Notice of Project Change
Runway Realty Ventures has submitted a Notice of Project Change to separate the Navy Hangar renovation from the larger North Airfield private jet expansion project.
This appears to be an attempt to fast-track approval while avoiding comprehensive environmental review.
Below you’ll find:
Project Overview: Merlin Labs
Public Comment Excerpts
Decision Certificate from Secretary Tepper
Key Documents
Project Overview: Merlin Labs
The developers are now seeking to renovate the historic Navy Hangar for "Research & Development" uses, with a prospective tenant being Merlin Labs, an autonomous aircraft testing company.
What Has Changed
In June 2025, the developers submitted a Notice of Project Change (NPC) requesting to separate the Navy Hangar renovation from the larger 17-hangar private jet expansion project. Key changes include:
New Use: Converting from corporate aviation support to R&D and autonomous aircraft testing
Building Changes: 58,000 sq ft of R&D space, 36,400 sq ft of hangar space, and 140 parking spaces
Flight Operations: 2-6 flight operations per day on average for aircraft testing
Timeline: Seeking to begin construction in Fall 2025
The Real Story Behind This Change
According to the Boston Globe's April 30, 2025 reporting, this change appears to be a strategic move by the developers. The prospective tenant, Merlin Labs, is an AI startup developing autonomous aviation software that currently operates out of California but is considering multiple locations including Rhode Island, New Hampshire, and New York.
"This expansion fits right in with our innovation-based economy and our efforts to bring new businesses to our state."
- Governor Healey spokesperson, as quoted in the Boston Globe
Key Concerns About This Approach
Environmental Review Avoidance By separating this project, developers may be trying to avoid the comprehensive environmental review required for the full 17-hangar expansion.
Setting Precedent Approving this project could establish infrastructure that makes the larger private jet expansion more likely to be approved in the future.
Still Involves Private Aviation Despite the R&D focus, the project still includes aircraft operations and maintains aviation infrastructure that could support private jets.
Experimental Aircraft Concerns Testing autonomous aircraft over densely populated areas requires special FAA waivers and poses unique safety considerations.
Notice of Project Change from The Developers
On June 2, 2025, the developers submitted a Notice of Project Change with a Phase One Waiver request, claiming "undue hardship" if they cannot proceed immediately. They argue that Merlin Labs will choose another state if the project is delayed.
However, this raises serious questions: Should public environmental protections be bypassed to accommodate private business timelines?
What They're Not Telling You
The project still involves aircraft operations that will contribute to emissions and noise
It establishes aviation infrastructure that could support the larger private jet expansion
The "R&D" designation could be a way to make private aviation infrastructure more palatable to regulators
Autonomous aircraft testing involves unique risks not fully addressed in their analysis
Public Comment Excerpts
The public comment period for this Notice of Project Change has generated significant concern from environmental groups, local residents, and climate advocates. Here are key themes from the comments:
Environmental Justice Concerns
"This piecemeal approach to development review undermines the comprehensive environmental analysis that communities deserve, especially when aviation projects have disproportionate climate impacts."
Climate Impact Worries
Commenters have noted that even though this project is smaller than the full expansion, it still:
Adds aircraft operations and associated emissions
Creates infrastructure that enables future aviation expansion
Sets a precedent for approving aviation projects during a climate emergency
Process Concerns
"Allowing developers to split projects to avoid environmental review defeats the purpose of having these protections in the first place. The cumulative impact of all proposed development should be evaluated together."
Safety Questions
Several comments raised concerns about testing autonomous aircraft over populated areas, noting that:
The FAA has identified Hanscom as a "hot spot" for pilot confusion due to complex runway layouts
Experimental aircraft operations require special waivers for flights over populated areas
Other testing locations like Quonset Airport in Rhode Island offer over-water flight paths that are safer
Decision Certificate from Secretary Tepper
Expected this week!