FAA says hangars no place for homebuilders

Submitted by Anonymous on

Forums: 

From: <Sky2high [at] aol.com>
Subject: FAA says hangars no place for homebuilders
Date: Sun, 3 Aug 2014 12:29:31 -0400 (EDT)
To: <lml [at] lancaironline.net>
Cc: <marv [at] lancair.net>

FAA
Says Hangars No Place For Homebuilders

The FAA says most of the work involved in building an airplane is
a "non-aeronautical use" and it has singled out homebuilders in a new
proposed policy statement issued July 22. Policy on the Non-Aeronautical Use Of Airport Hangars
(https://www.federalregister.gov/articles/2014/07/22/2014-17031/policy-on-the-non-aeronautical-use-of-airport-hangars#h-13)
says homebuilders will have to build the components of their projects
elsewhere and can only move to a hangar for final assembly. Comments are
being accepted until Sept. 5 and can be submitted
online (http://www.regulations.gov/#!home)
citing docket number FAA-2014-0463. The agency has devoted a
separate section in the proposed policy to explaining its stand. The
essence is that the principal role of a hangar is to supply enclosed
storage for aircraft to give ready access to the runway. The FAA's
argument is that bucking rivets on a wing doesn't require a runway so it's
not an aeronautical use. It also says the policy has always been in force.
"The FAA is not proposing any change to existing policy other than to
clarify that final assembly of an aircraft, leading to the completion of
the aircraft to a point where it can be taxied, will be considered an
aeronautical use," the proposed policy says. EAA is aware of the proposed
policy and staff are assessing it.

The new policy statement is the result of stepped-up enforcement of the
rules regarding uses of airport hangars. In dozens of audits conducted
over the past two years, the agency has found hangars crammed with just
about everything but airplanes. Household goods, cars, even non-aviation
related businesses have been discovered. The FAA says that because federal
funds are used to build and maintain airports, the use of airport
facilities for non-aeronautical uses amounts to a subsidy for those uses.
In some cases the city or county responsible for the airport was the
violator. Auditors found police cars and other municipal assets tucked
safely away in airport hangars.  The proposed policy will also
clarify the incidental storage of non-aeronautical items in hangars,
meaning that a couch and a beer fridge will probably be safe from the
feds.
 
==========
 
With respect to experimental aircraft building, this is stupid on the face
of it.  The FAA is supposedly concerned about aviation safety yet,
they will force builders to work in their mushroom cellar without any
immediately available advice of other builders, pilots or aircraft shops located
at their airport.  The FAA apparently no longer has objectives of
promoting GA or safety.
 
Scott Krueger 
 
PS Please consider making comments to FAA as outlined above.  Do not
mention your own airport because the data might be used by FA enforcement.
 
PPS Uh, Final Assembly starts when first part is
built/assembled.

FAA says hangars no place for homebuilders

Submitted by Anonymous on

From: Steve Richard <steve [at] oasissolutions.com>
Sender: <marv [at] lancaironline.net>
Subject: RE: [LML] FAA says hangars no place for homebuilders
Date: Sun, 03 Aug 2014 19:24:42 -0400
To: <lml [at] lancaironline.net>
Message Header


Undecoded Message

I just posted this on the site (hopefully in the correct location):

 

So the FAA would rather have the initial construction process done without the benefit of experienced builders and fliers who are always on the airport?  That
is counter to safety.  I am somewhat stunned this proposed requirement has seen the light of day, considering that the FAA is constantly trying to find ways to make experimental airplanes safer.  I believe the proposal should be changed to encourage builders
to start and end their projects at the airport.  It should acknowledge that airports are the geographic center of most safety activities.  Airports are where hundreds of years of expertise in the form of A&P's, IA's and serial kit builders can be accessed
almost instantaneously.  Would it not be better for a new builder to be near all this expertise rather than in their garage at home without any on site immediate counsel?

 

The FAA knows how important airports are as evidence by the money that flows to their capital improvement programs.  Do they not see that airport quality and
longevity will not work with money alone?  And the greatest supporters of airports are people who just invested thousands of dollars in a kit.

