The Letter

Summary

On January 22, 2025, Sebago Technics sent a letter (The Letter) with attachments to Mr. Matt

Grooms and Mr. Zachary Powell, City of Portland. The Letter provides background on the

proposed Jetport parking-expansion project, and includes justification for the two waiver

requests. The Letter uses the Sustainable Airport Master Plan of 2018 (Master Plan) to

rationalize their proposal to clear acres of woods and wetlands in order to create new surface

parking. The Letter’s attachments present an analysis of PWM parking data. The Letter claims

that the data analysis justifies the need for more parking.

The Sebago Technics analysis of parking data is flawed. We use the same data (below) to

refute The Letter’s primary findings. Moreover, The Letter’s proposal violates

recommendations that are clearly laid out in the Master Plan. We elaborate on both points

below.

These are serious problems that deserve careful consideration. In fact, the Sebago Technics

analysis of parking counts raises more questions than it answers. We agree that there is a

parking problem at PWM. All you need to do is ask the occasional passenger circling the

Jetport at 4am looking for a spot. The data shows that there are many low-cost ways to

eliminate these artificial early-morning parking crises. Solutions for both short-term and long-

term problems can be found in the Master Plan.

The intended violation of the Master Plan, as detailed in The Letter, was first presented at a

public meeting in fall 2023. Some Portland residents have tried to discuss alternatives ever

since. And many of those residents were involved in creating the Master Plan. The City of

Portland owns the Jetport, and the planning process is supposed to involve Portland

taxpayers. However, the residents are crying foul because waivers just approved by the

Planning Board will allow the violations to proceed without review, effectively removing

taxpayers from the planning process.

Consistency with the Master PlanThe Letter begins by providing background on the Master Plan to justify its surface-parking

proposal. Quoting from The Letter:

The Jetports Sustainable Master Plan contemplates both surface parking and a future

parking garage expansion. As shown on the Ultimate Facilities Plan and Terminal Area

Plan (attached), the location of the proposed surface parking is depicted as surface

parking on the Terminal Area Plan. The plan also contemplates a future parking garage

expansion, being an extension of the current parking garage next to the terminal building.

Problem #1: To suggest that the Master Plan in any way recommends expansion of surface

parking would be a gross mischaracterization. Master Plan recommendations appear in

Chapter 1 – Introduction and Summary and Chapter 6 – Recommended Master Plan Concept,

where several maps clearly show expansion of the parking garage. More importantly, the text

and the maps in those chapters DO NOT include expansion of surface parking. The Letter has

misinterpreted their attachment (mentioned in the quote above), which is a map that they

extracted from Appendix K. More on that below.

The Master Plan recommends 2-phase expansion of the garage. Each phase is clear in the

many maps presented in the body of the text that show the recommendations. For example,

the image below comes directly from Exhibit B on page 13 of Chapter 1. The first phase in

garage expansion is the orange region labeled 10 in the figure below. The next phase is the

blue region labeled 23. The translucent orange region labeled 3 is a recommended “Land

Acquisition”, which includes 350 spaces from the Park N Jet (PNJ) facility, as well as

undeveloped woods and wetlands. The 350 PNJ spaces were not owned by the City at the

time that the Master Plan was created.

In contrast, The Letter proposes creation of 3 surface parking lots denoted Lot A, Lot B and

Lot C in The figure below, which comes from one of The Letter’s attachments. Lots B and Care located where the map (above) from the Master Plan shows only woods and wetlands.

And, while Lot C includes some of the 350 PNJ spots, it does not include all of them. We

revisit this remarkable omission below.

The next paragraph in The Letter reads:

It is important to view the parking Master Plan as a sequential process where the

proposed surface parking is the initial phase that addresses near term needs in an

economical manner and builds parking capacity that will accommodate the displacement

of surface parking at a future time when needs and economics support a parking garage

expansion adjacent the existing garage and terminal.

