meeting defines Master Plan outcome to include:

Chapter 1 - Introduction
Chapter 2 - Airport inventory
Chapter 3 - Aeronautical Activity Forecast
Chapter 4 - Facilities Requirements
Chapter 5 - Airport Alternatives
Chapter 6 - Airport Layout Plan
Chapter 7 - Capital Improvement Plan
December 2009 ODA appoints Public Advisory Committee (PAC) comprised of airport users, representative of local municipalities and concerned citizens
July 22, 2010 PAC Meeting #1
Sept. 14, 2010 Letter from Clackamas Co., City of Wilsonville, neighboring communities & Friends of Marion Co. to Chair, Aviation Board saying Planning Advisory Committee (PAC) marginalized; process being rushed; discussion time severely limited; no discussion of study goals or vision; activity forecast sent to FAA for approval prior to PAC review; no impact analyses of noise, pollution, traffic; requests meeting with Chair of Aviation Board, FAA, Director ODA and Consultant.
Sept. 30, 2010 PAC Meeting #2
Dec. 9, 2010 PAC Meeting #3
Feb. 17, 2011 PAC Meeting #4
March 31, 2011 Preferred Alternative presented to Oregon Aviation Board in Salem by Department of Aviation staff (Chris Cummings) and its Master Plan consultant (Rainse Anderson, WH Pacific).  Master Plan recommendations include: change of ARC status from B-II to C-II, no expansion of physical size of airport, and no lengthening of runway. "ODA has decided that any extension would prove infeasible at this time…An extension to the south might have a negative impact on farmland—a potentially environmentally infeasible situation."
April 2011 Aviation Board directs ODA staff to change Preferred Alternative from “no extension” to “an extension is necessary.”
April 28, 2011 "New" Preferred Alternative with two scenarios to lengthen the runway via displaced threshold: one of 600 feet to north, the other 800 feet to south) are presented to Oregon Aviation Board. ODA staff is instructed to present the Preferred Alternative to the PAC
June 7, 2011 ODA receives letter from FAA Seattle Regional Office that is will not support nor fund displaced threshold approaches to runway lengthening being considered and will only support a 1,000 foot runway extension
June 7, 2011 Preferred Alternative with two lengthening scenarios (displaced threshold and 1,000 foot to south) is presented to PAC at public meeting. 
June 24, 2011 Aviation board votes unanimously in support of an 800 foot displaced threshold runway "extension" to the north.
Feb. 22, 2012 Letter from Oregon Dept. of Aviation to ADA District Office acknowledges the FAA rejection of both displaced threshold approached to runway lengthening, and confirms that the Oregon Aviation Board had unanimously voted in favor of a 1,000 foot runway lengthening to the south which “would require the relocation of Keil Road…and purchase or obtain an easement for land to protect the off-airport Runway Protection Zone (RPZ) to the south.”
May 22, 2012 Letter from Charbonneau Country Club to FAA reviews many concerns about the Master Plan process including the fact the minutes of the Oregon State Aviation Board meeting on March 31, 2011 omit any reference to the actual Dept. of Aviation presentation to the Board at the meeting stating that the Preferred Alternative was 'No Extension'. This is confirmed by The Oregonian report of April 8, 2011 which states in part "The Aurora State Airport runway will remain 5,000 feet long for two more decades under a detailed proposal released today—" And similar coverage in the Woodburn Independent on April 6, 2011.
July 20, 2012 Response letter from FAA District Office to Charbonneau Country Club confirms that runway extension has to be justified based on FAA criterion, and that the Sponsor (Oregon Dept. of Aviation) has chosen to pursue the 1,000 foot runway extension to the south.
Oct. 17-18, 2012 Airport Layout Plan signed by FAA and ODA after over a year of bickering and negotiating about tower siting, length of runway extension and location of runway extension.
Nov. 18, 2011 ODA receives letter from FAA confirming support for 1,000 foot extension to the south and disapproving 800 foot displaced threshold to the north.
UNKNOWN Revised Chapter 5 of the Aurora Airport Master Plan is published that includes a NEW Supplemental Data section detailing the 1,000 foot runway extension to the south. No public notice given, the Master Plan PCA is not informed.
UNKNOWN The ODA web page for the Aurora Airport Master Plan is updated with the revised Chapter 5 including Supplemental Data (but includes no date of page revision)
Feb. 16 2014 Public Hearing: Sens. Betsy Johnson and Fred Girod cosponsor SB 534 (so-called “Pottys for Pilots” bill) allowing cities to provide urban services (water & sewer) to airports without annexation – directly circumventing existing land use laws.
Jan. 8, 2015 Following frequent requests regarding release of the “final version” of the Aurora Airport Master Plan, Jeff Caines, Aviation Planner at Dept. of Aviation, confirms to FOFP that ODA has discovered that they do not have the required State Agency Coordinating (SAC) agreements or the corresponding Oregon Administrative Rules (OARs) in place to approve the Master Plan in compliance with State land use laws. He states that once complete “the agency will be able to address the formal adoption of airport Master Plans.”
July 27, 2015 SB 534 becomes law, allowing provision of some urban services to airports without annexation.
March 7, 2017 Aviation Board hears and approves proposed ODA State Agency Coordinating agreement and Administrative Rules.
Nov. 9, 2017 Rep. Rick Lewis meets with local constituents in French Prairie and received resounding opposition to Aurora Airport expansion. The next day he communicates that he is sponsoring a bill (HB 4092) to expand the airport by circumventing State and County land use laws by making Aurora Airport expansion onto EFU land an approved outright use.
Feb. 9 2018 House Transportation Committee holds a hearing on HB 4092 with significant opposition testimony that the bill would violate Goal 1 and circumvent the state land use laws. Rep. Lewis subsequently submits an amendment supporting the bill on the premise of emergency preparedness, but failed to coordinate with Dept. of Geology & Minerals who’s own earthquake maps show the southern half of the runway subject to liquefaction.
Feb. 9, 2017 Rep. Lewis’ HB 4092 sent to Rules Committee and is tabled for the remainder of the Legislative session following an animated Transportation Committee hearing with significant opposition.
July 27, 2018 Brian DeForest, Interim Director of ODA, sends letter to Senate President Peter Courtney and Speaker Tina Kotek informing them that ODA has submitted a Letter of Intent to apply for $37.7 Million in FAA funds to expand the Aurora Airport, and will shortly be submitting the full application, and will then be coming to the Legislature in September, 2018 to receive Retroactive Permission to do so.
Sept. 23, 2018 Emergency Board Sub-Committee on Government hearing on ODA seeking retroactive permission to apply to FAA for $37 million in funding to expand Aurora Airport.  Moved to Emergency Board on Sept. 24 with recommendation to pass.
Sept. 24, 2018 Emergency Board agenda item re: ODA request for retroactive permission to apply for $37 million in FAA funding for Aurora Airport. Per Sen. Betsy Johnson motion, item is tabled and Oregon Solutions retained to conduct intervention and mediation between opposing parties.
Oct. to Dec., 2018 Oregon Solutions conducts “assessment of Aurora Airport situation, including interviews with parties on both sides.
Nov. 29, 2018 City of Wilsonville holds the first and only public hearing on the question of expanding the Aurora Airport to be held since the end of the master plan process in 2012.  Over 200 people attend, and significant new opposition testimony is given, especially regarding: 1) probably Goal 1 violations that could result in legal action, and 2) likelihood that the 2012 Aurora Airport Master Plan is not a “legally adopted” plan.
Dec. 12, 2018 Oregon Solutions delivers final “Assessment Report” on Aurora Airport to Legislative leadership. The “Findings” section includes 13 major problem areas including: escalation of costs, safety, motor vehicle traffic, land use, public process, interagency coordination and Dept. of Aviation capability and capacity.
Dec. 13, 2018 Emergency Board Sub-committee on Government hearing on ODA request for retroactive permission to apply for $37 million in FAA funds to expand the Aurora Airport. No testimony is requested of Karmen Fore, Director of Oregon Solutions (though present at hearing). Rather testimony requested from Martha Meeker, Chair of State Aviation Board, who restates the request and fails to explain how a $7 million estimate in the 2012 Master Plan had grown to a $37 million request. No discussion of the Oregon Solutions report or any of its findings re: Aurora Airport. Request forward to Emergency Board with recommendation to pass.
Dec. 14, 2018 Emergency Board considers agenda item to grant retroactive permission to ODA for application to FAA for $37 million in funding. Motion passes unanimously with no discussion.
April 24, 2019 Betty Stansbury, new Director of Oregon Dept. of Aviation acknowledges in a letter to Friends of French Prairie the following:
  • The so-called Aurora Airport Master Plan was never “approved” by the Dept. of Aviation
  • The so-called Aurora Airport Master Plan was never “legally adopted” by the State Aviation Board
Though not complied with, Dept. of Aviation was subject to Dept. of Transportation State Agency Coordinating Agreement rules during the 2010 master plan process, which required the inclusion of all effected jurisdictions (such as City of Wilsonville and Clackamas County).
June 14, 2019 City of Wilsonville sends letter to Dept. of Aviation stating, that the “City of Wilsonville has had serious concerns about the lack of a meaningful public process in past Aurora State Airport Master Planning processes… Under both the previously binding ODOT State Agency Coordination Program and the more recently adopted program, Wilsonville is both an impacted and interested party with respect to future Aurora State Airport Master Planning and the potential expansion of a runway… Substantial changes have been made to the draft Aurora State Airport Master Plan since the public process closed in 2012. For whatever reason, however, Wilsonville and Clackamas County were effectively excluded from that process in the past… [W]hen the Master Plan process is reopened we are confident that…the ODA will seek participation and input from Wilsonville and Clackamas County.”
July 18, 2019 Posted agenda for August 1, 2019, Aviation Board meeting, Lebanon State Airport master plan approval agenda item, includes a new (undated) flowchart titled “State Agency Coordination Program: Adoption of Final Master Plans, Oregon Department of Aviation.” The 2010-2012 Aurora Airport Master Plan process demonstrates significant divergences from this defined process to comply with state rules on inter-agency coordination.
Aug. 19, 2019 Oregon Dept. of Aviation announced they are holding a meeting on Sept. 24 in Salem, from 3:00 to 5:00 PM to gather "information on the compatibility of the Master Plan with applicable land use plans and statewide planning goals." Written testimony will be accepted, but verbal testimony is limited to two minutes. ODA will then "present findings of compatibility" to the Aviation Board at its October 31 meeting in Sunriver.
Aug. 21, 2019 Betty Stansbury, Director of the Dept of Aviation sent a letter to FOFP’s land use attorney in which she "clarified and corrected" all her previous statements about the Aurora Airport Master Plan, now claiming that it had, in fact, been approved and adopted by the Aviation Board in 2012.
Sept. 10, 2019 Based on the legal opinion that the recant letter sent by Director Betty Stansbury on August 21, 2019 constituted the “land use decision” on the 2012 Aurora Airport Master Plan, FOFP has filed a LUBA appeal. The letter ostensibly sought to clarify and correct Director Stansbury’s previous statements about the status of the 2012 Aurora Airport Master Plan by denying them and claiming the Master Plan had been adopted.
Sept. 15, 2019 Using recently available ACTUAL objective data from the FAA Air Traffic Activity Data System (ATADS) FOFP is now able to compare projected growth in Total Operations and Based Aircraft found in the 2012 Aurora Airport Master Plan with what has actually occurred. These forecasts, along with Constrained Operations data, constitute the justification for lengthening the runway and expanding the airport at Aurora, and can now be seen as not just willful misrepresentations but falling as much as 40% short of forecast.

