U.S. Department of Transportation (DOT)

Federal Aviation Administration (FAA)

Section 804 Collaborative Workgroup

FAA National Facilities Realignment and

Consolidation Report

Part 2 Recommendations

Response to U.S. Congress

FAA Reauthorization Bill

Public Law 112-95

Section 804

DRAFT DATE: May 11, 2016

i
Contents

Executive Summary........................................................................................................................ 1

Introduction..................................................................................................................................... 2

Section 804 Collaborative Workgroup ........................................................................................... 2

Four-Step Process for Facilities Realignment Analysis.................................................................. 3

Report Scope................................................................................................................................... 4

FAA Administrator’s Recommendations ....................................................................................... 4

Recommendation #1: Realign Erie (ERI) TRACON Operations to Buffalo (BUF)................... 5

Background.............................................................................................................................. 5

Approach ................................................................................................................................. 5

Recommendation and Administrator’s Justification ............................................................... 5

Projected Costs and Savings.................................................................................................... 6

Recommendation # 2: Realign Akron-Canton (CAK) and Mansfield (MFD) TRACON 

Operations to Cleveland (CLE)................................................................................................... 7

Background.............................................................................................................................. 7

Approach ................................................................................................................................. 7

Recommendation and Administrator’s Justification ............................................................... 7

Projected Costs and Savings.................................................................................................... 8

Recommendation #3: Realign Grand Rapids (GRR), Lansing (LAN), Muskegon (MKG), Flint 

(FNT) & Saginaw (MBS) TRACON Operations to Kalamazoo (AZO) .................................... 9

Background.............................................................................................................................. 9

Approach ............................................................................................................................... 10

Recommendation and Administrator’s Justification ............................................................. 10

Projected Costs and Savings.................................................................................................. 11

Recommendation #4: Sustain and Maintain TRACON Operations at Toledo (TOL).............. 11

Background............................................................................................................................ 11

Approach ............................................................................................................................... 12

Recommendation and Administrator’s Justification ............................................................. 12

Projected Costs and Savings.................................................................................................. 12

Recommendation #5: Sustain and Maintain TRACON Operations at Youngstown (YNG).... 13

Background............................................................................................................................ 13

Approach ............................................................................................................................... 14

Recommendation and Administrator’s Justification ............................................................. 14

ii
Projected Costs and Savings.................................................................................................. 14

Proposed Timing for Implementation of Recommendations........................................................ 15

Conclusion .................................................................................................................................... 15

Federal Register Publication......................................................................................................... 16

iii
Executive Summary

A collaborative workgroup of representatives from the Federal Aviation Administration (FAA), 

the National Air Traffic Controllers Association (NATCA) and the Professional Aviation Safety 

Specialists (PASS) labor unions was established to analyze FAA’s Terminal Radar Approach 

Control (TRACON) facilities for realignment, pursuant to Section 804 of the FAA 

Modernization and Reform Act of 2012 (P.L. 112-95). 

The Section 804 collaborative workgroup conducted comprehensive analysis of TRACON 

operations by gathering and reviewing operational and technical requirements for facilities being 

reviewed, considering workforce impacts, gathering and evaluating stakeholder input, and 

estimating costs and benefits of potential realignments. 

The workgroup developed, validated, and presented its realignment recommendations to FAA 

and labor union leadership, and drafted this report for the FAA Administrator’s review and 

submission to Congress and the Federal Register. 

The following recommendations are contained in this report:

1. Realign Erie, PA (ERI) TRACON operations to Buffalo, NY (BUF) Tower / TRACON

2. Realign Akron-Canton, OH (CAK) and Mansfield, OH (MFD) TRACON operations to 

Cleveland, OH (CLE) Tower / TRACON

3. Realign Grand Rapids, MI (GRR), Lansing, MI (LAN), Muskegon, MI (MKG), Flint, MI

(FNT), and Saginaw, MI (MBS) TRACON operations to Kalamazoo, MI (AZO) Tower / 

TRACON

4. Sustain and maintain Toledo, OH (TOL) TRACON operations at the current location

5. Sustain and maintain Youngstown, OH (YNG) TRACON operations at the current 

location

Per statutory requirements, the justification and details for the collaboratively developed

recommendations are provided in the sections below.