 

Steve Richard

 

From: Lancair Mailing List [lml [at] lancaironline.net]">mailto:lml [at] lancaironline.net]
On Behalf Of Sky2high [at] aol.com

Sent: Sunday, August 03, 2014 9:30 AM

To: Lancair Mailing List

Subject: [LML] FAA says hangars no place for homebuilders

 

FAA
Says Hangars No Place For Homebuilders

The FAA says most of the work involved in building an airplane is a "non-aeronautical use" and it has singled out homebuilders in a new proposed policy statement issued July 22.

Policy on the Non-Aeronautical Use Of Airport Hangars (https://www.federalregister.gov/articles/2014/07/22/2014-17031/policy-on-the-non-aeronautical-use-of-airport-hangars#h-13)
says homebuilders will have to build the components of their projects elsewhere and can only move to a hangar for final assembly. Comments are being accepted until Sept. 5 and can be

submitted online (http://www.regulations.gov/#!home) citing docket number FAA-2014-0463. The agency has devoted a separate section in the proposed policy to explaining
its stand. The essence is that the principal role of a hangar is to supply enclosed storage for aircraft to give ready access to the runway. The FAA's argument is that bucking rivets on a wing doesn't require a runway so it's not an aeronautical use. It also
says the policy has always been in force. "The FAA is not proposing any change to existing policy other than to clarify that final assembly of an aircraft, leading to the completion of the aircraft to a point where it can be taxied, will be considered an aeronautical
use," the proposed policy says. EAA is aware of the proposed policy and staff are assessing it.

The new policy statement is the result of stepped-up enforcement of the rules regarding uses of airport hangars. In dozens of audits conducted over the past two years, the agency
has found hangars crammed with just about everything but airplanes. Household goods, cars, even non-aviation related businesses have been discovered. The FAA says that because federal funds are used to build and maintain airports, the use of airport facilities
for non-aeronautical uses amounts to a subsidy for those uses. In some cases the city or county responsible for the airport was the violator. Auditors found police cars and other municipal assets tucked safely away in airport hangars.  The proposed policy
will also clarify the incidental storage of non-aeronautical items in hangars, meaning that a couch and a beer fridge will probably be safe from the feds.

 

==========

 

With respect to experimental aircraft building, this is stupid on the face of it.  The FAA is supposedly concerned about aviation safety yet, they will force builders
to work in their mushroom cellar without any immediately available advice of other builders, pilots or aircraft shops located at their airport.  The FAA apparently no longer has objectives of promoting GA or safety.

 

Scott Krueger 

 

PS Please consider making comments to FAA as outlined above.  Do not mention your own airport because the data might be used by FA enforcement.

 

PPS Uh, Final Assembly starts when first part is built/assembled.

FAA says hangars no place for homebuilders

Submitted by Anonymous on

From: Dominic V. Crain <domcrain [at] tpg.com.au>
Sender: <marv [at] lancaironline.net>
Subject: Re: [LML] Re: FAA says hangars no place for homebuilders
Date: Mon, 04 Aug 2014 07:19:18 -0400
To: <lml [at] lancaironline.net>
Message Header


Undecoded Message

Un-bloody-believable!



Dominic V. Crain
domcrain [at] tpg.com.au

Phone 03-94161881
Mobile 0412-359320



On 4 Aug 2014, at 9:24, Steve Richard <steve [at] oasissolutions.com

> wrote:



I just posted this on the site (hopefully in the correct location):

 
So the FAA would rather have the initial construction process done without the benefit of experienced builders and fliers who are always on the airport?  That is counter to safety.  I am somewhat stunned this proposed requirement has seen the light of day, considering that the FAA is constantly trying to find ways to make experimental airplanes safer.  I believe the proposal should be changed to encourage builders to start and end their projects at the airport.  It should acknowledge that airports are the geographic center of most safety activities.  Airports are where hundreds of years of expertise in the form of A&P's, IA's and serial kit builders can be accessed almost instantaneously.  Would it not be better for a new builder to be near all this expertise rather than in their garage at home without any on site immediate counsel?

 
The FAA knows how important airports are as evidence by the money that flows to their capital improvement programs.  Do they not see that airport quality and longevity will not work with money alone?  And the greatest supporters of airports are people who just invested thousands of dollars in a kit.