Aurora Airport Master Plan Summary

The Aurora Airport Master Plan current revision has been a flawed process from the beginning, largely due to the fact that there is no independent party involved having decision making powers. All the decision makers, ODA, the Aviation Board and the FAA, have a vested aviation interest and some of the members of those groups even have an aviation business interest. In addition, there has been a complete lack of reliable documentation. There are no records of take-offs and landings at the Airport, and so any forecast of activity is suspect. There is no proper documentation of the claims by 11 operators at Aurora (out of about 350 based aircraft) that they have 'constrained operations' and need a longer runway. There is no documentation of ODA's conversations with the FAA whereby the FAA appears to overrule ODA's latest development proposals.

Then there is the actual sequence of events—the ever changing face of ODA's development 'Preferred Alternative" (PA). After much discussion among the Planning Advisory Committee (PAC) with no clear conclusion as to whether or not there should be a runway expansion, ODA decided their Preferred Alternative would be a strengthening of the runway but no extension. They said "ODA has decided that any extension would prove infeasible at this time." That seemed a reasonable compromise, given the differing views of the Policy Advisory Committee. But that did not satisfy the Airport developers and a few Airport businesses. They lobbied ODA and the Aviation Board hard. So ODA cherry-picked its comment responses and said that (within an arbitrary time period) there was a majority in favor of runway extension. They ignored all the petitions and testimony opposing an extension that had gone before. Suddenly runway expansion was no longer 'infeasible'. Two hybrid extension cases were produced which would lengthen the runway for take-offs but not for landings. At this point the FAA got in the act. Or were they in all along? They said they would not fund any hybrid expansion as proposed. So, out of the blue came the latest ODA PA, a 1000 foot expansion to the south which extends the airport outside the current boundary onto prime farmland and closes a road which is considered key access for the Aurora Fire District and local farmers. ODA itself said earlier "Keil Road provides necessary access for farm equipment/machinery and emergency responders—" Where did the 1000 feet come from? Why not 600 feet or 400 feet? The saga of the process, with no checks and balances, continues.