1
Introduction

Section 804 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 

2012 (P.L. 112-95) requires the FAA to develop a plan for realigning and consolidating facilities 

and services in an effort to support the transition to NextGen, and to reduce capital, operating, 

maintenance, and administrative costs where such cost reductions can be implemented without 

adversely affecting safety. 

To comply with Section 804 requirements, the FAA formed a collaborative workgroup with the 

National Air Traffic Controllers Association (NATCA) and the Professional Aviation Safety 

Specialists (PASS) labor unions. The workgroup developed a comprehensive process for 

facilities and service realignment analysis, and was chartered to conduct the analysis and to 

develop recommendations, taking the following factors into consideration: 

• NextGen readiness of facilities

• Terminal Automation Modernization and Replacement (TAMR) program schedule

• Operational and airspace factors

• Existing facility conditions and workforce impacts

• Industry stakeholder input

• Costs and benefits associated with each potential realignment alternative

• Facilities and engineering planning and priorities

• Employee career development

Per statutory requirements, the realignment recommendations are developed in coordination with 

the FAA’s Chief NextGen Officer and the Chief Operating Officer of the Air Traffic 

Organization (ATO), and are approved by the FAA Administrator.

Section 804 Collaborative Workgroup

The Section 804 collaborative workgroup developed the guiding principles and criteria for 

evaluating existing TRACON operations. The principles support the goals of developing 

operationally viable realignment and consolidation scenarios, capturing recommendations, and 

outlining next steps. 

The workgroup has developed a repeatable and defensible four-step process to:

• Evaluate facility TRACON operations and prioritize for analysis 

• Determine an initial set of realignment scenarios and a set of alternatives for each

scenario

• Collect facility and operational data, and document system requirements

• Document facility, equipment, infrastructure, operational and safety data

• Capture qualitative workforce considerations, including training, transition, facility, and

potential workforce impacts of potential realignments

2
• Consider potential impacts on operations, airspace modifications, route / fix changes,

arrival / departure procedures, intra / inter-facility coordination, and pilot community

interaction

• Collect and consider industry stakeholder input

• Quantify benefits and cost of potential realignments 

• Develop a recommendation for each realignment scenario 

Four-Step Process for Facilities Realignment Analysis

Each step of the process developed by the workgroup is outlined below:

Section 804 Four-Step Process Overview

The process serves as the platform for analyzing ATC facilities and services for potential 

realignments. To evaluate the realignment scenarios, the workgroup conducts working sessions 

at FAA headquarters, followed by site surveys at all facilities under analysis. At each facility the 

workgroup leadership facilitates sessions with facility management, labor representatives, and 

stakeholders. Stakeholders are briefed on the process, and meetings are held to answer questions 

and collect input. 

The workgroup’s technical and operational experts evaluate the airspace, equipment, facility, 

operational, and safety factors for each alternative in the analysis, and document the findings in 

Systems Analysis and Requirements Documents (SARDs), which serve as the basis for 

subsequent business case analysis. Workforce impact considerations, and future staffing and 

training requirements are captured, documented, and reviewed by the workgroup prior to making 

recommendations.

Throughout each step of the analysis, the workgroup interfaces with multiple FAA programs and 

organizations to fully inform its analysis and provide regular updates. The workgroup continually 

improves its processes by reviewing lessons learned from previous realignments, eliciting feedback 

from the facilities undergoing analysis, and refining working activities.

Realignment recommendations resulting from the four-step process are developed to:

• Maintain or improve operational safety and ensure service resilience

3
• Facilitate transition to NextGen

• Enable operational improvements

• Improve facility conditions

• Prioritize current and future investments

• Utilize agency assets more effectively

• Enhance controller proficiency

• Enhance career development and training opportunities

The workgroup operates in conjunction with the agency’s NextGen deployment initiatives and 

schedules, and focuses on smaller TRACON facilities and operations. In the future, the process 

and analysis may be adapted to include the FAA’s larger ATC facilities. However, at this time, 

the FAA does not have the necessary funds or planning capacity to consider these facilities for 

realignments or consolidations. 