Problem #2: The Master Plan does NOT propose a sequential process where increased

surface parking is the initial phase. On the contrary, the Master Plan does not recommend any

increase in surface parking whatsoever. Recommendations appear in Chapters 1 and 6, and

those chapters mention only phased expansion of the garage. Increased surface parking is

mentioned once. It is contemplated in Chapter 5 – Airport Development Alternatives. Chapter

5 does NOT contain recommendations; and Chapter 5 is very careful to to make that clear.

Chapter 5 presents contingency planning and risk management, which is an important part of

any planning process. The only reference to increased surface parking in the entire text of the

Master Plan is in one part of one sentence in Chapter 5. The relevant quote from Chapter 5 is

on page 31 (page 348 of the 689-page PDF), which reads:

The parking garage will encumber existing surface lot spaces but will offer an increased

number of overall spaces. Its construction should provide adequate parking allowances

for the future; however, remote surface lots could be developed to the north along

International Parkway if the need presents.

Problem #3: Chapter 5 presents many alternatives to the Master Plan that might beconsidered if unforeseen need presents. The map from Appendix K (that The Letter includes

as an attachment) shows features described in Chapter 5, including the Chapter 5 reference to

expanded surface parking that is quoted above. The problem is that The Letter uses the map

from Appendix K and that sentence from Chapter 5 to justify their proposal for Lots A, B and

C. Since The Letter is actually referencing a contingency plan, the only rationale for even

considering expansion of surface lots would be existence of problems unforeseen during

creation of the Master Plan. In fact, The Letter contains an analyis of PWM parking counts to

claim that the Jetport routinely exceeds 85% parking capacity. The Letter used that analysis to

claim that the need exists. However, the analysis in The Letter is flawed and the findings are

incorrect. We show below that the Jetport nas never reached 85% capacity.

PNJ

The figure below shows the parking spots referred to as Park’N Jet (PNJ) in The Letter. The

City of Portland purchased PNJ from Mr. Thomas Toye for $4.2 million in 2019. PNJ capacity is

350 parking spots (2.65 acres) according to the Appraisal of Real Property dated 8 Mar 2019

and prepared by Cushman & Wakefield. The 350 PNJ spaces were not included in the Master

Plan, which was completed before the purchase.

Problem #4: Whereas Lots B and C would violate the Master Plan and destroy wetlands and

woods, Lot A presents an entirely different problem. Lot A overlaps with the PNJ. The problem

is that a large fraction of the 350-space PNJ lot is missing from the Sebago Technics analysis

of Jetport parking capacity and it is left out of their parking proposal. In other words, The

Letter proposes destruction of woods and wetlands INSTEAD of using existing parking

capacity! That makes no sense at all.Flawed analysis of parking data

The Letter describes analysis of car-count data provided by PWM for the period January 1 to

October 31, 2024. They used the data to create the figure in their “Attachment 2: PWM

Parking Daily Counts.” We have reproduced their figure below. They use the analysis to state

that the “public parking lots were above 85% full (103 days) of the count window or 34% of

the time.” As a result of this finding, The Letter goes on to state that “the Jetport does not

have a sufficient ratio of peak period to facility capacity and does not meet the 1.25 spaces

per 1,000 total passengers standard.”

Problem #5: The figure (above) from Attachment 2 is incorrect. It misrepresents PWM public-

parking capacity (the horizontal red and gold lines, which represent their claim of FULL and

85% FULL, respectively). We use the same data below to show that the Jetport has NEVER

reached 85% of full capacity.

Corrected parking analysis

Our corrected version of the Attachment in The Letter (i.e., the figure above) appears here:The blue lines in our figure and in the Letter’s attachment are identical. They are obtained

from the PWM car counts by adding all the data for long-term parking for ALL the lots listed in

the table below.

Problem #6: The Letter claims that the blue line exceeds 85% capacity of public parking lots

for 103 days of the count window, or 34% of the time. The problem is that they estimate

capacity for only 3 of the lots that they used to create their blue line, namely, Garage, Surface

(long term) and Pink. We agree that the total for those 3 lots is 2,784. However, the capacity

for all lots used to create the blue line is much larger. The Jetport data does not include

capacity for all lots. So we estimated total capacity to be 3,558. The table below shows the

detailed breakdown. As a result, in our figure, the Jetport never reaches 85% FULL.