 
Steve Richard

 
From: Lancair Mailing List [lml [at] lancaironline.net (mailto:)

] On Behalf Of Sky2high [at] aol.com


Sent: Sunday, August 03, 2014 9:30 AM
To: Lancair Mailing List
Subject: [LML] FAA says hangars no place for homebuilders

 

The FAA says most of the work involved in building an airplane is a "non-aeronautical use" and it has singled out homebuilders in a new proposed policy statement issued July 22. Policy on the Non-Aeronautical Use Of Airport Hangars (https://www.federalregister.gov/articles/2014/07/22/2014-17031/policy-on-the-non-aeronautical-use-of-airport-hangars#h-13) says homebuilders will have to build the components of their projects elsewhere and can only move to a hangar for final assembly. Comments are being accepted until Sept. 5 and can be submitted online (http://www.regulations.gov/#!home) citing docket number FAA-2014-0463. The agency has devoted a separate section in the proposed policy to explaining its stand. The essence is that the principal role of a hangar is to supply enclosed storage for aircraft to give ready access to the runway. The FAA's argument is that bucking rivets on a wing doesn't require a runway so it's not an aeronautical use. It also says the policy has always been in force. "The FAA is not proposing any change to existing policy other than to clarify that final assembly of an aircraft, leading to the completion of the aircraft to a point where it can be taxied, will be considered an aeronautical use," the proposed policy says. EAA is aware of the proposed policy and staff are assessing it.

The new policy statement is the result of stepped-up enforcement of the rules regarding uses of airport hangars. In dozens of audits conducted over the past two years, the agency has found hangars crammed with just about everything but airplanes. Household goods, cars, even non-aviation related businesses have been discovered. The FAA says that because federal funds are used to build and maintain airports, the use of airport facilities for non-aeronautical uses amounts to a subsidy for those uses. In some cases the city or county responsible for the airport was the violator. Auditors found police cars and other municipal assets tucked safely away in airport hangars.  The proposed policy will also clarify the incidental storage of non-aeronautical items in hangars, meaning that a couch and a beer fridge will probably be safe from the feds.

 

==========

 

With respect to experimental aircraft building, this is stupid on the face of it.  The FAA is supposedly concerned about aviation safety yet, they will force builders to work in their mushroom cellar without any immediately available advice of other builders, pilots or aircraft shops located at their airport.  The FAA apparently no longer has objectives of promoting GA or safety.

 

Scott Krueger 

 

PS Please consider making comments to FAA as outlined above.  Do not mention your own airport because the data might be used by FA enforcement.

 

PPS Uh, Final Assembly starts when first part is built/assembled.

FAA says hangars no place for homebuilders

Submitted by Anonymous on

From: Jim Nordin <panelmaker [at] earthlink.net>
Sender: <marv [at] lancaironline.net>
Subject: FAA says hangars no place for homebuilders
Date: Mon, 04 Aug 2014 07:20:22 -0400
To: <lml [at] lancaironline.net>
Message Header


Undecoded Message

Before you comment, and I suggest every one
does, read http://www.regulations.gov/#!documentDetail;D=FAA-2014-0463-0001
the crux being:

“Use of
Hangars for Fabrication and Assembly of Aircraft

While
building an aircraft results in an aeronautical product, the FAA has not found
all stages of the building process to be aeronautical for purposes of hangar
use. A large part of the construction process can be and often is conducted
off-airport. Only when the various components are assembled into a final
functioning aircraft is access to the airfield necessary.

In
Ashton v. City of Concord, NC, (3) the
complainant objected to the airport sponsor's prohibition of construction of a
homebuilt aircraft in an airport T-hangar. The decision was based on a FAA
determination that aircraft construction is not per se an aeronautical activity. While final stages of
aircraft construction can be considered aeronautical, the airport sponsor
prohibited this level of maintenance and repair in T-hangars but provided an
alternate location on the airport. The FAA found that the airport sponsor's
rules prohibiting maintenance and repair in a T-hangar, including construction
of a homebuilt aircraft, did not violate the sponsor's grant assurances.