Report Scope 

This report contains the details and results of analyzing 19 TRACON facilities. The majority of 

facilities included in this report were considered legacy sites – those sites were identified by the 

FAA to be realigned prior to enactment of Section 804 of the FAA Modernization and Reform 

Act of 2012 and workgroup establishment. 

FAA Administrator’s Recommendations 

The following recommendations are contained in this report:

1. Realign Erie, PA (ERI) TRACON operations to Buffalo, NY (BUF) Tower / TRACON

2. Realign Akron-Canton, OH (CAK) and Mansfield, OH (MFD) TRACON operations to 

Cleveland, OH (CLE) Tower / TRACON

3. Realign Grand Rapids, MI (GRR), Lansing, MI (LAN), Muskegon, MI (MKG), Flint, MI 

(FNT), and Saginaw, MI (MBS) TRACON operations to Kalamazoo, MI (AZO) Tower / 

TRACON

4. Sustain and maintain Toledo, OH (TOL) TRACON operations at the current location

5. Sustain and maintain Youngstown, OH (YNG) TRACON operations at the current 

location

Details for each realignment scenario and recommendation are provided in the sections below.

4
Recommendation #1: Realign Erie (ERI) TRACON Operations to Buffalo 

(BUF)

The Section 804 workgroup evaluated ERI TRACON operations for realignment to BUF, CLE, 

or Pittsburgh (PIT) Tower / TRACON. 

Background

ERI Tower / TRACON was constructed in 1957. The local airport authority owns the facility and 

leases it to the FAA. In 1987 the facility was converted from a TRACAB to a Tower / TRACON 

configuration. In 2004, the facility underwent a complete refurbishment. ERI is an ATC level 5 

and the hours of operation are 0600-2400. ERI TRACON operations in CY 2014 were 33,929 

annually.1

BUF Tower / TRACON was constructed in 1994. The FAA owns the facility. BUF is an ATC 

level 8 facility and it operates 24 hours a day. BUF is sufficiently sized to accommodate ERI 

TRACON operations. BUF TRACON operations in CY 2014 were 138,229 annually.

Approach

The workgroup conducted a working session at FAA headquarters, followed by stakeholder 

meetings and site surveys at ERI, CLE, BUF, and PIT. 

During the evaluation, CLE and PIT were removed from further consideration because there 

were no operational synergies or other indicators supporting further analysis of realignment. 

Some ERI stakeholders expressed concerns regarding the potential loss of local knowledge

relating to interaction with Canadian ATC facilities and unique weather patterns, such as lakeeffect snow, in the Erie area. Both ERI and BUF facilities have existing communications with 

Canadian ATC facilities and experience similar weather patterns.

Recommendation and Administrator’s Justification

Upon applying the agreed-upon process and analysis, the workgroup recommends realigning ERI 

TRACON operations to BUF. 

Pursuant to the statute, realignment to BUF could accelerate the transition to NextGen-enabling 

automation for ERI airspace. BUF is a NextGen-enabled facility built to current design and 

safety standards, with ample space and existing capacity to accommodate ERI operations. ERI 

and BUF have contiguous airspace. Both facilities acknowledged limited RADAR coverage in 

the Jamestown airspace that could be improved by realigning ERI operations to BUF and 

merging the airspace between the two facilities. With airspace redesign, operational benefits such 

as reductions in boundary coordination could improve the current airspace efficiency. 

At the time of analysis, ERI was one of the five slowest TRACONs in the NAS. The low level of 

operations presents a challenge in training and certifying controllers at ERI TRACON.

BUF TRACON can accept ERI operations with minimal facility expansion or reconfiguration. 

1 FAA OpsNet was a source for all CY 2014 facility traffic counts quoted throughout this document. 

5

 
Projected Costs and Savings 

The ERI business case indicates that realignment of ERI TRACON operations to BUF provides a

slightly negative return-on-investment, given the project lifecycle duration of 2015 to 2034, with 

the B/C ratio of 0.984, and an NPV of -$159.7K. A B/C ratio of 1 or above is considered 

positive. The costs and benefits were estimated conservatively: only 50% of the potential air 

traffic staffing efficiencies were taken into account and the resulting number was further riskadjusted to the 80% confidence level, in accordance with FAA and OMB guidance. If calculated 

using 100% of expected staffing efficiencies, the B/C ratio would increase to 1.08 with a NPV of 

$788.5K. 