The most glaring omission in Sebago Technics analysis comes from the missing 350 PNJ

spots. Those 350 spots may be missing from their analysis because PNJ sits empty most of

the year. It is brought into service only during peak periods such as spring break. We also note

that a large fraction of that PNJ capacity is excluded from Sebago Technics proposal. PNJ is

immediately adjacent to Lot C in their proposal, so the reason that they fail to include all of

PNJ in Lot C is a mystery.

Our figure includes two additional horizontal black lines for reference. The lower black line

(3,793 car counts) represents “Total All Parking” from Table 4K on page 49 of Chapter Four in

the Master Plan. The second horizontal black line in the figure adds the two additional lots that

the Jetport uses for public parking during peak periods: 350 spots from PNJ and 111 fromHutchins.

Lot(s) Capacity The

Letter

Source

Garage 2,033 2,033 Master Plan, p49, Chapter One (PDF 82)

Surface (long

term)

343 343 Master Plan, p49, Chapter One (PDF 82)

Pink Lot 459 459 Master Plan, p49, Chapter One (PDF 82)

Subtotal 2,784 2,784—

PNJ 350 0 City of Portland, Assessment

Cell Phone 96 0 Master Plan

Hutchins 111* 0 Estimate from PWM data, 111 = 95/0.85

(maximum occupied: 95)

Employee

Spaces**

217* 0 Estimate from PWM data, 217 = 184/0.85

(maximum occupied: 184)

Total Capacity 3,558 2,784

FULL = Total Capacity for managed long-

term public parking

85% of Total 3,024 2,366 85% FULL = 85% of Total Capacity

• *Capacity for Hutchins and Employee Spaces estimated from maximum occupied for

long-term parking divided by 0.85.

• **Employee Spaces maximum used: 184 (that’s 85% of: 217). This estimate of long-term

capacity for the employee lot (217) is less than half of the 480 total for that lot.

• Maximum Occupied in PWM data (1 Jan through 31 Oct 2024): 2,947 (occurred on 19 Oct

2024)

• 3,467 = capacity associated with 85% occupied = 2,947

• Garage + Surface + Pink + PNJ + Cell Phone = 3,230 (that’s 237 short of 3,467)

• On 19 Oct 2024, only 8 PNJ spots were occupied.

References

• Sustainable Airport Master Plan

◦ https://portlandjetport.org/sustainable-airport-master-plan◦ The Master Plan was downloaded from the Jetport website as a 689-page PDF.

• Plan Number: PL-002853-2024 – Major Site Plan Development, Approved by Board with

Conditions

◦ 3 of the 81 attachments were used for this analysis

◦ “Correspondence APP 2025-01-08.pdf” – Sebago Technics letter to City of Portland

◦ “PWM Daily Counts (01-01-24 to 10-31-24).pdf” – Sebago Technics figure

(reproduced above)

◦ “Parking Exhibits 2025-01-08.pdf” * Attachment 6: Proposed Parking Lot Exhibit

▪ Lot A == Cell + a fraction of the “gravel valet” (PNJ)

▪ The combined capacity of lot A is 402 (Sebago Technics letter)

◦ To download these 3 files click the following link:

▪ https://selfservice.portlandmaine.gov/EnerGov_Prod/SelfService#/plan/c8e4fe67-

beac-499c-883b-9586a47dc704

▪ Then click the “Attachments” tab

▪ The files of interest are near the bottom of the list of 81 attachments

• 350 PNJ spots – Appraisal of Real Property, 8 Mar 2019, prepared by Cushman &

Wakefield

◦ This document shows the 350 PNJ spots purchased by City of Portland

◦ Approximately half of these spots are left out of the Sebago Technics proposal

◦ This reference is available at the following link:

◦ https://portlandme.portal.civicclerk.com/event/1912/files/attachment/11486

• “PWM Counts Jan 2023 - May 2024.xlsx”

◦ Paul Bradbury provided this excel file in a email to Woody Howard on Sunday,

November 24, 2024.

◦ We used this data to create our corrected version (above) of the Sebago Technics

figure (also above).

◦ We would gladly make this da