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A Serious Threat to Homebuilding

Ironflight

VAF Moderator / Line Boy
Mentor
This has flown a little quietly under the radar, what with the Third Class Medical stuff and all, but the FAA is looking for comments on a policy statement that says that the ONLY proper use for a hangar is aircraft storage, and that you are also allowed to have a desk...and keep some log books. No building, no maintenance (apparently). This is in response to all of those hangars sitting chock full of boats, old cars, household goods, etc, etc around the country.

Avweb posted a good piece on this today here, and it has the links to go make a comment to the FAA on this topic. I advise EVERYONE to go comment - it took me about five minutes.

Here is what I posted:

Having been personally involved in aircraft construction, maintenance, and flight for over 40 years, I am stunned to read that aircraft construction is not an aeronautical activity. The FAA personnel involved in developing this document need to actually visit a small airport some time and see just what is going on outside the beltways of major cities. Aircraft construction and maintenance has been performed in airport hangars since the dawn of aviation - the earliest airports were no more than convenient fields NEXT TO the building in which the airplane was constructed. This policy statement shows a complete lack of touch with the real world - most small maintenance facilities are, indeed, located in "hangars" with a taxiway leading to the runway. This statement would make virtually ALL maintenance facilities fall outside of the definition, and potentially put them out of business.

In the past month alone, as an aviation journalist (Editor in Chief of Kitplanes Magazine), I have visited three different manufacturers of aircraft and aircraft kits, all of whom are constructing aircraft components and aircraft in buildings which they use as hangars located directly on airport taxiways. This policy will devastate them - they will be out of business, and the entire general aviation industry with them.

Defining hangar usage in this way will provide a legal basis for the total destruction of aviation activities, since major airplanes also do maintenance in hangars. The recourse, of course, is for an individual to hang a sign on their building clearly labeling it as something other than a hangar.

While I support the idea of limiting the use of hangars to aeronautical activities, which would provide a great many more hangars that are currently being used to store boats, household goods, farm equipment, and the like, I can not see how any reasonably educated person could refuse to acknowledge that aircraft construction and maintenance are not "aeronautical activities". This portion of the policy is clearly wrong and needs to be re-written.

This is a huge threat if your local airport decides to use the FAA's definitions in a legal action. As of this morning, there were only 46 comments - there need to be 4600!
 
Not good!

I'll be posting a comment on this today. What about airparks? Or is this proposal limited to only airports that receive federal funds. This would shut down a large portion of our community at Spruce Creek!
 
Done!

But...Jay Leno should write a letter too so he doesn't lose his garage-mahal :D

Last I knew his hangar didn't have any airplanes in it.....
 
I can certainly understand the basic idea of protecting aviation, but this is so misguided.

One thing that might be mentioned, the home build industry generates huge revenue directly for US made goods and services and they are ALL directly related to growth and advancement of aviation.

I wish we had the numbers compared to certified (certificated?) aircraft. Data anyone?

Comment posting underway.
 
Wow! Where did this come from?! I'll respectfully comment to the FAA.

Two steps forward, one step back...ugh!

Thanks for alerting the troops Paul!

Brent

my comment:

"As a professional pilot who has been flying for over 27 years, I also have restored and built a number of airplanes as part of my passion for aviation. This allows me to enjoy recreational flying on top of my professional pursuits and helps to promote and share the freedom we enjoy in this country as aviators.

While I understand that using hangars for storage of non-aviation related items is misuse of airport facilities, it is incomprehensible to prohibit aircraft restoration or construction in these structures. One of the most prolific aspects of recreational aviation that would be doomed to extinction if this proposal is not properly amended.

Please reconsider the unintended consequences this proposal would have on an already ailing industry; one in which costs have escalated out of control, student pilot starts are at an all time low, the number of registered pilots is lower than it has been in the last four decades, and a real pilot shortage is on the horizon."
 
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Gov't Intrusion

Just posted my comment. Was civil and hopefully made sense.