The Master Planning process is supposed to be a collaborative one between airport users, neighboring communities and local government representatives. This one has become a one sided effort to grow the Aurora Airport with disregard by the Aviation Board and ODA for local input. That was followed by the FAA rejecting ODA’s first three recommendations. Where will it all end and who will be the independent arbiter of this process which is spending, and will in the future spend, lots of scarce taxpayer money to benefit a very few?

Tony Holt
Charbonneau Country Club Civic Affairs

Friends of French Prairie position on the Master Planning process.

Friends of French Prairie is on record as opposing lengthening of the runway and does not believe the data supports the need. We are strongly opposed to any expansion of the airport boundary that would close Kiel Road and take EFU farmland. We find it perplexing after a month's long process on the part of ODA, WH Pacific and the PAC, that prompting from the Oregon Aviation Board and the FAA have seemingly caused a reversal of the position stated in the Preferred Alternative of March 24, including the statement: "ODA has decided that any extension would prove infeasible at this time....An extension to the south might have a negative impact on farmland—a potentially environmentally infeasible situation."

The City of Salem has decided to extend the runway at the airport at the State capital. Why should the public, through FAA Federal money and State OTIA III state money pay for TWO airport runway expansions for competing airports which are only 26.3 miles from each other?

Aurora is 26.3 miles from Salem and 22.8 miles from downtown Portland, much farther than PDX. Salem can serve the needs of the South Metro/North Willamette Valley with only slightly longer driving distances on fully developed roads than Aurora, who’s local roads are rural and inadequate for increased airport traffic.

Given the choice, Salem should get the go ahead and Aurora should remain as it is today, because:

  • Salem has a tower and urban services – Aurora would need to build a tower and has NO urban services, is on limited well water and septic tanks.
  • Salem has municipal governance, Aurora is on EFU land, outside city limits, urban growth boundaries and has no immediate plans to become urbanized
  • Salem has commercial air service, Aurora has none;
  • Salem serves the Air National Guard and the State Capitol; Aurora serves flight schools and private pilots, it’s major economic focus is helicopters, which do not need new expensive runway expansions to provide jobs.
  • Salem’s runway, after extension would be shorter than Aurora’s – Why do we need to expand a constrained airport, when a non-constrained airport exists?
  • The Aurora expansion is supported by false airport use numbers, with little real demand other than the desire of airport users to fly bigger jets and developers to do real estate deals, Salem has real need, real economic growth potential and serves hundreds of acres of nearby zoned and served industrial land.

After a year and a half long process where are we? The Aviation Board has voted in support of a displaced threshold runway "extension" knowing full well that the FAA is almost certainly not going to approve and provide funds for it. This would enable the Aviation Board to accept the FAA's position of a 1,000 foot runway extension and be able to say: "we tried for less, but the FAA forced us to make a longer conventional extension." The problem is that position doesn't pass the smell test.

Of note, on March 10, 2011, when the Preferred Alternative was presented to the Aviation Board and proposed no runway extension, that recommendation was ostensibly based on a set of data (surveys, constrained operations numbers, etc.). That recommendation did not satisfy the Aviation Board nor airport users, and ODA and their consultant was directed to look at additional runway extension options. On what data is the 800 foot runway extension based? None! It is purely a function of the desire of airport users and the Aviation Board to enlarge the Aurora Airport and extend the runway, and now they have their straw man in the form of the FAA. This is an outrageous assault on local decision making and an terrible use of tax payer dollars!

Where are we now, early 2013?

The very public process by which the update to the Aurora Airport Master Plan ran for a year and a half, and engaged a great deal of public involvement—both pro and against expansion.  The result was delivery by ODA and their consultant, WH Pacific, a Preferred Alternative that recommended to runway extension and no expansion of the airport.  That wasn’t good enough for the Oregon Aviation Board who summarily instructed ODA to go find a way to extend the runway.  ODA did another survey of aviation users and excluded all other public comment, resulting in a new set of data that strongly supported runway extension. This lead to two new extension scenarios, and the Aviation Board then unanimously approved the one for an 800 foot extension to the north—knowing full well that the FAA was already on record opposing such an extension.  That was the end of the public process—though its worthy of note that Aviation Board meetings aren’t really part of the public process: they are not publicly noticed and there is no space on the agenda for public comment.

On October 12, 2012 FAA and ODA signed the Airport Layout Plan, finalizing the central element of the Master Plan. The sixteen months between the last vestige of public activity at the Aviation Board meeting and the agreement between ODA and FAA on the Airport Layout plan were completely shielded from public involvement.  And the result is a “delivered plan” that is about as far apart from the original “Preferred Alternative” as could be possible.

  • Instead of no runway extension we now have a 1,000 foot extension
  • Instead of no airport expansion we now have the proposal to acquire 55 acres of EFU land south of the airport to expand the runway protection zone
  • Instead of concern about a negative impact on farmland, all the farmland south of the airport id a direct fly over zone
  • Instead of no impact on Kiel Road, Kiel Road will be abandoned on its west end where it joins Hwy. 551 and rerouted to Ehlen road, dividing the remaining farmland south of the airport in half and marginalizing it.

FOFP said almost two years ago that what was going on at Aviation Board meetings was an outrageous assault on local decision making and use of tax dollars. What has ensued since is an egregious overturn of public process, where all public input ended up ignored and used as nothing more than window dressing so State and Federal aviation agencies could get what they wanted all along. And who benefits? A very small percentage, the less than 1% in the aviation sector, who now get to have their infrastructure paid for by regular tax payers.


On October 17 and 18, ODA and FAA signed the final Airport Layout Plan, finalizing the central elements of the Aurora Airport Master Plan process by finally agreeing on the location of the air traffic control tower, the strength and designation of the runway, the extension of the main runway, and the expansion of the airport to the south to extend the runway protection zone.

Preferred Alternative Map

Download the Airport Layout Plan in PDF here


On March 31, the Oregon Department of Aviation recommendation on updates to the Aurora Airport Master Plan was made to the Oregon Aviation Board by ODA staff and their consultant. Of note, the core of the presentation was the explanation of the "Preferred Alternative" which replaces the four alternative found in the draft of Chapter Five of the Master Plan. The "Preferred Alternative" document and its accompanying layout map recommend:

  1. Change in Classification from B-II to C-II (a classification to accommodate larger and heavier jets) with improved avionics.
  2. No lengthening of the runway, but a substantial extension of the Runway Protection Zone (RPZ) to the south, including:
  3. Acquisition of EFU farm land to accommodate the RPZ and run off areas.
  4. The change of classification to C-II means strengthening the runway to accommodate larger jets.

