with whom LEVY and JABAR, JJ., join, dissenting.
[¶ 17] Today, the Court further narrows the applicability of the MTCA by ignoring the plain meaning of the word “use” and substituting its own meaning of a commonly used word. The Court equates “use” with “ownership” and “maintenance.” Unfortunately, this interpretation will have far-reaching consequences.
[¶ 18] Under the majority’s construction, in order to “use” an aircraft under the MTCA, the governmental entity must control how the aircraft is maintained or operated. This means either that “use” is synonymous with ownership and maintenance, or that “use” means “operation.” Either interpretation contradicts the plain *90language of the Act and may be read as extending the cloak of immunity to virtually every instance in which the government contracts with third-parties to provide transportation services.
[¶ 19] Title 14, section 8104-A provides:
§ 8104-A. Exceptions to immunity
Except as specified in section 8104-B, a governmental entity is liable for property damage, bodily injury or death in the following instances.
1. Ownership; maintenance or use of vehicles, machinery and equipment. A governmental entity is liable for its negligent acts or omissions in its ownership, maintenance or use of any:
A. Motor vehicle, as defined in Title 29-A, section 101, subsection 42;
B. Special mobile equipment, as defined in Title 29-A, section 101, subsection 70;
C. Trailers, as defined in Title 29-A, section 101, subsection 86;
D. Aircraft, as defined in Title 6, section 3, subsection 5;
E. Watercraft, as defined in Title 12, section 1872, subsection 14;
F. Snowmobiles, as defined in Title 12, section 13001, subsection 25; and
G. Other machinery or equipment, whether mobile or stationary.
The provisions of this section do not apply to the sales of motor vehicles and equipment at auction by a governmental entity.
14 M.R.S. § 8104-A (2009).
[¶ 20] “Use” must have an independent meaning from “ownership” or “maintenance,” or it would be mere surplusage. See Linnehan Leasing v. State Tax Assessor, 2006 ME 33, ¶ 21, 898 A.2d 408, 413 (applying “our rule of construction that we will not treat any provision of a statute as surplusage when a reasonable construction of a statute can provide meaning to each provision”). In determining the definition of the word “use” in the statute, we look to its plain meaning. See Me. Sch. Admin. Dist. No. 37 v. Pineo, 2010 ME 11, ¶ 16, 988 A.2d 987, 993. “A use is the application or employment of something for some purpose.” Uliano v. Bd. of Envtl. Prot., 2009 ME 89, ¶ 18, 977 A.2d 400, 409 (interpreting the Natural Resources Protection Act) (quotation marks omitted). “Use” does not mean “operate,” but rather has a broader definition, and this Court has noted that the choice of the word “using,” as opposed to “operating,” in a contract “reflects a recognition that one may use a motor vehicle without operating it.” Craig v. Estate of Barnes, 1998 ME 110, ¶ 11, 710 A.2d 258, 261; see also Allstate Ins. Co. v. Lyons, 400 A.2d 349, 352 (Me.1979) (noting, in the context of an insurance contract, the “choice of the word ‘use’ as distinguished from the word ‘operation,’” and agreeing that “the words use and operation are not synonymous.... Use is ... broader than operation”) (quotation marks omitted); id. at 353 (discussing the “dispositive nature of [the] choice of terms”).
[¶ 21] The United States Supreme Court as well has held the word “use” to mean “active employment,” and in the context of a firearm found that to include not only operation as a weapon, but the broader activities of brandishing and bartering with the firearm. See Bailey v. United States, 516 U.S. 137, 143, 146, 116 S.Ct. 501, 133 L.Ed.2d 472 (1995), superseded by statute, Act to Throttle Criminal Use of Guns, Pub.L. No. 105-386, § 1(a), 112 Stat. 3469 (1998) (codified at 18 U.S.C.S. § 924(c)(1) (LexisNexis 2005)). This definition is consistent with the common meaning of the word described in both legal and non-legal dictionaries. See Black’s Law *91Dictionary 1681 (9th ed. 2009) (defining “use” as “[t]he application or employment of something”); American Heritage Dictionary 1331 (2d ed. 1985) (defining “use” as “[t]o bring or put into service; employ”).
[¶ 22] If the Legislature had intended “use” to mean something narrower than the common definition, it would have used the word “operation,” as it did in the Maine Aeronautics Act, referencing the “operation of aircraft.” See 6 M.R.S. § 3(24) (2009). The majority discusses this statute but misses the point that it shows that the Legislature knows how to use the word “operation” as opposed to the word “use” when a different meaning is intended. Therefore, the Legislature’s choice of the word “use” in the MTCA encompasses activities beyond those where a government employee is actually operating the aircraft. Here, in the words of the majority, the City conducted its AFJROTC orientation program “using an FAA-certified aircraft.” This is a “use” of an aircraft as provided for in the statute.
[¶ 23] The majority raises the example of a city purchásing seats on a commercial airliner to suggest the possible expansive result of interpreting “use” according to its plain meaning. This example is misleading for two reasons. First, the MTCA requires not only use of the aircraft, but also negligence by the City in that use, in order to impose liability. See 14 M.R.S. § 8104-A(1) (“A governmental entity is liable for its negligent acts or omissions in its ... use ....”) (emphasis added). Therefore it is extremely unlikely that a governmental entity would be liable for an accident involving a commercial airliner because, in most contexts, allowing students to board a commercial flight would not be a negligent act. Here, in contrast, the City chartered the aircraft, potentially had information that such use would be dangerous, and allowed the students to board the plane anyway. This potentially negligent use subjects the City to a claim under the MTCA.9
[¶ 24] Second, this Court is tasked with interpreting the statute as written, not with finding a meaning that will avoid an increase in liability. We have always followed the plain meaning of statutes, see, e.g., Pineo, 2010 ME 11, ¶ 16, 988 A.2d at 993, and the majority’s interpretation departs from this cardinal rule of statutory interpretation.
[¶ 25] It is common for local governments to contract with independent operators to provide transportation services as well as to perform activities such as garbage collection or street maintenance. Government employees may nonetheless be directly involved in the use of the vehicle associated with those services, and those employees should not be exempted from liability for their negligence. For example, a local official who has reason to believe that a school bus driver employed by a private operator is intoxicated should be expected to take steps to prevent the students from boarding the bus. Under the majority’s approach, the local official’s negligence would be deemed not to fall within the MTCA’s unambiguous exception to immunity for a government’s “negligent acts or omissions in its ... use of any ... [m]otor vehicle.” 14 M.R.S. § 8104-A(1)(A). The majority’s construction of the MTCA, by extending governmental immunity to situations where a governmental *92unit “leases out” its functions, renders the law outmoded and unresponsive to the frequency with which governments contract for transportation services in today’s economy. This could not be intended by our Legislature.
[¶ 26] In this case, the City was using the aircraft when the accident occurred, and it was within the context of that use that Colonel Meyer is alleged to have acted negligently. For these reasons, I would hold that there is no governmental immunity for the City of Lewiston.
. This result is consistent with our focus "on the risk of harm naturally or directly caused by the vehicle’s contact with the general public.” See Thompson v. Dep't of Inland Fisheries & Wildlife, 2002 ME 78, ¶ 8, 796 A.2d 674, 677. Here, the City's negligent use resulted in deaths from a crash, which is a harm that ”flow[s] naturally” from the negligent use of an aircraft. See id. ¶ 7, 796 A.2d at 676-77.