In The State of the U.S. Heliport Record, the report we produced with Rex Alexander, FRAeS, of Five-Alpha, we published a number that kept coming back in conversations: more than 1,100 hospital helipads operate in this country with no FAA registration on file. We found them by cross referencing the federal hospital infrastructure dataset against the FAA's facility registry. A pad shows up in one record and not the other.
That method left an open question, and fair skeptics asked it. Maybe the FAA just never heard about these pads. Hospitals build a concrete square on a roof or a slab behind the emergency department, the helicopters come, and no paperwork ever reaches Washington. If that were the whole story, the registry gap would be an awareness problem, and the fix would be outreach.
It is not the whole story. We can now show that for hundreds of these pads, the FAA itself processed their paperwork.
What we did
When a hospital wants to establish a helipad, federal process asks for a notice before construction. The FAA studies the airspace around the proposed landing area, checks it against approach surfaces and nearby procedures, and issues a determination. Those cases live in the FAA's obstruction evaluation system, which the agency recently rebuilt and which publishes its case history as regional archives.
We ingested all of it. 285 regional archive files covering every FAA region, 483,006 aeronautical study records reaching back decades. From those we extracted every landing area case: heliport studies, notices of landing area proposal, and the FAA's new advanced air mobility case class. That gave us 12,054 landing area cases nationwide.
Then we matched them. Each case carries precise coordinates, so we joined them against the 5,647 registered heliports in the FAA's facility registry, and against the federal hospital dataset. About 5,000 cases matched registered facilities, which quietly solved a different problem: 61 percent of registered U.S. heliports now carry their airspace determination history in our record, up from 6.5 percent this morning.
The interesting residue is the cases that matched nothing.
What we found
4,373 distinct sites have a determined FAA landing area case and no registered facility at that location. Many of these are explainable. Some proposals were never built. Some sit inside airport boundaries. We set all of those aside and kept only the strictest class: sites where the case coordinates land at a hospital, where the hospital infrastructure dataset independently says a helipad exists, and where the FAA registry shows nothing within two nautical miles.
284 hospital helipads meet all three tests.
Read that carefully, because each leg comes from a different federal or public source. The Department of Homeland Security's infrastructure dataset says the helipad physically exists. The FAA's own case archive says the agency studied the airspace at that exact spot and issued a determination, with match distances typically inside a few hundred feet. And the FAA's facility registry has no record of it.
The paperwork is not new, either. 88 of these determinations were issued in 2010 or earlier. Those gaps have persisted through fifteen years or more of registry publication cycles. Another 149 date from the 2010s. And 47 are from this decade, which means the reconciliation failure is still being produced today, not just inherited from the past.
The pattern concentrates where hospital aviation concentrates. Texas leads with 34 of these facilities, followed by Arizona with 20, California with 16, Tennessee with 14, and Ohio with 13.
The names are ordinary and checkable. Sentara Northern Virginia Medical Center in Woodbridge, Virginia has a determined landing area case from this year, 360 feet from the hospital, and no registered facility. Baptist Health in North Little Rock, Arkansas matches within 60 feet. Citizens Medical Center in Colby, Kansas. Prisma Health Tuomey in Sumter, South Carolina. These are working hospitals with working helipads and federal airspace paperwork, invisible to the registry that pilots, planners, and increasingly software rely on.
The pads arriving right now
The same archive gave us something we did not expect: a forward view. 29 of the unmatched hospital sites carry determinations from 2024 or later, several from this year, with proposal text that reads simply: establish hospital heliport. These pads are being built right now. They appear in no registry yet. The case files are the earliest public evidence they will exist.
That changes what a landing record can be. A registry tells you what was. Case files tell you what is coming.
What the FAA's own letters say
The case archive records that a study happened. It does not, on its own, tell you what the FAA concluded. So we went one level deeper and pulled the determination letters themselves, the signed documents the agency issues when a study closes. For 113 of these 284 facilities the letter is still retrievable; the rest predate the FAA's electronic letter system. The letters do not hedge.
The letter for Prisma Health Tuomey in Sumter, South Carolina, dated this past February, is headed "Notice of Heliport Airspace Analysis Determination, Establish Private Use Heliport, No Objection." The FAA conducted an on site evaluation, recommended the heliport meet the touchdown, approach, and safety area standards of its own Advisory Circular, and determined the site would not adversely affect the airspace. A complete, closed, favorable federal airspace determination for a hospital helipad the federal registry does not list.
An older letter is blunter still. In a 2009 final determination for a medical center in Elk City, Oklahoma, the FAA's own description of the case reads: "Existing medical center heliport was never airspaced." The agency acknowledged, in writing, a hospital heliport already in operation without an airspace study, and then completed one. Seventeen years later that facility is still absent from the registry.
This is the part that should be hard to wave away. The gap is not a matter of interpretation, or of one dataset disagreeing with another. It is documented in the FAA's own determination letters, in the FAA's own words.
Why this matters
For the helicopter era, this gap was survivable, because a pilot looks out the window. The next era of vertical flight does not work that way. Automated and semi automated aircraft plan against data. An emergency landing system that reads the federal registry sees nothing at 284 hospitals where a usable pad exists. An insurer pricing a hospital's aviation exposure may not learn the pad exists at all. A state EMS planner counting landing infrastructure undercounts it.
And the fix is not awareness. The FAA already has the paperwork. What the system lacks is reconciliation: the case file on one side of the agency never became a registration on the other. That is precisely the kind of work an independent record exists to do. We read both sides, match them, and publish the difference with every claim traceable to its source.
Method and limits
This analysis holds to the same standard as the original report: everything above reproduces from public files. The case archives are public downloads from the FAA's obstruction evaluation system. The hospital dataset is public. The facility registry is public. Our matching used case coordinates, a quarter nautical mile clustering radius for repeat cases at one site, half a nautical mile to associate a case with a hospital, and a two nautical mile exclusion radius to confirm no registered facility nearby. Match distances for the named examples are stated in the text.
Two honest limits. First, a determination alone does not prove construction, which is why the headline class requires the hospital dataset to independently attest the helipad exists; where only the paperwork existed, we counted the site but made no claim about it. Second, the determination outcomes quoted above come from the per-case letters, which are retrievable for 113 of the 284. For the remainder, which predate the agency's electronic letter system, we rely on the case record's determined status without characterizing the specific letter, and the bulk archive does not carry the outcome on its own.
The full facility lists behind this analysis, including the state level breakdowns, are available to institutional readers. If you are responsible for a hospital system, an insurance book, or a state EMS network and want to know which of these facilities are yours, ask us.