U.S. Department 

of Transportation 

Federal Aviation 

Administration 

September 16, 2014 

Mr. Russ Maguire, A.A.E. 

Airport Manager 

New England Region 

Norwood Memorial Airport 

125 Access Road 

Norwood, MA 02062 

Dear Mr. Maguire: 

12 New England Executive Pari< 

Burlington, MA 01803 

On Tuesday, August 5, 2014, representatives from the Federal Aviation Administration 

(FAA) and Massachusetts Department of Transportation Aeronautics Division conducted a 

land use inspection at Norwood Memorial Airport (OWD), Norwood, Massachusetts. We 

would like to thank you and your Commissioners for the time and attention you committed 

to our visit. 

The purpose of the inspection was to determine whether the airport sponsor, Town of 

Norwood and its Airport Commission, is in compliance with the terms of its Federal 

obligations dealing with airport property use, lease agreements and property releases. The 

inspection included a review of airport property use in accordance with the currently 

approved Airport Layout Plan (ALP) dated October 30, 2007. 

We are providing you with a Land Use Inspection Report documenting our discussion and 

observations during the inspection. The compliance action items noted under Inspection 

Remarks require the airport sponsor submit a corrective action plan to this office by October 

20, 2014. Should you have any questions please contact Thomas Vick, the New England 

Region Airport Compliance and Land Use Specialist, at 781-238-7618. 

T. Walsh 

v~

Jw, Airports Division 

cc: MassDOT Aeronautics Division 
LAND USE INSPECTION REPORT 

Norwood Memorial Airport- August 2014 

Federal Aviation Administration, New England Region, Airports Division 

Inspection Site Location: 

Norwood Memorial Airport (OWD), Norwood, MA 

Individuals Conducting Inspection: 

Thomas Vick, FAA, New England Region Airports Division, Compliance Specialist 

Lisa Lesperance, FAA, New England Airports Division, Planner 

Lauren King, FAA, New England Airports Division, Management Analyst 

Steven Rawding , MassDOT Aeronautics, Planner 

Purpose: 

This inspection serves as part of the FAA's compliance oversight of federally obligated General 

Aviation Airports in order to assess if airport land-uses comply with Federal requirements. The 

inspection was conducted as per Senate Report No.1 06-55, dated May 1999 and Compliance 

Letter 2002-01 , dated May 15, 2002, Regional Land Use Inspections. 

Airport Owner/Operator: 

Owner/Operator- Town of Norwood 

Airport Manager- Norwood Airport Commission, Russ Maguire, A.A. E. 

Airport Master Record - 5010: (Operations for 12 months ending 9/30/2013) 

1. Based Aircraft - 114 

2. Multi-Engine - 10 

3. Jet- 8 

Operations 

4. Air Taxi - 22,000 

5. GA Local- 40,000 

6. GA Itinerant- 37,000 

7. Military - 800 

Total Annual Operations - 99,800 

Airport Federal Obligations: 

1. Expired AP-4 Agreements 

2. Grant Agreements under Airport Improvement Program (AlP), Federal-Aid 

Airport Progress (FAAP), and/or Airport Development Aid Program (ADAP) 

3. Assurance pursuant to Title VI, Civil Rights Act of 1964 

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LAND USE INSPECTION REPORT 

Norwood Memorial Airport- August 2014 

Federal Aviation Administration, New England Region, Airports Division 

Aerial View of Airport Property: 

Airport Background/History 

Norwood Memorial Airport (OWD) is a general aviation reliever airport owned and operated by 

the Town of Norwood through its Airport Commission. OWD has an air traffic control tower that 

is contracted by Midwest ATC. It is operational daily. 

OWD has two runways that are both paved asphalt and several helipads. The FAA funded a 

FAR Part 150 noise compatibility study for OWD in 1986. 

The airport has received more than $17M in entitlement and discretionary airport improvement 

funding since the program began in 1982. 

Special Grant Assurance 

As a Commonwealth of Massachusetts airport sponsor, there is a required special condition 

added to the Massachusetts airports' grant agreements. It states: 

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LAND USE INSPECTION REPORT 

Norwood Memorial Airport- August 2014 

Federal Aviation Administration, New England Region, Airports Division 

''The FAA, in tendering this offer on behalf of the United States, recognizes the existence 

of an agency relationship between the Town of Norwood, as principal, and the 

Massachusetts Aeronautics Commission, as agent, created by an Agreement of Agency 

dated April 21, 1971, which incorporated herein by reference. The sponsor agrees that 

said Agency Agreement will not be amended, modified or terminated without the prior 

written approval of the FAA. " 