There
have been industry objections to the FAA's designation of any aircraft
construction stages as non-aeronautical. While the same principles apply
generally to large aircraft manufacturing, compliance issues involving aircraft
construction have typically been limited to homebuilt aircraft construction at
general aviation airports. Commercial aircraft manufacturers use dedicated,
purpose-built manufacturing facilities, and questions of aeronautical use for
these facilities are generally resolved at the time of the initial lease. In
contrast, persons constructing homebuilt aircraft sometimes seek to rent
airport hangars designed for storage of operating aircraft and easy access to a
taxiway, even though it may be years before a homebuilt aircraft kit will be
able to take advantage of the convenient access to the airfield.

The
FAA is not proposing any change to existing policy other than to clarify that
final assembly of an aircraft, leading to the completion of the aircraft to a
point where it can be taxied, will be considered an aeronautical use.”

 

I can well understand this problem. My
airport has several totally non-aeronautical businesses on airport. But to tell
me building an experimental airplane is not aeronautical - is absurd. So this
policy must be addressed so everyone can understand what is meant by
aeronautical as my homebuilt can not be used for anything other than
aeronautical functions even if it isn’t flying.

I’m amazed at the ignorance of our
politicians and bureaucrats. Let me say that another way. Politicians and
bureaucrats are citizens without specific knowledge and skills.

Saying all this, I realize GA airports are
not for (designed to be used for) non-aviation activities. So the problem.
Surely our rulemakers can be more intelligent in getting these issues
addressed. It is good that we have the opportunity to have a say.

BTW, if my airplane is in non-operational
condition, should I move it from the hangar to … where?

The best place in many places to get
aeronautical knowledge is around airports.

Jim

 

From: Lancair Mailing
List [lml [at] lancaironline.net]">mailto:lml [at] lancaironline.net] On Behalf
Of Sky2high [at] aol.com

Sent: Sunday, August 03, 2014
11:30 AM

To: Lancair Mailing List

Subject: [LML] FAA says hangars no
place for homebuilders

 

FAA
Says Hangars No Place For Homebuilders

The FAA says most of the work involved in
building an airplane is a "non-aeronautical use" and it has singled
out homebuilders in a new proposed policy statement issued July 22. Policy
on the Non-Aeronautical Use Of Airport Hangars (https://www.federalregister.gov/articles/2014/07/22/2014-17031/policy-on-the-non-aeronautical-use-of-airport-hangars#h-13)
says homebuilders will have to build the components of their projects
elsewhere and can only move to a hangar for final assembly. Comments are
being accepted until Sept. 5 and can be submitted online (http://www.regulations.gov/#!home)
citing docket number FAA-2014-0463. The agency has devoted a separate section
in the proposed policy to explaining its stand. The essence is that the
principal role of a hangar is to supply enclosed storage for aircraft to give
ready access to the runway. The FAA's argument is that bucking rivets on a
wing doesn't require a runway so it's not an aeronautical use. It also says
the policy has always been in force. "The FAA is not proposing any
change to existing policy other than to clarify that final assembly of an
aircraft, leading to the completion of the aircraft to a point where it can
be taxied, will be considered an aeronautical use," the proposed policy
says. EAA is aware of the proposed policy and staff are assessing it.

The new policy statement is the result of
stepped-up enforcement of the rules regarding uses of airport hangars. In
dozens of audits conducted over the past two years, the agency has found
hangars crammed with just about everything but airplanes. Household goods,
cars, even non-aviation related businesses have been discovered. The FAA says
that because federal funds are used to build and maintain airports, the use
of airport facilities for non-aeronautical uses amounts to a subsidy for
those uses. In some cases the city or county responsible for the airport was
the violator. Auditors found police cars and other municipal assets tucked
safely away in airport hangars.  The proposed policy will also clarify
the incidental storage of non-aeronautical items in hangars, meaning that a
couch and a beer fridge will probably be safe from the feds.

 

==========

 

With respect to experimental aircraft
building, this is stupid on the face of it.  The FAA is
supposedly concerned about aviation safety yet, they will force builders to
work in their mushroom cellar without any immediately available advice of other
builders, pilots or aircraft shops located at their airport.  The FAA
apparently no longer has objectives of promoting GA or safety.