The primary cost drivers were salary increases related to moving from the existing ATC level 5 

(ERI) facility to an ATC level 8 (BUF) facility. Other key realignment costs included planning, 

site preparation/installation, controller and technician training and overtime, and Permanent 

Change of Station (PCS) compensation.

Savings include the avoidance of purchasing and refreshing a STARS system and scheduling

efficiencies for both ERI and BUF personnel upon realignment.

Business Case Summary Tables for ERI

Table 1: Cost Summary (Risk Adjusted, Then-Year $K)

Type Mod-Sustain Realign

Investment F&E Total $3,582 $2,082

Indirect F&E Total $134,698 $131,102

O&M Total $474,850 $480,562

Table 2: Economic Analysis Summary (Risk Adjusted, Present Value $K)

Type Mod-Sustain Realign

Realignment Costs - $10,062

Cost Savings/Avoidance - $9,902

Net Present Value (NPV) - -$159.7

B/C Ratio - 0.984

6
Recommendation # 2: Realign Akron-Canton (CAK) and Mansfield (MFD)

TRACON Operations to Cleveland (CLE)

The workgroup evaluated CAK TRACON operations for realignment to PIT or CLE. 

Concurrently, the workgroup evaluated MFD TRACON operations for realignment to Columbus 

(CMH) Tower / TRACON or CLE Tower / TRACON. 

Background

CAK Tower / TRACON was constructed in 1961. The FAA leases the CAK structure. In the 

event of CAK TRACON realignment to CLE, the agency would continue to lease portions of this 

space to operate the CAK Tower. CAK is an ATC level 7 facility, and it operates 24 hours a day 

for Tower and 0600-2400 for the TRACON. CAK TRACON operations in CY 2014 were 

101,321 annually.

MFD Tower / TRACON was constructed in 1974. The FAA owns the facility. The MFD 

equipment room is at capacity for any future equipment that may be deployed. MFD is an ATC 

level 5 facility, and the hours of operation are 0600-2300. MFD TRACON operations in CY 

2014 were 31,702 annually.

CMH Tower / TRACON was constructed in 2004. The FAA owns the facility. CMH is an ATC 

level 9 facility, and it operates 24 hours a day. CMH TRACON operations in CY 2014 were 

322,744 annually.

PIT Tower / TRACON was constructed in 1985. The FAA owns the facility. PIT is an ATC level 

9 facility, and it operates 24 hours a day. PIT TRACON operations in CY 2014 were 249,856

annually.

CLE is an ATC level 9 facility, and it operates 24 hours a day. The FAA owns the facility. CLE 

TRACON operations for CY 2014 were 198,463. 

The FAA commissioned a new CLE Tower / TRACON in September 2015 with an overall cost 

of approximately $75M:

• The agency’s investment into the new CLE Tower / TRACON is considered sunk cost 

and therefore was not accounted for in the current realignment business case, in 

accordance with standard accounting practices. 

• The new CLE facility was designed and constructed to accommodate the realignments of 

TOL, MFD, CAK, and YNG TRACONs. This plan was developed before Section 804 of 

the FAA Modernization and Reform Act of 2012 was enacted.

• The new CLE Tower / TRACON is a state-of-the art facility with redundant engine 

generators, uninterruptible power supply (UPS) / power conditioning system (PCS), and 

environmental systems. 

Approach

The workgroup conducted working sessions at FAA headquarters and in Columbus, OH, 

followed by stakeholder meetings and site surveys at CAK, MFD, CMH, PIT, and CLE.

Recommendation and Administrator’s Justification

Upon applying the agreed-upon process and conducting analysis, the workgroup recommends 

realigning CAK and MFD TRACON operations to CLE.

7
The realignments support the transition to NextGen-enabling automation for the CAK and MFD 

airspace and enable 24-hour approach control service for CAK and MFD.

Future airspace redesign, which may be enabled by the realignment, is expected to result in 

operational benefits such as reductions in boundary coordination. 