Airport Sponsor's Compliance with Federal Obligations 

There was a Title 14 Code of Federal Regulations Part 16 Complaint filed in 2008, Boston Air 

Charter, Complainant, versus Norwood Airport Commission, Norwood, Massachusetts, FAA 

Docket Number 16-07-03. The FAA investigation found that the Town of Norwood was in 

noncompliance of its grant assurances. The FAA required the Town of Norwood to provide a 

corrective action plan to address how the Airport will provide access to aeronautical service 

providers to establish a fuel facility and conduct self-fueling operations consistent with state and 

local regulations; will end the practice of awarding long-term leases of federally funded ramps 

that have the effect of granting one party control over the majority of the ramps on the Airport; 

put in place short term ramp leasing policy for the Airport to assert more control of the federally 

funded ramps; and will regain the Airport's rights and powers to access the 1100 foot strip to 

provide power to the Airport ramps for Airport tenants. The Town provided a corrective action 

plan that the FAA concurred with . 

In 2014, the FAA opened a Title 14 Code of Federal Regulations Part 13 Informal Investigation 

concerning the Town of Norwood's compliance with its grant assurances on unjust 

discrimination and exclusive rights. At this time, the investigation is pending additional 

information from the complainant. 

Because of the ongoing Part 13 complaint, issues related to that complaint are not discussed in 

this inspection. Consequently, the FAA may require follow-up meetings and actions by the 

Town on additional questions after the Town addresses the findings in this land use inspection. 

Airport Operations, Pavement, and General Maintenance 

A tour of the facility demonstrated the useable pavement and associated markings to be in good 

condition. This had been confirmed by the review of the Pavement Analysis Study for OWD 

financed by the Massachusetts DOT Aeronautics in 2012. 

There is an established Vegetation Management Plan that is required under state law by the 

Commonwealth of Massachusetts Department of Environmental Programs. The airport also 

conducts daily airfield inspections, which includes wildlife and if necessary, issuing a daily 

NOT AM for bird activity on the airport. 

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LAND USE INSPECTION REPORT 

Norwood Memorial Airport- August 2014 

Federal Aviation Administration, New England Region, Airports Division 

Airport Existing Land Use Analysis 

This land use inspection focuses on the Airport's adherence to several key Airport 

Improvement Program Grant Assurances: 

Assurance 5 - Preserving Rights and Powers 

Assurance 19 - Operation and Maintenance 

Assurance 20 - Hazard Removal and Mitigation 

Assurance 23 - Exclusive Rights 

Grant Assurance 5. Preserving Rights and Powers. 

Grant Assurance 5 states the Sponsor: 

"a. It will not take or permit any action which would operate to deprive it of any of the 

rights and powers necessary to perform any or all of the terms, conditions, and 

assurances in the grant agreement without the written approval of the Secretary, and will 

act promptly to acquire, extinguish or modify any outstanding rights or claims of right of 

others which would interfere with such performance by the sponsor. This shall be done 

in a manner acceptable to the Secretary. 

b. It will not sell, lease, encumber, or otherwise transfer or dispose of any part of its title 

or other interests in the property shown on Exhibit "A " to this application or, for a noise 

compatibility program project, that portion of the property upon which federal funds have 

been expended, for the duration of the terms, conditions, and assurances in the grant 

agreement without approval by the Secretary. If the transferee is found by the Secretary 

to be eligible under Title 49, United States Code, to assume the federal obligations of the 

grant agreement and to have the power, authority, and financial resources to carry out 

all such federal obligations, the sponsor shall insert in the contract or document 

transferring or disposing of the sponsor's interest, and make binding upon the transferee 

all of the terms, conditions, and assurances contained in this grant agreement." 

Inspection Remarks Concerning Grant Assurance 5 

The Exhibit A (i.e. the airport property map) and Airport Layout Plan (ALP) needs to be updated. 

The airport management team was unsure of the property lines on certain parcels. These 

parcels of land need to be properly surveyed and identified whether the airport sponsor, the 

Norwood Airport Commission, is the owner of the properties. One parcel of concern includes 

lands outside the airfield fence adjacent to the Verizon parking lot. The other includes the 

parcels of leased airport property in dispute between Boston Aircraft Group and Boston 

Executive Helicopters. 

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LAND USE INSPECTION REPORT 

Norwood Memorial Airport- August 2014 

Federal Aviation Administration, New England Region, Airports Division 

Airport restaurants are considered a non-aeronautical activity. The airport restaurant should be 

designated as interim non-aeronautical purposes on the appropriate ALP exhibit sheets. The 

inspection also identified a public observation area located on land designated as aeronautical. 

While this use is currently acceptable since there is no current demand for it, the airport 

management staff stated that there is very limited available usable land for further development. 