 

Scott Krueger 

 

PS Please consider making comments to FAA
as outlined above.  Do not mention your own airport because the data might
be used by FA enforcement.

 

PPS Uh, Final Assembly starts when first
part is built/assembled.

FAA says hangars no place for homebuilders

Submitted by Anonymous on

From: John B <2thman1 [at] gmail.com>
Sender: <marv [at] lancaironline.net>
Subject: Re: [LML] FAA says hangars no place for homebuilders
Date: Mon, 04 Aug 2014 07:21:02 -0400
To: <lml [at] lancaironline.net>
Message Header


Undecoded Message
This one has me totally perplexed.  Doesn't the FAA have enough to do?  Seems like they have no business telling folks what to do with their hangars.  The opinion expressed by Greyhawk and others about safety is a no brainer.  What's wrong with these people?

John Barrett

Sent from my iPad


On Aug 3, 2014, at 9:29 AM, Sky2high [at] aol.com

wrote:

FAA
Says Hangars No Place For Homebuilders

The FAA says most of the work involved in building an airplane is
a "non-aeronautical use" and it has singled out homebuilders in a new
proposed policy statement issued July 22. Policy on the Non-Aeronautical Use Of Airport Hangars
(https://www.federalregister.gov/articles/2014/07/22/2014-17031/policy-on-the-non-aeronautical-use-of-airport-hangars#h-13)
says homebuilders will have to build the components of their projects
elsewhere and can only move to a hangar for final assembly. Comments are
being accepted until Sept. 5 and can be submitted
online (http://www.regulations.gov/#!home)
citing docket number FAA-2014-0463. The agency has devoted a
separate section in the proposed policy to explaining its stand. The
essence is that the principal role of a hangar is to supply enclosed
storage for aircraft to give ready access to the runway. The FAA's
argument is that bucking rivets on a wing doesn't require a runway so it's
not an aeronautical use. It also says the policy has always been in force.
"The FAA is not proposing any change to existing policy other than to
clarify that final assembly of an aircraft, leading to the completion of
the aircraft to a point where it can be taxied, will be considered an
aeronautical use," the proposed policy says. EAA is aware of the proposed
policy and staff are assessing it.

The new policy statement is the result of stepped-up enforcement of the
rules regarding uses of airport hangars. In dozens of audits conducted
over the past two years, the agency has found hangars crammed with just
about everything but airplanes. Household goods, cars, even non-aviation
related businesses have been discovered. The FAA says that because federal
funds are used to build and maintain airports, the use of airport
facilities for non-aeronautical uses amounts to a subsidy for those uses.
In some cases the city or county responsible for the airport was the
violator. Auditors found police cars and other municipal assets tucked
safely away in airport hangars.  The proposed policy will also
clarify the incidental storage of non-aeronautical items in hangars,
meaning that a couch and a beer fridge will probably be safe from the
feds.
 
==========
 
With respect to experimental aircraft building, this is stupid on the face
of it.  The FAA is supposedly concerned about aviation safety yet,
they will force builders to work in their mushroom cellar without any
immediately available advice of other builders, pilots or aircraft shops located
at their airport.  The FAA apparently no longer has objectives of
promoting GA or safety.
 
Scott Krueger 
 
PS Please consider making comments to FAA as outlined above.  Do not
mention your own airport because the data might be used by FA enforcement.
 
PPS Uh, Final Assembly starts when first part is
built/assembled.

FAA says hangars no place for homebuilders

Submitted by Anonymous on

From: Ted Noel <tednoel [at] cfl.rr.com>
Sender: <marv [at] lancaironline.net>
Subject: RE: [LML] Re: FAA says hangars no place for homebuilders
Date: Mon, 04 Aug 2014 13:47:41 -0400
To: <lml [at] lancaironline.net>
Message Header


Undecoded Message

This is a consequence of Noel's Three Laws of the Bureaucrat:

 

1. A Bureaucracy is created to solve a problem that "only it is qualified to solve." The FAA is supposed to solve issues related to the interstate movement of aircraft.