At the time of the analysis, MFD was one of the five slowest TRACONs in the NAS. The low 

level of operations there present a challenge in training and certifying controllers in the 

TRACON. Realignment to CLE may provide the relocated workforces with enhanced career 

progression opportunities, and create a more effective training environment through additional 

levels of complexity and higher traffic volume. The realignments will allow for the efficient use 

of the new CLE facility, which was designed and built to accommodate these facilities. 

Employees currently working in aging facilities will operate in a NextGen-enabled state-of-theart facility that meets current standards and building codes. 

While some CAK stakeholders expressed concern about the potential loss of local knowledge, 

other stakeholders favored the realignment as it would provide 24-hour-a-day approach control 

service.

Projected Costs and Savings

The CAK and MFD business case indicates that realignment to CLE provides a slightly negative 

return-on-investment, given the project lifecycle duration of 2015 to 2034, the benefit to cost 

(B/C) ratio of 0.95, and a negative NPV of just under $1M. The costs and benefits were 

estimated conservatively: only 50% of the potential air traffic staffing efficiencies were taken 

into account and the resulting number was then further risk-adjusted to the 80% confidence level, 

in accordance with FAA and OMB guidance. If calculated using 100% of expected staffing 

efficiencies, the B/C ratio would increase to 1.47 with a NPV of $8.2M.

The estimated cost of realigning CAK and MFD TRACON operations to CLE is $18.21M. The 

primary cost drivers were salary increases related to moving from the existing lower ATC level 

facilities (CAK, MFD) to an ATC level 9 (CLE) facility.

The estimated cost savings are approximately $17.24M. The CAK and MFD realignments will

offer savings in equipment and technology refreshment over “mod-sustain” alternative, as well 

as controller salary savings through scheduling efficiencies. Additional salary savings are 

realized in the long term due to the lowered ATC level of CAK and MFD Towers.

Business Case Summary Tables for CAK and MFD

Table 1: Cost Summary (Risk Adjusted, Then-Year $K)

Type Mod-Sustain Realign

Investment F&E Total $9,156 $5,458

Indirect F&E Total $356,595 $358,280

O&M Total $1,052,632 $1,060,525

8
Table 2: Economic Analysis Summary (Risk Adjusted, Present Value $K)

Type Mod-Sustain Realign

Realignment Costs - $18,214

Cost Savings/Avoidance - $17,241

Net Present Value (NPV) - -$972.9

B/C Ratio - 0.947

Recommendation #3: Realign Grand Rapids (GRR), Lansing (LAN), 

Muskegon (MKG), Flint (FNT) & Saginaw (MBS) TRACON Operations to 

Kalamazoo (AZO)

The workgroup evaluated the following realignment scenarios:

• GRR TRACON operations for potential realignment to AZO or South Bend (SBN)

• MKG TRACON operations for potential realignment to AZO, SBN, or Milwaukee 

(MKE)

• FNT TRACON operations for potential realignment to AZO or Detroit (D21)

• LAN TRACON operations for potential realignment to AZO or D21 

• MBS TRACON operations for potential realignment to AZO or D21

• Fort Wayne (FWA) TRACON operations for potential realignment to AZO or SBN

Background

GRR Tower / TRACON was constructed in 1963. The FAA owns the facility. GRR is an ATC 

level 7 facility, and its hours of operation are 0530-2400. GRR TRACON operations for CY 

2014 were 97,884. 

MKG Tower was commissioned in 1967, originally in a TRACAB configuration. The TRACON 

was commissioned in 1979 with the addition of a base building. The FAA owns the facility. 

MKG is an ATC level 5 facility, and its hours of operation are 0600-2300. MKG TRACON 

operations for CY 2014 were 47,376.

MBS Tower / TRACON was constructed in 1966. The FAA owns the facility. MBS is an ATC 

level 5 facility, and its hours of operation are 0600-2300. MBS TRACON operations for CY 

2014 were 43,598.

FNT Tower / TRACON was constructed in 1997. The FAA owns the facility. FNT is an ATC 

level 5 facility, and its hours of operation are 0545-2330. FNT TRACON operations for CY 

2014 were 51,298.

9
LAN Tower / TRACON was constructed in 1958. The FAA owns the facility. LAN is an ATC 

level 6 facility, and it operates 24 hours a day. LAN TRACON operations for CY 2014 were 

80,721.