Preferred Alternative Map Overlay

The problem is that the oral testimony and discussion before the Aviation Board included a substantial discussion of another alternative: the future implementation of a "DIsplaced Threshold" which would result in a 1,000 foot runway extension at the south end of the runway for the purposes of allowing jets to take off to the north with a full load of passengers and fuel in the heat of the summer. If approved, this runway lengthening would bring the south end of the runway to the current south airport boundary. Implementing it would require:

  1. Further expansion south of the Runway Protection Zone
  2. Closure of Kiel Road
  3. The loss of additional EFU farm land, in as much as this would essentially condemn all property between the airport and Ehlen Road as suitable for airport-related development.

Friends of French Prairie opposes any runway lengthening. The Aurora Airport is constrained on three sides by major roads, and to the south by EFU farmland. Sacrificing foundation farmland for runway expansion to benefit less than 1% of the population, and paying for it with taxpayer's money is not acceptable.

Download the Master Plan Preferred Alternative in PDF here
Download the Preferred Alternative map in PDF here


Friends of French Prairie submitted a written letter in opposition to all three build alternatives, accompanied by a petition signed by many members, given that all expansion alternatives do so at the expense of farm land. In part the letter said:

"We are opposed to expansion of the Aurora Airport, because all such expansion occurs at the expense of farm land. The airport was expanded in the '90s (resulting in the reconfiguration of Kiel Road), which in turn allowed the airport to handle larger aircraft. This attracted not just aircraft owners with larger aircraft, but aviation industry, which in turn led to more traffic, etc. The result of which is the current "safety problem" that has to be resolved with an air traffic control tower. Marion County has abetted this process by approving zone changes that have increased aviation activity, in as much as they see the airport as a tax revenue source and appear not to be concerned that the consequence is loss of farm land. The most recent and egregious example is the rezoning of EFU land allowing Helicopter Transport Corp. to relocate to the southwest corner of the airport will greatly increase helicopter traffic, and removes 30 acres of farm land. While we support improved air traffic safety, and thus the air traffic control tower, we support the No-Build Alternative found in Chapter 5 of the current Aurora Airport Master Plan document. The airport should continue as is, with necessary and required maintenance"

In addition, the Community of Charbonneau submitted a letter of opposition to all build alternatives accompanied by a petition with over 220 signatures.

Download the FOFP letter and petition in PDF


After a month long process to update the Aurora Airport Master Plan, that has included a Public Advisory Committee (PAC), ODA and its consultants finally released Draft of Chapter 5 "Airport Development Alternatives" for review and comment. The process has seemed backwards to many outside observers and some members of the PAC, given that defining airport expansion was among the goals, but nothing definitive was published until this draft document was released. It includes four alternatives for consideration, any one or a combination of which will be recommended by ODA staff to the State Aviation Board for approval.

  • No build alternative - no expansion of the current runway, only maintenance
  • Build Alternative 1 - expansion of the runway 600 feet to the north; all within current airport boundaries
  • Build Alternative 2 - expansion of the runway 1000 feet to the south, closure of Kiel Road and extension of the runway safety zone south of the current airport boundary
  • Build Alternative 3 - a "precision approach" alternative with no current runway lengthening, but expansion of runway safety zones in all directions beyond the current airport boundaries.

Download a copy of the Master Plan Chapter 5 in PDF

Public Comment will be accepted at the next PAC meeting, on March 10.


On September 14, a number of members of the Planning Advisory Committee (the planning committee appointed by Oregon Dept. of Transportation to provide planning input on the air traffic control tower) wrote a letter of protest to ODA documenting their concerns that the tower project was being rushed to a pre-determined conclusion by ODA and their consultant, WH Pacific. Among the cited concerns:

  • master planning process is being rushed on a condensed schedule
  • air traffic control tower is being actively pursued prior to development of the new master plan
  • the role of the PAC has been deliberately marginalized
  • the above is not the meaningful, due process input the FAA intends in their Master Plan process.

While the members of the PAC sending this letter represent the numerical minority of members, they represent the non-aviation members on the Committee and have been making the case for the need for master planning in advance of tower construction.

In late October ODA released the first three chapters of the Draft Aurora Airport Master Plan. This document, prepared by WH Pacific further confirmed concerns about the pre-determined goals and outcomes, because the Draft Master Plan document contained data laying the foundation to enable future lengthening and strengthening of the runway.

Specifically, runway lengthening is controlled by FAA policy:

E.1 Runway Length Requirements for Airport Design (AC 150/5325-4B)

In determining recommended runway lengths, the FAA uses a five step procedure based upon a selected list of critical aircraft. The five steps include:

  1. Identify the list of critical design airplanes that will make regular use of the proposed runway for an established period of at least five years.
  2. Identify airplanes or family of airplanes that will require the longest runway lengths at maximum certified takeoff weight (MTOW).
  3. Using Table 1-1 of AC 150/5325-4B and the airplanes identified in Step #2, determine the method that will be used for establishing the recommended runway length based upon useful load and service needs of critical design aircraft or family of aircraft.
  4. Select the recommended runway length from among the various runway lengths generated in Step 3 using the process identified in Chapter 2, 3 or 4 of AC 150/5325-4B, as applicable.
  5. Apply any necessary adjustment (i.e. pavement gradient, pavement condition (wet or dry), etc.)

In response to this document, Clackamas County legal staff prepared a letter requesting explanation and clarification from ODA regarding two important elements of future growth. The first was a projected increase in annual jet aircraft traffic, above and beyond the one time growth experienced by the South Park Jet Center. The second derives from the first, specifically the designation of the "critical aircraft" to be a Citation X. This is a much larger and heavier jet, capable of coast-to-coast non-stop flights, and presently none are based at the Aurora Airport.

It appears that these elements of the forecast in the Master Plan are purposefully included to justify continued airport expansion and lengthening of the runway—in spite of public declaration that airport expansion is not a goal of the tower project.

Of note, ODA's application for ConnectOregon III funding to construct the tower included letter from Xerox Corp. in November, 2009. It not only stated support for air traffic control tower, but went on to discuss runway lengthening.

General aviation and corporate traffic has steadily been on the rise in this prime location Having a control tower. adding an ILS and increasing the runway length by 500 to 1000 feet will not only increase safety. it will expedite traffic in and out of the area and attract even more business aircraft to KUAO that will have a positive impact on the economy

From the above it appears quite clear that the aviation interests pushing for the air traffic control tower have more than improved safety in view. They know full well that an air traffic control tower is a major infrastructure improvement to the airport and will drive aviation growth and airport expansion. They, along with ODA, and apparently aided and abetted by the FAA, are diligently working to avoid any of the master planning required by Oregon State land use laws.