 

Corollary 1: The Bureaucracy cannot ever solve the problem, or its reason to exist would cease.

Corollary 2: In the rare and unfortunate circumstance that the problem is resolved, the Bureaucrat must immediately find a new problem of equal or greater magnitude that "only he is qualified to solve."

 

2. All problems are solved with rules.

 

Corollary 1: Rules are objective and compliance can be identified with checkboxes.

Corollary 2: Reason is outlawed.

 

3. You didn't follow the rule.

 

 

 

In short, this idiocy is Rule 1, Corollary 2 in action. Welcome to the Brave New World of Washington, D.C.

 

Ted Noel

 

From: Lancair Mailing List [lml [at] lancaironline.net]">mailto:lml [at] lancaironline.net] On Behalf Of Steve Richard
Sent: Sunday, August 03, 2014 7:25 PM
To: Lancair Mailing List
Subject: [LML] Re: FAA says hangars no place for homebuilders

 

I just posted this on the site (hopefully in the correct location):

 

So the FAA would rather have the initial construction process done without the benefit of experienced builders and fliers who are always on the airport?  That is counter to safety.  I am somewhat stunned this proposed requirement has seen the light of day, considering that the FAA is constantly trying to find ways to make experimental airplanes safer.  I believe the proposal should be changed to encourage builders to start and end their projects at the airport.  It should acknowledge that airports are the geographic center of most safety activities.  Airports are where hundreds of years of expertise in the form of A&P's, IA's and serial kit builders can be accessed almost instantaneously.  Would it not be better for a new builder to be near all this expertise rather than in their garage at home without any on site immediate counsel?

 

The FAA knows how important airports are as evidence by the money that flows to their capital improvement programs.  Do they not see that airport quality and longevity will not work with money alone?  And the greatest supporters of airports are people who just invested thousands of dollars in a kit.

 

Steve Richard

FAA says hangars no place for homebuilders

Submitted by Anonymous on

From: Peter Van Arsdale <petervanarsdale [at] gmail.com>
Sender: <marv [at] lancaironline.net>
Subject: FAA says hangars no place for homebuilders
Date: Tue, 05 Aug 2014 07:23:54 -0400
To: <lml [at] lancaironline.net>
Message Header


Undecoded Message

It's about time the FAA is addressing this serious problem.  Imagine,

building an airplane on an airport!



To let everyone know they are serious, I hope they start with the big fish

like Boeing, Cessna, Bombardier, etc.  This way us privateers will get the

clear message.



Better still, let the scofflaws do their builds far from any US airport.

Let's say in China.



An unintended benefit of this new program will be a surplus of unoccupied

hangars that can be torn down to create some more green space.



Where would we be without this government?



Peter Van Arsdale

St. Louis, MO







-----Original Message-----

From: Lancair Mailing List [lml [at] lancaironline.net (mailto:)

]

Sent: Tuesday, August 05, 2014 5:00 AM

To: Lancair Mailing List

Subject: lml Digest #4700



        Lancair Mailing List Digest #4700



 1) Re: FAA says hangars no place for homebuilders

    by "Dominic V. Crain" <domcrain [at] tpg.com.au>

 2) FAA says hangars no place for homebuilders

    by "Jim Nordin" <panelmaker [at] earthlink.net>

 3) Re: Gascolators and fuel lines.

    by bob mackey <n103md [at] yahoo.com>

 4) Re: FAA says hangars no place for homebuilders

    by John B <2thman1 [at] gmail.com>

 5) Balston Magneto filter

    by "jwilless [at] itd-nc.com" <jwilless [at] itd-nc.com>

 6) Re: N40941 (LIVP) Filed TAS 295 knots. Was this realistic at 15000'

cruise and 1

    by "John C. Bohn" <johnb [at] bohn-tech.com>

 7) Re: Balston Magneto filter

    by Neal George <ngeorge [at] continentalmotors.aero>

 8) Re: FAA says hangars no place for homebuilders

    by "Ted Noel" <tednoel [at] cfl.rr.com>

 9) Aeronautical use of Hangars

    by rwolf99 [at] aol.com



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