AZO Tower / TRACON was commissioned in 2014. The FAA owns the facility. AZO is an 

ATC level 6 facility, and its hours of operation are 0600-2300. AZO TRACON operations for 

CY 2014 were 72,133. 

The AZO TRACON was designed to accommodate additional TRACON positions. The overall 

cost of the facility was approximately $28M: 

• The agency’s investment into the AZO Tower / TRACON is considered sunk cost and 

therefore was not accounted for in the current realignment business cases, in accordance 

with standard accounting practices. 

• The AZO Tower / TRACON facility was designed and constructed to accommodate the 

realignments of GRR, MKG, and LAN TRACON operations. This plan was developed 

before Section 804 of the FAA Modernization and Reform Act of 2012 was enacted. 

• The new AZO Tower / TRACON is a state-of-the art facility with redundant engine 

generators, UPS / PCS, and environmental systems. 

Approach

The workgroup conducted working sessions at FAA headquarters and field sessions in Saginaw 

and Flint, MI, followed by stakeholder meetings and site surveys at MBS, FNT, LAN, MKG, 

GRR, FWA, D21, MKE, SBN, and AZO. 

The initial scope of the analysis included GRR, MKG, LAN, and FWA. Based on facility input 

during the working sessions and site surveys, the workgroup determined that inclusion of MBS 

and FNT would provide a more comprehensive analysis of the facilities in the region. 

FWA, D21, SBN, and MKE were removed from further consideration during the evaluation 

process due to lack of operational synergies or other indicators supporting further realignment

analysis. 

Recommendation and Administrator’s Justification

Upon applying the agreed-upon process and conducting analysis, the workgroup recommends 

realigning GRR, MKG, MBS, FNT, and LAN TRACON operations to AZO Tower / TRACON.

The realignments support the transition to NextGen-enabling automation for the GRR, MKG,

MBS, FNT, and LAN airspace. The realignment will enable 24-hour approach control service for 

GRR, MKG, MBS, and FNT. LAN currently has 24-hour approach control service.

Future airspace redesign, which may be enabled by the realignment, is expected to result in 

operational benefits such as reductions in boundary coordination.

At the time of analysis, MKG and MBS were some of the slowest TRACONs in the NAS. The 

low level of operations in those facilities presents a challenge in training and certifying 

controllers in the TRACON. The opportunity to train and develop controllers at mid-level 

facilities should help to prepare certified candidates for busier facilities. The realignments are 

expected to enhance controller career progression opportunities, and will allow the new AZO 

TRACON facility to be used more efficiently. Upon realigning TRACON operations to AZO, 

employees will operate in a NextGen-enabled state-of-the-art facility that meets current 

standards and building codes.

10
Projected Costs and Savings

The GRR, MKG, MBS, FNT, and LAN business case indicates that realignment of TRACON 

operations from those facilities to AZO provides a positive return-on-investment, given the 

project lifecycle duration of 2015 to 2034, with a positive benefit to cost (B/C) ratio of 1.055, 

and an NPV of $3.6M. The costs and benefits were estimated conservatively: only 50% of the 

potential air traffic staffing efficiencies were taken into account and the resulting number was 

then further risk-adjusted to the 80% confidence level, in accordance with FAA and OMB 

guidance.

The primary costs are implementation planning, telecommunications, transition, training,

overtime, staff relocation costs, and additional staffing costs due to facility level upgrades. 

Primary savings are in staffing scheduling efficiencies and the Prime Mission Equipment (PME) 

cost avoidance of purchasing and refreshing STARS at GRR, MKG, MBS, FNT, and LAN.

Business Case Summary Tables for GRR, MKG, MBS, FNT and LAN 

Table 1: Cost Summary (Risk Adjusted, Then-Year $K)

Type Mod-Sustain Realign

Investment F&E Total $15,218 $9,413

Indirect F&E Total $328,740 $310,956

O&M Total $753,357 $774,191

Table 2: Economic Analysis Summary (Risk Adjusted, Present Value $K)

Type Mod-Sustain Realign

Realignment Costs - $65,417

Cost Savings/Avoidance - $69,002

Net Present Value (NPV) - $3,584.7

B/C Ratio - 1.055

Recommendation #4: Sustain and Maintain TRACON Operations at Toledo 

(TOL)

The workgroup evaluated TOL TRACON operations for realignment to CLE, D21, or AZO.