The Aurora Airport Master Plan web page, providing an overview of the project and process, with documents and new updates can be found at:

Chapters of the current Master Plan are posted as released, and can be accessed, read and downloaded at:

The Chapters page also includes a link for citizens to make comments on the Master Planning process.


The testimony before the Oregon Transportation Commission given by the City of Wilsonville, Clackamas County and Friends of French Prairie was best summarized in the final testimony given by Mia Nelson of 1000 Friends of Oregon when she said that the fundamental problem was that "the funding cart is ahead of the planning horse," and went on to point out that comprehensive land use planning, as intended by Oregon Law, could very well demonstrate that the cost of infrastructure required to support the expansion sure to follow construction on an air traffic control tower at the Aurora Airport would be so great as to be financially impractical.

Clearly all of this testimony fell on deaf ears at the Oregon Department of Transportation (ODT), as evidenced by the Staff Report that was released on August 18, which dismissed public concern about land use considerations with the simple statement that "Construction of an ATCT at the Aurora State Airport will not change the existing land use." The blind eye in such a statement is staggering, given that the air traffic control tower itself will not change existing land use, but the projected airport expansion and related development will. The Oregon Department of Aviation funding application projects 300 new jobs at the Aurora Airport resulting from the air traffic control tower, in addition to the improved aviation safety delivered by a tower. The fundamental problem all along has been the dutiful avoidance of land use and traditional master planning in order to get FAA funding for the tower, and defer land use planning into the future....sometime! That approach is compounded by the conscious ignoring of the fact that the majority of the impact of airport expansion falls on Wilsonville and Clackamas County, who have been uniformly excluded from the process.

[Download the ODT 08/10 Staff Report/Agenda here]

This conscious ignoring of the pertinent issues presented in the testimony given at the July 21 OTC hearing (see below), has prompted the City of Wilsonville to write a letter to OTC expressing their disappointment and detailing the infrastructure, land use and planning issues the staff report ignores.

[Download the City of Wilsonville letter here]

To add insult to injury, on August 19, the Oregon Aviation Board held a monthly meeting via teleconference, at which Mark Ottenad, Public/Government Affairs Director reiterated the concerns of the City of Wilsonville, Clackamas County, 1000 Friends and Friends of French Prairie, which was essentially derided and dismissed, and "The Board then passed a motion to approve designing the tower to budget and to use future Aurora AIP entitlement funds as needed for tower construction."

[Download the summary of the OAB meeting here]

This entire process is not only the funding cart ahead of the planning horse, but is more and more looking like a conspiracy of State agencies with private aviation interests to build an air traffic control tower that will fuel expansion and development via a process that has been gerrymandered to get around all State and local land use planning requirements. And who benefits? The less than 1% of Oregonians who own aircraft, and the business interests at the Aurora Airport who stand to make big bucks on business and real estate development at the Aurora Airport.


On Wednesday, June 21, the Oregon Transportation Commission took public testimony in a hearing on the ConnectOregon III program, the funding source for master planning and siting an air traffic control tower at the Aurora Airport. This project has been ranked high on the funding list, but is fraught with problems, as detailed in the section below.

Public testimony was given by Friends of French Prairie, Clackamas County, the City of Wilsonville and 1000 Friends of Oregon, all centered on:

  • the need for completion of the master planning process before any release of funds for an air traffic control tower,
  • rectification of the current IGA that excludes Clackamas County and City of Wilsonville
  • the need for an open process that includes all impacted municipalities and citizens,
  • complete and thorough assessment of all the infrastructure mitigation that would be required.

You can download testimony below:


To download the entire Oregon Department of Transportation document package, with ODA's  application for ConnectOregon III funding, letters of concern/support and the 2000 Aurora Airport Master Plan [click here to download PDF]


Over the course of the past two years, a great deal of activity has been afoot behind the scenes concerning the Aurora Airport. Most focused on the prospect of a getting funding and approval for an air traffic control tower at the airport. On June 7, Commissioner Milne presented a proposed Intergovernmental Agreement (IGA) to the County Board of Commissioners for approval. This IGA was approved and fast-tracked so that it could be signed and delivered to the Oregon Dept. of Aviation (ODA) the next day. The tower project has been approved by the Federal Aviation Administration (FAA) and funding for it is pending the final decision of funds allocation from the ConnectOregon III program. The tower was reported by the Woodburn Independent to be number four on the project list (see article below) on June 17. These facts confirm that the application for funding the tower was submitted far in advance of updating the airport master plan.

The Costs and the Benefits

The obvious benefit of an air traffic control tower at the Aurora Airport is greatly improved safety for all aircraft operators. The airport is the second busiest in the state (after PDX) and has a mix of propeller and jet aircraft as well as helicopters. With its north-south runway axis a large percentage of flights approach or take off over Charbonneau and Wilsonville. An air traffic control tower would benefit aviation and improve safety by sequencing flights, and could mitigate noise impact by moving from visual approaches to more optimal flight paths. Cleary this is in the public interest.

The problem is that while improved safety is being touted as the reason for pursuing the tower, there are many other motivations—many very problematic—that have made the process conflicted and questionable. Citizens and communities have been excluded to the benefit of aviation interests. Land use planning laws have been ignored in favor of fast tracking the project. Funding applications are full of misrepresentation in order to put forward the appearance of unanimity. Important impacts like traffic mitigation have been deferred into the future in order to line up the approvals now. And at the end of it all, the outcome beyond safety is the potential for rampant development at the Aurora Airport.

Impacted Communities and Citizens

Wilsonville and Clackamas County have been trying to become a part of the airport master planning process for two years, as has Friends of French Prairie. The fact that the north end of the airport sits on the Marion-Clackamas County line, and that the north end of the runway is just south of the county line makes an indisputable case that much of the flight impact (noise, pollution, etc) will occur in Clackamas County, specifically in Charbonneau and Wilsonville. In the ten mile radius around the airport, the population concentration is in Wilsonville and Charbonneau, resulting in the following impact zone map prepared by the City of Wilsonville.

Click image for enlarged view

The process to approve and fund the air traffic control tower has essentially been reduced to a negotiation between Commissioner Milne representing Marion County, the ODA, the FAA and aviation interests at the airport—who stand to financially gain from a tower. Excluded have been public hearings to solicit citizen input, as well as the Cities of Wilsonville & Canby and Clackamas County. Also ignored have been completion of the master planning process, assessment of long term impact on surrounding EFU farm land, assessment and mitigation of infrastructure requirements (such as surface roads, impact on the Boone Bridge, change in I-5 traffic levels, etc.), all for the purpose of getting FAA approval and funding in place now. Representatives of Wilsonville were specifically "uninvited" from one meeting with personnel from the FAA, so that their concerns would not be heard.