Therefore, this area should also be designated on the ALP sheets as an interim nonaeronautical use activity to protect it to meet a future aviation activity. 

In addition, airport management staff indicated that they were unaware whether the subtenant 

leases were formally reviewed and approved by the airport sponsor. By failing to review and 

approve subleases, the airport sponsor could be depriving itself of being able to perform all of its 

Federal obligations. FAA strongly recommends that the sponsor reviews and approves all 

subtenant leases. 

Grant Assurance 19 Operation and Maintenance. 

This grants states that: 

"a. The airport and all facilities which are necessary to serve the aeronautical users of 

the airport, other than facilities owned or controlled by the United States, shall be 

operated at all times in a safe and serviceable condition and in accordance with the 

minimum standards as may be required or prescribed by applicable federal , state and 

local agencies for maintenance and operation. It will not cause or permit any activity or 

action thereon which would interfere with its use for airport purposes. It will suitably 

operate and maintain the airport and all facilities thereon or connected therewith, with 

due regard to climatic and flood conditions. Any proposal to temporarily close the airport 

for nonaeronautical purposes must first be approved by the Secretary. In furtherance of 

this assurance, the sponsor will have in effect arrangements for: 

(1) Operating the airport's aeronautical facilities whenever required; 

(2) Promptly marking and lighting hazards resulting from airport conditions, including 

temporary conditions; and 

(3) Promptly notifying airmen of any condition affecting aeronautical use of the airport." 

Inspection Remarks Concerning Grant Assurance 19 

The inspection noted a picnic bench and a snowblower inside the airfield fence line. While a 

small snowblower may be acceptable during snow season, it needs to be removed from the 

aircraft ramp during the offseason. During snow season, it needs to be located on the grass 

behind the aircraft. The picnic bench needs to be removed from the airfield . 

The airport reported there is bird activities on the airport particularly waterfowl that come from 

the adjacent river. According to the airport management staff, there are only daily inspections 

on weekdays or special inspections. When they observe a wildlife hazard, the staff issues a 

NOT AM. Thus, it is conceivable that there may be a wildlife hazard and a NOT AM is not 

issued. Consequently, it is recommended that the airport sponsor insert a comment in the 

Airport Facility Directory (AFD) to provide further notification of wildlife hazards to pilots. 

Grant Assurance 20. Hazard Removal and Mitigation. 

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LAND USE INSPECTION REPORT 

Norwood Memorial Airport- August 2014 

Federal Aviation Administration, New England Region, Airports Division 

This grant assurance states that the sponsor: 

"It will take appropriate action to assure that such terminal airspace as is required to 

protect instrument and visual operations to the airport (including established minimum 

flight altitudes) will be adequately cleared and protected by removing , lowering, 

relocating , marking, or lighting or otherwise mitigating existing airport hazards and by 

preventing the establishment or creation of future airport hazards." 

Inspection Remarks Concerning Grant Assurance 20 

It appears that there are trees penetrating the approach surfaces to the runways. The airport 

management staff confirmed that these trees are located on airport sponsor owned property. 

The airport sponsor must clear the tree obstructions that penetrate the approaches to the 

runways . 

Grant Assurance 23. Exclusive Rights. 

This Assurance states: 

"It will permit no exclusive right for the use of the airport by any person providing , or 

intending to provide, aeronautical services to the public. For purposes of this paragraph, 

the providing of the services at an airport by a single fixed-base operator shall not be 

construed as an exclusive right if both of the following apply: 

a. It would be unreasonably costly, burdensome, or impractical for more than one fixedbase operator to provide such services, and 

b. If allowing more than one fixed-base operator to provide such services would require 

the reduction of space leased pursuant to an existing agreement between such single 

fixed-base operator and such airport. 

It further agrees that it will not, either directly or indirectly, grant or permit any person, 

firm , or corporation, the exclusive right at the airport to conduct any aeronautical 

activities, including , but not limited to charter flights, pilot training, aircraft rental and 

sightseeing, aerial photography, crop dusting, aerial advertising and surveying, air 

carrier operations, aircraft sales and services, sale of aviation petroleum products 

whether or not conducted in conjunction with other aeronautical activity, repair and 

maintenance of aircraft, sale of aircraft parts, and any other activities which because of 

their direct relationship to the operation of aircraft can be regarded as an aeronautical 

activity, and that it will terminate any exclusive right to conduct an aeronautical activity 

now existing at such an airport before the grant of any assistance under Title 49, United 

States Code." 

Inspection Remarks Concerning Grant Assurance 23 

FAA has no comments or remarks concerning this Grant Assurance at this time. 

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