Background

The TOL facility was constructed in 1967. The structure is leased from the Toledo Airport 

Authority, and operated and maintained by the FAA. The facility is in need of modernization. 

The equipment room is at capacity for any future equipment that may be deployed. TOL is an 

11
ATC level 6 facility, and it operates 24 hours a day. TOL TRACON operations for CY 2014 

were 83,129. 

D21 was commissioned in 1992. The FAA owns the facility. D21 is an ATC level 11 facility, 

and it operates 24 hours a day. D21 TRACON operations for CY 2014 were 522,752. 

Approach

To analyze the scenario, the workgroup conducted a working session at FAA headquarters, 

followed by site surveys and stakeholder meetings at TOL, CLE, D21, and AZO. Two

realignment alternatives (TOL to CLE and TOL to AZO) were eliminated due to the lack of 

operational advantages or expected cost savings of realigning to those sites. 

Recommendation and Administrator’s Justification

Upon applying the agreed-upon process and conducting analysis, the workgroup recommends 

sustaining and maintaining TOL TRACON operations at the current location. 

Airspace operations between D21 and TOL are closely aligned, and improvement in air traffic 

flows could possibly result from realignment. 

While realignment to D21 would support the transition to NextGen-enabling automation for TOL 

airspace, the estimated increase in lifecycle costs result in a significantly negative return-oninvestment. 

Projected Costs and Savings

The TOL to D21 business case indicates that realignment of TRACON operations to D21 does 

not provide a positive return-on-investment, given the project lifecycle duration of 2015 to 2034 

and a negative benefit to cost (B/C) ratio of 0.6, and an NPV of negative $8.97M. The costs and

benefits were estimated conservatively: only 50% of the potential air traffic staffing efficiencies 

were taken into account and the resulting number was then further risk-adjusted to the 80% 

confidence level, in accordance with FAA and OMB guidance.

Primary cost drivers are controller salary increases associated with moving from an existing 

ATC level 6 (TOL) to an ATC level 11 (D21) facility, as well as STARS equipment acquisition

at D21, facility modification at D21, and transition, training, overtime, and PCS costs. 

These costs are greater than the savings and the cost avoidance of STARS procurement and 

facility modernization at TOL. 

Due to the significant negative return-on-investment, the workgroup does not recommend this 

realignment, despite potential operational benefits.

12
Business Case Summary Tables for TOL 

Table 1: Cost Summary (Risk Adjusted, Then-Year $K)

Type Mod-Sustain Realign

Investment F&E Total $3,764 $5,348

Indirect F&E Total $383,299 $382,941

O&M Total $1,098,790 $1,110,296

Table 2: Economic Analysis Summary (Risk Adjusted, Present Value $K)

Type Mod-Sustain Realign

Realignment Costs - $22,847

Cost Savings/Avoidance - $13,879

Net Present Value (NPV) - -$8,968.0

B/C Ratio - 0.607

Recommendation #5: Sustain and Maintain TRACON Operations at 

Youngstown (YNG)

The Section 804 workgroup evaluated YNG TRACON operations for potential realignment to 

PIT or CLE. 

Background

YNG Tower / TRACON was constructed in 1970. The FAA owns the facility. YNG is an ATC 

level 5 facility, and it operates 24 hours a day at the Tower and 0600-2400 at the TRACON.

YNG TRACON operations for CY 2014 were 44,416. 

PIT Tower / TRACON was constructed in 1985. The FAA owns the facility. PIT is an ATC level 

9 facility, and it operates 24 hours a day. PIT TRACON operations for CY 2014 were 249,856 

annually.

CLE Tower / TRACON is an ATC level 9 facility, and it operates 24 hours a day. The FAA 

owns the facility. CLE TRACON operations for CY 2014 were 198,463. 

The FAA commissioned a new CLE Tower / TRACON in September 2015 with an overall cost 

of approximately $75M:

• The agency’s investment into the new CLE Tower / TRACON is considered sunk cost 

and therefore was not accounted for in the current realignment business case, in 

accordance with standard accounting practices. 