The application of ConnectOregon III funding is replete with misrepresentation, perhaps the most egregious being the answer given to the question: Can the project demonstrate support from public agencies that must approve the project? The answer provided: "Coordination required per IGA with Marion county and Aurora. Tower Master Plan study in progress and will be completed in 2010 with concurrence of counties of Clackamas, Marion and cities of Wilsonville, Canby and Aurora." This is patently false or at best, a gross overstatement, given the final form of the IGA that excluded Clackamas Co. and Wilsonville from any meaningful role in the master plan process, re-drew the impact zone map to exclude all parts of Clackamas Co., and did not include Canby at all.

The Marion County bias

The IGA approved by the Marion County Commissioners is between the County, ODA and the City of Aurora, and purposefully excluded Wilsonville and Clackamas County according to Commissioner Milne because "there is not a way Marion County can protect its own interests and follow land use planning guidelines and at the same time make Wilsonville and Clackamas County signing partners with equal standing to the IGA." Which is the politically correct way to say "we don't want to cede any power and control to the impacted parties because they may not want to do what we want to do."

[Download a copy of the Management Meeting minutes here]

Commissioner Milne is on record as referring to the Aurora Airport as "that little economic development engine in the north part of the County," and has fully supported all development proposals at the airport. Including the recent conditional use permit approval to allow Helicopter Transport Corp. to build a helicopter facility on the Netter-Collett property adjoining the airport—essentially allowing a "thru the fence" aviation use to occur on non-airport property.....and thereby threatening all the EFU land south of the airport.

It is hard to understand the motivation on the part of the Board of Commissioners to promote development at the Aurora Airport, where over 85% of registered aircraft owners and over 90% of business owners are not Marion County residents, instead of focusing on the Salem Airport—at the state capitol, the County seat and where there used to be commercial flights. And, where there already is an air traffic control tower! Why all this effort to improve and enhance an airport that caters to non-county residents, when Salem has an airport that needs development work?

The IGA is perfectly engineered to achieve local development goals and exclude anyone who might take exception. Consider the impact zone map incorporated into the IGA: it completely excludes all of Clackamas County, even though the north end of the runway almost sits on the County line and most flights must fly over (i.e. impact) Clackamas County and Wilsonville.

Click image for enlarged view

FOFP Position on the Aurora Airport IGA

FOFP is fully supportive of the need for enhanced aviation safety at the Aurora Airport, the kind that an air traffic control tower could provide. However, it should be "tower and process" not "tower trumps process." The exclusion of Wilsonville and Clackamas County in the current IGA is incorrigible and is among the worst current examples of inter-governmental relations in the State. The position is indefensible on the face of it and requires the denial of geographic reality to support it. The way the IGA, the application Oregon has land use laws for a reason. The long term consequence of the tower approval without due process and the input of all parties will be rampant growth at the Aurora Airport. Consider this statement from the letter of support in the ConnectOregon III application from Xerox Corp: "Having a control tower, adding an ILS and increasing the runway length by 500 to 1000 feet will not only increase safety, it will expedite traffic in and out of the area and attrct even more business aircraft." It is unlikely that this is idle speculation. The forces behind the tower at the Aurora Airport envision massive development, and that comes at the expense of ag land south of the airport, plus all the other negative complications.

In February of this year, over protests by the City of Aurora and FOFP, the Marion Co. Board of Commissioners unanimously approved the requested designation submitted by US Leaseco (Helicopter Transport Corp). This approval converted EFU land to aviation usage. To the City of Aurora's point, doing so creates a precedent, essentially approving this property (which is not part of the Aurora Airport) for thru-the-fence aviation use. FOFP's opposition was based on the use of ag land for aviation purposes, and the implication for the other EFU land between the airport and the City boundary.


On March 31, 2009, U S Leaseco, Inc, a Delaware corporation with a local address in Corvallis filed an application to change the Comprehensive Plan designation from Primary Agriculture to Public, seeking an exception to Statewide Planning Goals 3 (Agricultural Lands) and 14 (Urbanization) and for a conditional use for airport related uses on a 27.48 acre parcel located at 14497 Keil Rd and 22265 Airport Rd NE, Aurora, OR.

This is the same property for which the previous owners (Netter & Collett) submitted a zone change application in 2007 and withdrew it in July, 2008. In the past nine months U S Leaseco has acquired the Netter/Collett property and is seeking a zone change to construct a helicopter landing zone, 5 helicopter pads and a helicopter hangar on the property, allowing 'through the fence' access to the airport to enable a giant commercial helicopter operation and a massive increase in aviation traffic at Aurora Airport.

[Download a copy of the Land Use Request/Request For Comments (3/31/09)]

US Leaseco is a large helicopter charter service, operating 80 helicopters in the United States, Canada, and overseas. Their intent is to relocate their western US operations from Corvallis and consolidate them on this property adjacent to the Aurora Airport. This is made possible by “through the fence” airport access at the Aurora Airport (one of three Oregon airports eligible to participate).

The applicant intends to construct a 126,000 square foot hangar facility, including component and engine overhaul shop, inventory facility and management office space. The application requests a “reasons” exception” to Statewide Planning Goals 3 and 14, requesting an urban use on rural land, and from Primary Agriculture to Public, as well as the zoning from Exclusive Farm Use (EFU) to Public (P).

Click image for enlarged view

[Download engineering drawing of US Leaseco Hangar & Helipad drawing in PDF]

The application for the requested changes attempts to make the case that:

  • There is a need for property to expand airport operations and the subject property is the most appropriate location for expansion.
  • The economic benefits to be accrued to the immediate area by this facility with its projected 160 full time jobs (by the end of the 5th year of operation).
  • An onsite well and septic system will be feasible to handle the required demands of the proposed use.
  • No anticipated limitations exist to the air, water, energy and land resources.

[Download the entire US Leaseco Application for zoning change in PDF]

Preserving Agricultural Lands First

Subject property does abut the Aurora Airport at its southeast corner. It and the property directly north, as well as the property east of Airport Road and south of Keil Road are all zoned EFU. The property is adjacent to the airport and has an access road (Yellow Gate Lane) to the Airport, but none of that changes the fact that this is agricultural land, zoned EFU with Class 1 soils. The previous owners made the assertion in an earlier zoning attempt (which they withdrew in the face of opposition) that all of this property is comprised of low quality soils.

A look at the aerial map below quickly shows how misleading this assertion about poor quality land was. The airport is essentially surrounded by EFU agricultural land, with a few exceptions. Most of the land to the west across Highway 51 and all the land to the east across Airport Road is intensively farmed. The majority of the land to the south and southeast is zoned EFU and is being farmed.

Click image for enlarged view

What is wrong with this application?

There are two principal problems.

