Aircraft construction isn't part of aviation...

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Jack Tyler
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Aircraft construction isn't part of aviation...

Postby Jack Tyler » Wed Sep 03, 2014 6:37 am

...or so the FAA would like to claim.

I know many here aren't actively involved in building an aircraft. Neither am I. But the FAA recently extended its deadline for public comment on their proposed rule to eliminate active aircraft construction from the hangars at airports receiving federal funds. And since all of us need to be concerned about the vitality and viability of our local airports, we really should be weighing in on the value of aircraft builders being a part of the organic functioning of an airport. So I'm suggesting you visit the Docket site and post a comment. If you con't want to wrap yourself up in the details, you might find the EAA's suggested change of term to be helpful. The FAA wants to limit hangar use to 'final assembly of aircraft' which means the empennage, fuselage, wings, etc. would all have to built elsewhere and then trucked to the airport grounds. The EAA's counter proposal is to change that term to "active assembly of aircraft." Especially given the vitality of the experimental portion of recreational aviation these days, I don't think we want to choke off that activity from the one place all pilots and aircraft owners congregate.

You can post your comment by going here:
http://www.regulations.gov/#!docketBrow ... 2BPR%252BO
and clicking on 'Comment Now'.

FWIW here's the comment I left...but it won't have any additional value by just being copied and pasted, so please contribute your own thoughts in your own language.

"Mr. Kevin Willis' summary statement, included in this Docket info pack, officially describes the boundaries of this rule which apply to use of airport hangars: "Summarily, an airport owner is obligated to use aeronautically designated land and facilities for aeronautical purposes. Hangars located on airport property designated for aeronautical use may only be used in direct support of an aeronautical purpose." So the fundamental issue to be addressed by this proposed rule is how we - the FAA and the general public on who's behalf it serves - define "aeronautical purposes".

Airports are organic entities, which is to say they are not solely land parcels with paved sections. They need a host of other activities, skill sets, supporting infrastructure, policies, management oversight, aircraft and pilots in order to serve their 'aeronautical purposes'. The FAA acknowledges, in its regulatory role and its public discourse, that airports in part should serve recreational purposes and educational purposes. It draws very wide lines around supporting activities like the operation of fuel sales, the management of the facilities and the training of pilots and servicing of aircraft. E.g. the FAA does not prohibit an airport manager from leasing hangar facilities for an aviation repair & maintenance business - no matter how long an aircraft is left partially disassembled in a back corner - nor for a flight school to operate in the hangar's office suite area. The FAA has consistently acknowledged that it takes a wide variety of services and activities to make an airport fully functional.

This is why one element in the proposed rule language limiting hangar use to 'final aircraft assembly' strikes those of us actively involved in aviation as so bizarre. Only in the vast cubicles of a remote bureaucracy, it seems, would it be deemed logical to disconnect the construction of aircraft - including the recreational benefits that are directly aviation related and the educational opportunities that directly contribute to the safe use of aircraft - from its relevance to aviation and the functioning of an airport. The FAA position - in a practical sense - means a student pilot can learn about the lift of an airfoil in a hangar-based office but shouldn't learn how that foil is constructed, or why & how its structural limits exist. This rule suggests it's okay to enjoy recreational flying but not the recreational avocation of building what we fly. This rule draws an artificial line where, out in the real world, it doesn't - and shouldn't - exist.

I support the goal of this rule, which is intended to definitively exclude non-aviation uses of hangars receiving federal funds. But along with EAA and AOPA, I also support amending the language to include "active assembly of aircraft." Airport owners can manage to that rule, and aviation as it exists at local airports would be the better for it.
Jack
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drseti
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Re: Aircraft construction isn't part of aviation...

Postby drseti » Wed Sep 03, 2014 7:20 am

Very good submission, Jack. Factual, on-topic, clear and concise.

My own comments (yet to be submitted) lament that, under the proposed language, unless the next Orville and Wilbur Wright happen to have a bicycle shop in which to build their machine, they will never get to revolutionize aviation.
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roger lee
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Re: Aircraft construction isn't part of aviation...

Postby roger lee » Wed Sep 03, 2014 10:11 am

Some airports are really taking this to heart. If you have a car, motor home, house storage or some other business in a hanger the airport may be charged with getting rid of it all. I believe their basic premise for this is to open more hangar space for aircraft since there is a lot of waiting list at airports. U

It looks a little like a shotgun approach, but I think it will pass and I'm sure city owned facilities will most likely abide by the new ruling.
Unfortunately they are including aircraft being built until a final stage assembly. They should allow building for all stages, but that isn't how it is written right now.

This is going to affect thousands of people.mostly negative, but for the ones waiting for hangar space it would be good.
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CTLSi
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Re: Aircraft construction isn't part of aviation...

Postby CTLSi » Wed Sep 03, 2014 10:18 am

......
Last edited by CTLSi on Mon Dec 01, 2014 10:52 am, edited 1 time in total.

Jack Tyler
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Re: Aircraft construction isn't part of aviation...

Postby Jack Tyler » Thu Sep 04, 2014 9:02 am

"This is going to affect thousands of people.mostly negative, but for the ones waiting for hangar space it would be good."

Depends on how one defines 'good'. Yes, it's obvious the FAA's new language helps insure hangars are used for "aeronautical purposes" and I'm first in line to support kicking out the RVs, boats, small business shops and such that prevent hangars serving those "aeronautical purposes". The question is whether retaining active aircraft construction, along with its educational and recreational benefits - to both builders and the rest of us - on airport grounds contributes to these purposes. Only a bureaucrat would claim the two are mutual exclusive and enjoy no beneficial relationship.

This kind of nonsense makes a grown man weep...
Jack
Flying in/out KBZN, Bozeman MT in a Grumman Tiger
Do you fly for recreational purposes? Please visit http://www.theraf.org

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MrMorden
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Re: Aircraft construction isn't part of aviation...

Postby MrMorden » Thu Sep 04, 2014 9:04 am

I heard of one FAA inspection of hangars where pilots were instructed to remove all TOOLS from the hangars because they are not related to aviation. :x
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Re: Aircraft construction isn't part of aviation...

Postby Merlinspop » Thu Sep 04, 2014 12:00 pm

MrMorden wrote:I heard of one FAA inspection of hangars where pilots were instructed to remove all TOOLS from the hangars because they are not related to aviation. :x

Well, at least the notice makes clear that the FAA is okay with hangars being used to store some stuff *in addition* to an aircraft.
- Bruce


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