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

  • Notice of Project Change from the Developers

  • Public Comment Excerpts

  • Decision Certificate from Secretary Tepper

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

Joint comment letter from the Hanscom Area State Representatives:

Click the image to the right or here to read the full letter

Signed by Representatives Simon Cataldo, Michelle Ciccolo, Carmine L. Gentile, Kenneth I. Gordon, and Alice H. Peisch

Decision Certificate from Secretary Tepper

Read the full certificate here