Florida International Rally and Motorsport Park (FIRM) sued the Keystone Heights Airport Authority in late June and claimed breaches of Sunshine Law, retaliation in violation of the First Amendment, breaking lease agreements and other charges.  

The potential of legal action had been brewing since early 2024 when the Federal Aviation Administration (FAA) notified Keystone Heights Airport of federal code breaches. The breaches dealt with FIRM and its raceway, which operates on over 300 acres of leased airport property. 

The Keystone Heights Airport Authority (KHAA) manages the airport for the city, with members of the authority appointed by the City Council. FIRM has operated on the property since 2012 when it took over a contract with European Rally & Performance Driving School that began in 1999. The business sees between 10,000 and 12,000 visitors each year. 

In the lawsuit, FIRM asks a Bradford County judge to issue an emergency injunction to prevent KHAA from evicting the company or taking actions that would cause irreparable harm, like demolishing or removing assets at the racetrack.  

Airport manager Craig Coon warned about a lawsuit in a March 2025 email to the FAA. In the email, Coon proposed a temporary solution to avoid legal action and keep FIRM bringing in crucial revenue.

“However, one of my biggest concerns with the relationship between the airport and the tenant is not only the souring attitudes, but the real threat of legal action between the two parties,” Coon said.

The lawsuit stems from the three discovered conflicts with FAA codes.  

First, a portion of the racetrack overlaps with a designated Runway Protection Zone. According to the lawsuit, the KHAA knew about the conflict back in 2014 but never told the FIRM. The violation of FAA codes puts the company at risk and should have been disclosed when FIRM entered the contract to lease the land, the company said.

Second, the lawsuit said the 300-acre property is also zoned incorrectly. The property should be zoned for non-aeronautical use to abide by FAA regulations. 

“In reliance on the [KHAA’s] representations and omissions, FIRM invested millions of dollars in infrastructure, marketing, and development,” the lawsuit said. “Had FIRM been made aware of these issues, it would not have entered into the Lease under the same terms. As a direct result, FIRM has suffered substantial financial harm, regulatory exposure, and operational disruption.” 

Lastly, the FAA requires fair market value for all leasing on airport property, but the contract with FIRM falls below that threshold. The FAA said fair market value is “significantly higher” than the current contract.

The 1999 contract that FIRM took over imposed a $18,000 annual payment with a 1.5% annual increase after the first two years, placing the rent at around $25,000 for the last year assuming no contract changes. FIRM decided in 2024 to move forward with a 15-year extension on its contract. Another 10-year extension is also available.

The FAA sent the violation notice in February 2024, but FIRM claims the airport authority already knew about the breaches with federal codes, citing a 2014 email from the airport engineer. According to FIRM’s lawsuit, the KHAA tried to undermine the lease agreement after the notice of violation.  

But the airport authority and FIRM have a way to reach compliance with the FAA.  

According to exhibit emails in the lawsuit, Coon and the FAA reached an agreement on a corrective action plan. Through the plan, the Runway Protection Zone would be reduced to a smaller area, allowing FIRM to operate while working to reconfigure the racetrack. The reconfigured racetrack would need to stay completely outside the original protection zone.  

However, neither side wants to pay for the reconfiguration.  

In an April 2025 letter, a FIRM attorney said the company would amend its contract to start paying fair market value if the airport authority covered the cost of reconfiguring the racetrack. According to FIRM, the airport authority is at fault for failing to disclose the breach with FAA codes more than a decade ago. 

“. . .both parties would avoid the costs and disruption of protracted litigation. This approach serves the best interests of all stakeholders involved,” FIRM attorney Joel Piza-Batiz wrote to Coon.  

That deal never happened. James Eifert, KHAA chairman, updated the Keystone Heights City Council on June 23.  

He said the airport authority had rejected a letter from FIRM asking the airport to cover the reconstruction costs. This happened at the June 10 airport authority meeting. At the same meeting, another motion passed that gave FIRM until June 25, the original FAA deadline, to remove obstacles and impediments within the Runway Protection Zone. 

If the raceway failed to remove the obstacles, Eifert said the airport authority would consider terminating the contract with FIRM.   

But Eifert told the City Council that FIRM sued 10 days later. If a judge grants the emergency injunction, the airport authority may be prevented from removing the obstructions or canceling the contract.  

Eifert added that the FAA had been dissatisfied that no efforts were underway to bring the area into compliance. He said the FAA also told the airport authority that it planned to retroactively ask FIRM for fair market value on the contract for the past six and a half years.  

Eifert said how that payment is imposed remains an open question. He also said the FIRM lawsuit was full of inaccuracies.

In its lawsuit, FIRM also commented on the June 10 KHAA meeting.

“Despite FAA’s willingness to temporarily approve continued use of the track and evaluate progress in good faith, KAA has persisted in its threats to demolish the track and terminate FIRM’s Lease,” the lawsuit said. “This includes KAA’s stated intention during its June 10, 2025, meeting to unilaterally demand track removal by June 25, 2025, even though no final FAA determination has been issued and despite the pending corrective plan now under FAA review.”

According to FIRM, members of the KHAA have been working to undermine and terminate the contract.

Keystone Heights Airport had no comment when contacted, saying it was working with legal counsel on the matter.  

Included with the charges listed above, FIRM also sued for interference with peaceful enjoyment, breach of good faith and fair dealing and violation of the public’s right to be heard. 

“The [KHAA] has deliberately and unfairly interfered with FIRM’s operations by issuing arbitrary directives, obstructing communications, and engaging in retaliatory conduct against FIRM,” the lawsuit said.

Even though Keystone Heights is a city in Clay County, FIRM is located in Bradford County, with the airport sitting right on the boundary separating the two counties. The airport authority has yet to file a legal response.