13
• The new CLE facility was designed and constructed to accommodate the realignments of 

TOL, MFD, CAK, and YNG TRACONs. This plan was developed before Section 804 of 

the FAA Modernization and Reform Act of 2012 was enacted.

• The new CLE Tower / TRACON is a state-of-the art facility with redundant engine 

generators, UPS / PCS, and environmental systems. 

Approach

The workgroup conducted working sessions at FAA headquarters, followed by stakeholder 

meetings and site surveys in YNG, PIT, and CLE.

Recommendation and Administrator’s Justification

Upon applying the agreed-upon process and conducting analysis, the workgroup recommends 

sustaining and maintaining YNG TRACON operations at the current location. 

The recommendation is made because of the significant costs associated with potential 

realignment and lack of operational efficiencies between YNG and either PIT or CLE.

Projected Costs and Savings

The workgroup investigated multiple YNG realignment alternatives, however the resulting 

business cases were not favorable. The business case analysis for YNG indicates realignment of 

TRACON operations to either CLE or PIT would not provide a positive return on investment in 

any realignment alternative, given the project lifecycle duration of 2015 to 2034. The 

realignment of YNG to PIT was the least negative alternative with a BC ratio of 0.7, and a NPV 

of negative $3M. 

The costs and benefits were estimated conservatively: only 50% of the potential air traffic 

staffing efficiencies were taken into account and the resulting number was then further riskadjusted to the 80% confidence level, in accordance with FAA and OMB guidance.

Primary cost drivers were staffing costs, with a significant increase in air traffic controller 

salaries associated with moving from ATC level 5 facility (YNG) to ATC level 9 (PIT) facility.

Primary cost savings were the cost avoidance of purchasing and refreshing STARS equipment at 

YNG. However, the costs were far greater than the cost avoidance or savings offered by 

realignment. 

Due to the significant negative return-on-investment of any YNG scenarios, the workgroup does 

not recommend this realignment, despite potential operational benefits.

14
Business Case Summary Tables for YNG

Table 1: Cost Summary (Risk Adjusted, Then-Year $K)

Type Mod-Sustain Realign

Investment F&E Total $2,890 $2,085

Indirect F&E Total $304,109 $308,274

O&M Total $883,533 $891,903

Table 2: Economic Analysis Summary (Risk Adjusted, Present Value $K)

Type Mod-Sustain Realign

Realignment Costs - $10,344

Cost Savings/Avoidance - $7,348

Net Present Value (NPV) - -$2,995.5

B/C Ratio - 0.710

Proposed Timing for Implementation of Recommendations

The implementation of facility and operational realignments and staff moves are subject to 

current labor and FAA collective bargaining agreements, which require a 12 month notification 

to the workforce as well as other FAA policies, and regulations. The FAA currently plans to 

notify the workforce of the recommendations in 2016, initiate project implementation in 2017, 

and conduct the cutovers in 2018. Implementation of each realignment is contingent on funding 

and resource availability.

Conclusion 

The realignment recommendations outlined in this report are the result of a collaborative process 

that involved a multi-disciplinary workgroup of representatives from FAA management, labor, 

field facilities, finance, and subject matter experts. 

The repeatable and defensible process developed by the workgroup serves as a stable foundation 

for realignment analyses and recommendations that will be developed in the future. The process 

will be used to maximize operational, administrative, and maintenance efficiencies, support 

transition to NextGen, and deliver the highest value to stakeholders. 

Through continuous analysis and assessment of facilities through this process, the FAA supports 

its goal of ensuring safe and secure operations across the nation. 

15
The FAA’s success in conducting realignment analysis, continuing to develop realignment 

recommendations, and implementing those realignments is contingent upon stable multi-year 

funding, continued collaboration with labor unions, and coordination with industry stakeholders. 

Federal Register Publication

Following the process outlined in Section 804 of the FAA Modernization and Reform Act of 

2012, the FAA plans to submit the National Facilities Realignment and Consolidation Report, 

Part 2 to Congress and publish it in the Federal Register for public review and comment. This 

report will be available for review on the Federal Register docket and the FAA website. 

After the 45-day public comment period and the 60-day comment review period, the FAA plans 

to submit the final report to Congress, with collected public comments.

16