  1. The subject property is one of 17 pieces of property to the south and southeast of the airport. As pointed out, this is the only expansion direction available to the airport. The last piece of land to be integrated into the airport was not in agricultural usage and became the airport water and septic facility. This property, and the adjoining 16 pieces of property are all agricultural farm land with high quality soil. If one goes, the odds are very high on all the rest being "integrated" into the airport sooner or later. If the property owners want to sell their land, they should do so within the zoning and to people who plan on farming.
  2. The fact that the Aurora Airport sits in the middle of high quality farm land through a quirk of fate (the need for a second airport during World War II) does not minimize the value of the farm land. The economic interests and desires of the airport and the private commercial interest therein do not de-value the surrounding farm land. The purpose of Statewide Planning Goal 3 is to protect agricultural land.

Expansion pressures from Metro Portland in the past two decades have made the I-5 corridor south of the Willamette River among the most pressured to convert agricultural land for development. This area is the Gateway to the Willamette Valley-that is to say, the gateway from Metro Portland to the most fertile and productive lands in the state and the world. It has to be treated as such. All development in this area has to be considered with great care, and the value of the farm land has to be a major element in the assessment.

The starting point has to be that farmland should be preserved not developed. Climate change, rising fuel costs, contamination of imported commodities and other factors have all contributed to the understanding that we must "think global but buy local." The fact is we may desperately need our farm land in a few years, and one certainty will always prevail: when farm land is taken out of agricultural usage and paved over, it never goes back.

FOFP's Position on this application

FOFP is strongly opposed to this application and the conversion of any farmland for non-agricultural purpose where the change serves only a very small minority interest (those in the aviation industry) and does so at the long term expense of farming, farmers and our land.

Beyond the principle of converting Agricultural Land with Class 1 soils into urban uses, the other problems with the application include:

  • The so-called “need” presented in the application for an expansion of airport related business is an expression of the Applicants business desires. No such “need” is defined in the 1976 Aurora Airport Master Plan or it’s October, 2000 update. Rather, this property is described therein only as “acceptable for airport-related development.”
  • The economic benefit to be locally derived rides on the back of current infrastructure, and is premised on the assertions that very little additional traffic will be created, or other infrastructure service needs.
  • Water usage by the industrial applications would likely strain existing water supplies, already problematic is this part of French Prairie; further the sewage waste created by 160 personnel are far beyond septic tank capacity in a small portion of this 27 acre property.
  • The increase in helicopter flights will contribute substantial noise pollution to the surrounding area, especially to the residential areas south of subject property, as well as raise significant safety issues by adding a large quantity of helicopter traffic to the existing Aurora Airport traffic patterns without a control tower.

[Download Friends of French Prairie's Letter of Opposition to this application in PDF]

What is missing in this discussion is an Area or Regional Master Plan for the northern end of the Willamette Valley. FOFP is calling on Marion County and the leaders of the municipalities involved to table all development and begin the process of formulating a long term Master Plan for the area bounded by the north Marion County line, Ehlen Road, the Pudding River and Butteville Road. Until such a plan is completed, with adequate public input from citizens and municipalities, only agriculture-related development consistent with the current zoning should be allowed to go forward.

Aurora Airport Expansion

The Aurora Airport is already the busiest municipal airport in Oregon in terms of small plane take offs & landings, and has been the subject of numerous expansion and development proposals over the years. The most recent was Sen. Betsy Johnson's attempt in the final days of the 2007 Oregon Legislative session to sponsor legislation that would have created a self-directed taxing district to enable "tax increment funding" of sewer and water development without the governance of a local government.

Many economic interests, outside our community seek unbridled commercial development with no meaningful input from the people who live here and deal with the consequences. Fortunately, media coverage of this self-serving legislation resulted in a public outcry which assured the measure's death in committee at the Legislature. We are now seeing those interests back, motivated by the large profits of such a land speculation selling prime farmland for commercial and industrial development next to this 'rural' airport.

A New Expansion Threat

Apart from this application for a helicopter operation, for the airport to expand significantly, it needs an FAA-regulated control tower. Marion County has previously applied for full or partial financing for a new airport tower from state Connect Oregon II, Intermodal Transportation funds, generated by higher vehicle registration fees.
The presence of a control tower is part of the intention behind the Rural Airport Expansion bill, and would allow two significant things to happen at Aurora Airport besides the addition of a new helicopter facility:

  • Relocation of many corporate jets from Hillsboro to Aurora to provide more convenient access for corporate owners.
  • Significant airport-related developments, such as a rumored air freight hub located away from Portland International Airport.

Any of these developments would greatly increase local traffic on Hwy 551 (the Canby/Hubbard cutoff), I-5 access at Charbonneau and the Donald/Aurora exits, increase noise pollution for Charbonneau and Aurora, and stress the limited local infrastructure.

This has the potential to become the springboard for much bigger commercial developments, such as the Langdon Farms casino project or the conversion of Langdon Farms or other property adjoining the airport into light industrial developments. All of these will add pollution, traffic and will convert prime farmland to ugly industrial sprawl - not the vision the local community has for its future.

What's Wrong With Development Here?

The big missing ingredient is municipal infrastructure. The Aurora Airport is located in Marion County and is not within the urban growth boundary (UGB) of any of the nearby cities or towns. That means it doesn't have municipal access to development funds and, more importantly, has no municipal oversight. Being outside of an UGB means that development there would lack the local control, checks and balances built into Oregon's land use laws - especially if it could achieve an independent taxing authority such as likely in any Rural Airport Expansion bill. that proposed by Sen. Betsy Johnson and her supporters in the aviation community.

The Aurora Airport is located on prime farm land in northeast French Prairie, is surrounded by agriculture, and sits squarely on EFU zoned land. It is also, along with Langdon Farms, part of the "doorway to the Willamette Valley" heading south from metro Portland. Development here has to be done carefully and with a long term view. Rampant and unchecked development would not only severely damage this local part of French Prairie, but could be the beginning of a development conduit down I-5 to Salem. Once farm land is gone, it never comes back.

Click image for enlarged view

A better alternative is to keep Airport activity inside Urban Growth Boundaries, as is the case with the Salem and Hillsboro airports. Airports and associated developments are urban uses and should be kept out of farm country. Keeping Aurora Airport small, uncontrolled airspace will help protect this area from land speculation and unwise industrialization - there are clearly other, better places for this kind of urbanization.

What's Wrong With a Control Tower?

In principle, nothing! However, recent development options have been pushed by private interests who stand to benefit from the airport expansion, an in practice there are at least three things:

  • First, what's missing? The public! The local residents who will be most impacted have had almost no say, and the public has been kept out by special interests.

    Click image for enlarged view

    Those with vested long term interests, but who are being kept in the dark about the true intentions of the airport development are:
    • Charbonneau residents in the flight path of the airport, within 10,000 feet of the center of the runway.
    • Local residents who live within five miles of the airport and will have to suffer high volumes of traffic, including the communities of Wilsonville, Aurora, Donald, Canby, Hubbard and Woodburn. All citizens within five miles of the Aurora Airport should have an active say in the future of this facility.
    • Local businesses and residents who frequently suffer increased traffic, noise and air pollution from the commercial aviation activity at this airport including helicopters and corporate jet traffic.