Being Retired Military, and former Civil Service, I tried to put it into a statement they would read, not just toss in the "in" basket.
 
commented

I just posted my comment, just another way to control the things we enjoy, I think it's important because fellow builders and pilots can lend alot of experience
 
I read the proposed FAA policy statement to mean it would be OK to do the "final assembly", whatever that means, but not all the construction. The "FAA determination that aircraft construction is not per se an aeronautical activity" is simply ridiculous. If building an airplane is not an aeronautical activity -- then what the heck is it? And banning maintenance in hangars when E/AB and A/LSA owners are able to do their own maintenance is just plain stupid. If I can't maintain my own plane in the hangar I'm paying for (twice), then where else exactly would I do it? I think they're after the guys who park a stripped, derelict airframe in their "on-airport storage locker" and claim to be restoring it. I also know of a couple with airplanes in them that are being restored, albeit slowly over a period of several years. It seems obvious to me that one use should clearly be OK, the other probably not -- but I don't know how you could enforce that with a policy.

I can't see how they could make this or any similar policy clear enough not to confuse people and screw over at least some builders.

Polite comment filed.
 
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Comment made

This needs to be brought to the attention of our Congress critters. Given that this is an election year, that may work into our favor. I presume that the alphabet agencies will also weigh in on this.
 
But how do you write the rule?

Houston, we have a problem.

I made my comment this morning, but I clearly see the problem here.

Near me is a hanger that has motor bikes, a couch and a tool truck that rents space from the leassor. Hanging on the wall is a wing frame from an old Luscombe so the guy says the hanger is used for Aviation purposes. He is not an AP and has never touched the wing after he hung it up.

How do you write this rule?

How about the guys who start building, but have to stop for awhile? Maybe even a year? Life happens and this is still a project that will proceed. How do you write that?

Yes, my airport is clogged with non-aviation use, but we can not call everything non-aviation to just clear out hangers.

We need to see aviation from end-to-end if we are to see general aviation grow. From design, development and maintenance of all aircraft. From building experimentals (even slow building) to restoration of older birds.

I also would like to add that the rules include an appeals process.

CC
 
Sometimes I think that the goal of the FAA is to destroy general aviation so they don't have to deal with it.
 
Hangers with clutter

If there is a person misusing hanger the fellow renters should bring it up to management of the airport with the misuse is occurring. You can not allow the government to tell us what we can do first hangers, then soon they get emboldened and start even more rules. You need to talk your airport management if you have an issue the government is not ment to solve these issues.
 
I really hope I just chucked a spear that lands someone in hot water.....





I recently tried to find a hangar for my home built in the Trenton/Princeton area of New Jersey. Upon scouting out hangar space at Princeton airport (39N) I came to learn that not only is the airport property being used by a local car dealership to store inventory, but so are most of the hangars. Allegedly in an under the table deal with the city.

This is the story at most airports I've been looking for.

Home-builders are advocates for aviation, and the industry. The airplanes they build ultimately turn into tax revenue, fuel sales, etc for the community.

Building at an airport, in your hangar is vastly safer as well, especially when there are multiple projects within a hangar. When I moved my project to the airport, being surrounded by other builders the amount of knowledge I gained was incredible. The things I had done wrong were fixed, I learned better and approved ways of doing things. Isolating builders and pilots, especially new ones, to the corners of their garages and basements in no way at all advances aviation or aviation safety.

How about instead of kicking out actual pilots and airplanes, you start by booting everything else I've seen in hangars. RV storage businesses, car dealerships, boat storage, furniture businesses, hoarders, auto parts storage, car restoration businesses, etc. Only then, after all the truly "non-aviation related" activities have been evicted, should you then be targeting home builders because of a lack of hangar space.

When this country has a hangar space shortage problem because they're all full of actual airplanes and airplanes under construction... I'll celebrate. When I can't find a hangar because everyone is building, or there are airplanes everywhere it gives me hope for the aviation industry in the US. When I can barely get to the FBO because there are 200 new Honda Accords lining both sides of the road, it infuriates me and makes me wonder just what the FAA's priorities actually are.
 
I've added my comments too.

It is important to note, however, that the FAA does not consider this as a change from their current policy, as they have previously confirmed that an airport owner/sponsor that receives Federal funds, or is otherwise obligated to only allow "aeronautical use" of the facilities, is allowed to prohibit hangars from being used for aircraft construction and maintenance. Here is the actual wording from the Proposed Rule:
-----------------------------------------------------------------------------

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.
 
