Aircraft construction isn't part of aviation...
Posted: 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.
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.