      Click image for enlarged view

    • The above impact map is based on an FAA standard of 14,000 feet around an airport, and shows the impact on the ground-but note, that the ring rises in the air as a cone representing airspace around the airport. That leads to the second point: it is entirely inappropriate for a development that is essentially a "municipal and public" asset like an airport to be developed without the impacted municipalities being involved and having a seat at the table. The absence of the public is a clear violation of Land Use Goal 1 - Public Involvement.
  • Second, it is entirely inappropriate for a development that is essentially a "municipal and public" asset like an airport to be developed without the impacted municipalities being involved and having a seat at the table. The absence of the public is a clear violation of Land Use Goal 1 - Public Involvement.
  • Third, the existing Aurora Airport master plan is ten years old and out of date, and the current expansion is going forward without a master plan. An airport expansion of this scope needs to have an updated master plan, be part of a larger French Prairie master plan that includes all effected municipalities, solicits public input, and gives emphasis to protecting the 'agricultural foundation lands' which are the best in the work, unique and threatened by development.

This kind of development should also fit into state-wide goals. For instance, as Salem Municipal Airport expands and adds commercial flights, shouldn't significant airport expansion in north Willamette Valley occur there, in an urban and commercial setting, rather than in the middle of an agricultural area? Alternatives to Aurora Airport Expansion should be considered. Are there other airports already within Urban Growth Boundaries where this growth in aviation should be focused, where there are not the negative impacts on prime agricultural lands?

FOFP Position on the Aurora Airport Expansion

FOFP believes that while development at the Aurora Airport is likely, no development should occur without a new master plan that includes active participation of all effected communities, and also includes adequate public hearings. We have sent a letter to the Marion County Commissioners requesting that the tower funding request be withdrawn and a public hearing process begun.

[Download the letter in PDF]

News Coverage:

Wilsonville Spokesman logo Wilsonville government appeals Aurora Airport decision to Oregon Court of Appeals
December 23, 2020
[Download PDF here]
Controversial Aurora State Airport runway extension plan takes small step forward
December 19, 2020
[Download PDF here]
Wilsonville Spokesman logo Land Use Board of Appeals dismisses Aurora Airport case
December 16, 2020
[Download PDF here]
Wilsonville Spokesman logo Aurora Airport leaders pour money into Wilsonville election
October 5, 2020
[Download PDF here]
Wilsonville Spokesman logo Wilsonville candidates fight over Aurora airport — and Oregon’s land use laws
October 5, 2020
[Download PDF here]
Two cities, two land-use advocacy groups sue to challenge Aurora Airport expansion
Friday, June 26, 2020
[Download PDF here]
Law Suits Stack Up Over Aurora Airport
Tuesday, March 10, 2020
[Download PDF here]
Wilsonville Spokesman logo Aurora Airport master plan under dispute
May 14, 2019
[Download PDF here]
Wilsonville Spokesman logo Wilsonville Contests Airport Expansion
August 15, 2018
[Download PDF here]
Press Release Citizens of Aurora Meet to oppose HB 4092 – Controversial Aurora Airport Land Use bill
January 31, 2018
[Download PDF here]
Wilsonville Spokesman logo Airport improvements benefits few
January 31, 2018
[Download PDF here]
Wilsonville Spokesman logo A Letter of Concern
January 16, 2018
[Download PDF here]
NBAA logo Santa Monica Airport to Close Dec. 12 For 10 Days; Will Reopen With Shorter Runway
November 21, 2017
[Download PDF here]
Los Angeles Times logo Santa Monica Airport will close in 2028 and be replaced by a park, officials say
January 2017
[Download PDF here]
Los Angeles Times logo Santa Monica council votes to close the city's airport by July 2018
August 24, 2016
[Download PDF here]
Aurora Airport summit offers insight
September 23, 2015
[Download PDF here]
Wilsonville Spokesman logo Airport Economic Benefit is Small
January 14, 2014
[Download PDF here]
Wilsonville Spokesman logo Reader View: Airport is vital to region’s economy
December 18, 2013
[Download PDF here]
Wilsonville Spokesman logo Reader View: Full Story Not Being Told
December 11, 2013
[Download PDF here]
Wilsonville Spokesman logo Aurora control tower up in the air
November 27, 2013
[Download PDF here]
Wilsonville Spokesman logo Reader View: Noise is still a problem at Aurora Airport
October 1, 2013
[Download PDF here]
Aurora State Airport: Finding Its Economic Footing
September 24, 2013
[Download PDF here]
Aurora Airport Master Plan contains more than $20 million
September 28, 2011
[Download PDF here]
City officials target runway expansion
Sunday, August 21, 2011
[Download PDF here]
Woodburn Independent Interest groups wait for next step in Aurora State Airport process
July 6, 2011
[Download PDF here]
The Oregonian Aviation board advances limited Aurora State Airport runway extension
June 24, 2011
[Download PDF here]
The Oregonian Officials to make Aurora State Airport development decision today
June 22, 2011
[Download PDF here]
Salem to pursue a runway extension
Tuesday, May 10, 2011
[Download PDF here]
Some want Oregon rural airports to get urban renewal
Thursday, May 5, 2011
[Download PDF here]
The Oregonian A proposal rejects lengthening the runway for at least two decades
April 8, 2011
[Download PDF here]
Woodburn Independent No runway extension recommended for Aurora State Airport
April 6, 2011
[Download PDF here]
Woodburn Independent Aurora wants to annex airport
March 28, 2011
[Download PDF here]
Woodburn Independent Aviation chairman takes on Wilsonville and Clackamas County
March 16, 2011
[Download PDF here]
Woodburn Independent Airport meeting draws crowd of nearly 100
March 16, 2011
[Download PDF here]
Three nonhighway projects in area to get funding
August 26, 2010
[Download PDF here]
FAA Criticizes Clem's oversight of Aurora Airport
August 25, 2010
[Download PDF here]
Control tower funding takes off before planning
August 24, 2010
[Download PDF here]
Woodburn Independent Control tower planning begins despite concerns
July 29, 2010
[Download PDF here]
Meeting about Aurora Airport to be Thursday
July 17, 2010
[Download PDF here]
Three Mid-Valley projects to ease transportation
July 17, 2010
[Download PDF here]
Aurora air traffic control tower makes priority list
for state funding

June 17, 2010
[Download PDF here]
Airport changes causing concerns
January 30, 2008
[Download PDF here]
Airport zoning upsets growers
Friday, March 14, 2008
[Download PDF here]
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