A careful reading....

I intend to submit a comment on the proposed rule but I'm having trouble seeing where the proposal would prohibit me from doing maintanence in "my" hangar on the RV-6. I realize the proposal would give individual airports license to customize (abuse??) the policy, but here are direct quotes from the proposal:

begin quote-

Storage of operational aircraft

○ Final assembly of aircraft

○ Short-term storage of non-operational aircraft for purposes of maintenance, repair, or refurbishment

Provided the hangar is used primarily for aeronautical purposes, an airport sponsor may permit limited, non-aeronautical items to be stored in hangars provided the items are incidental to aeronautical use of the hangar and occupy an insignificant amount of hangar space (e.g., a small refrigerator). The incidental storage of non-aeronautical items will be considered to be of de minimis value for the purpose of assessing rent.Show citation box
Generally, items are considered incidental if they:

○ Do not interfere with the aeronautical use of the hangar;

○ Do not displace the aeronautical contents of the hangar;


end quote-

How will this language prohibit me from conducting condition inspections, oil changes, panel upgrades, etc on my RV-6 and storing items in the hangar required to conduct these operations?

Here is the line in question from the above quote:

○ Short-term storage of non-operational aircraft for purposes of maintenance, repair, or refurbishment

I hate gov't intrusion as much as anyone but I think a careful reading of this proposal is in order before we draw final conclusions.
 
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Please excuse the Devil's advocate...

There are practical arguments why you may not want a homebuilder on the other side of your t-hangar wall. Sanding dust, paint overspray, and certain fire and electrical issues leap to mind. Don't limit your thinking to RV construction. For example, I want to weld a fuselage frame. Never mind that your fuel tank vents, in the connecting hangar, like to belch fuel on the floor.

You worked quite hard to build your new RV at home, and did so in a very reasonable time span, mostly due to the fact that in addition to weekends, you worked in many hundreds of short sessions. How will you feel about remaining on a hangar waiting list while a non-flyer who rarely works on his project enjoys the airport experience?

Point is, such a policy is not entirely unreasonable. The proposed clarification merely supports local administrative efforts....IF your local sponsor chooses to write a no-homebuilding clause into a lease and enforce it in the local courts. The Feds themselves won't enforce. They merely withhold grant funds, and then only if somebody plays squeaky wheel.
 
begin quote-

Storage of operational aircraft

○ Final assembly of aircraft

○ Short-term storage of non-operational aircraft for purposes of maintenance, repair, or refurbishment

Provided the hangar is used primarily for aeronautical purposes, an airport sponsor may permit limited, non-aeronautical items to be stored in hangars provided the items are incidental to aeronautical use of the hangar and occupy an insignificant amount of hangar space (e.g., a small refrigerator). The incidental storage of non-aeronautical items will be considered to be of de minimis value for the purpose of assessing rent.Show citation box
Generally, items are considered incidental if they:

○ Do not interfere with the aeronautical use of the hangar;

○ Do not displace the aeronautical contents of the hangar;


end quote-

How will this language prohibit me from conducting condition inspections, oil changes, panel upgrades, etc on my RV-6 and storing items in the hangar required to conduct these operations?

.



Sam,

I read it the same way.

However, at what point is the assembly of an airplane at its "final" stage? How much of the hangar can be occupied by non-aviation stuff before it is no longer "insignificant?" What's the timeframe for "short-term storage?"

Perhaps it is intentionally vague. But then this allows the airport sponsor to set these rules in their own terms.

Maybe it's like the definition of pornography: "I don't know for sure how to define it, but I'll know it when I see it."
 
Who is the owner?

It would make sense to me that hanger "owners" such as a FBO would prefer renters that actually have aircraft that fly or are close to flying. Allowing a car dealership to store autos in hangers makes little sense to me.
I would think that additional sales in the form of fuel, oil or repair would be much more beneficial than allowing storage of non-aviation products.

I prefer to keep Government in a limited role as they don't always possess common sense in the every day world.

I see two problems. The unfortunate reality that hanger space is misused and a Government entity attempting to solve a private business issue. Looks like an accident waiting to happen.
I completed my comment for the FAA today. Thanks Paul for the heads up.

Is this a reason why I can't find a hanger at an airport in Katy/Houston???

Pat Garboden
Katy, TX
RV9A N942PT flying
Dues paid.
 
I have posted my comment to the FAA. A whopping 50 comments now. Come on people, this is US they want to restrict.
 
May I suggest that folks make the point that the construction of and maintenance of ANY aircraft is a proper use of any hangar facility.

Do not try to make the argument that a project is an "aircraft"-------that is a long standing contention of the tax man and has been for the most part successfully debunked by those of us who have projects----------no sense in adding fuel back to that particular fire.

And speaking of fire--------Dan H. made some very valid points about safety issues, but IMHO they are not relevant to whether a project is appropriate use of a hangar, there are already plenty of existing fire rules and regs to deal with that situation. Take a look at the NFPA guidelines, which is the basis for most local fire laws.

My comment below.

"I am totally shocked that the FAA has determined to single out the home building community in this action. Or to put it in more correct terms, the Experimental community.

When Boeing or Lockheed builds a new design, it also starts off as an experimental..........................so why are they not also included in this proposal??

Any use of a hangar exclusive of aircraft is what you folks should be pursuing, but the building of, and maintenance of aircraft MUST be considered to be a conforming "aeronautical use" of the airport and hangar."
 
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So if you live in a neighborhood where the homeowners covenants prohibit building in your garage (which is ludicrous btw)... you're pretty much hosed.
 
Public Interest

Sam is right. This issue requires careful reading and thoughtful responses. When an airport accepts federal funds to build and maintain their airport property (AIP or Airport Improvement Program) the airport knowingly agrees to comply with federal policies. By law, federal regulations are founded in public interest. In this case, the public interest is providing as much runway access as possible to those that wish to store their aircraft on the airport. A hangar filled with furniture is the obvious target. Homebuilding would be a reach of course. Homebuilders are the minority in the airport environment. Regulation is designed to benefit society as a whole rather than a particular interest. Advocates for homebuilding on federally funded property will have to show their activity to be in the public interest...which they can, as many of you point out. I have no doubt this is the approach that will be taken by the EAA staff that will be involved.

Even the 3rd Class medical proposal mentioned by Administrator Huerta will no doubt be a "public interest" approach that benefits all of society, not just the 50,000 mentioned in the EAA petition.
 
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I bet the guys who don't want homebuilders at the airport sure would not mind them if they need help or borrow a tool. Remember even a air compressor can throw a spark and start a fire , the same air compressor you use to fill your tires maybe think about its not just homebuilders thst may cause problems , there is no perfect and safe world so don't stop a guys dream of building at the airport
 
Our airport board of directors is aware of the problem of non-aviation uses of the hangers and works to eliminate it. This is the correct approach, not a new federal rule. Since when does the FAA tell an airport what to allow and not allow in their hangers? Seems to me that the hanger is not located on federal property so where is the jurisdiction? Does there exist some unlimited power of the federal government when it comes to airport hangers?
I posted my "fairly" respectful comment.
 
Be on target!

I totally agree that everyone needs to read the proposed wording carefully. It can be interpreted a number of ways, and I am completely ok with the concept of restricting non-aviation uses of airports that get in the way of aeronautical uses. My only problem, actually, is with this statement in the proposal:

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.

The wording of this interpretation is vague enough that a city attorney can use it to go after a lot of folks when a newly-elected councilperson decides he needs a hangar for their flying airplane and wants to kick a homebuilder out of there's. Legal action costs EVERYONE - and arguing over a vague interpretation (what exactly IS "final assembly") will only create work (and income) for the legal system.

Remember - to a scratch-builder, "Final assembly" might mean cutting down the spruce tree they planted from which to make the spars. To someone who wants to argue the other way, it might mean adding oil and gas before first flight.

We also have to be careful not to discriminate against homebuilders when aircraft (and kit) companies can do the same thing. Van's, Glasair, Cubcrafter, Sonex, Kitfox...all manufacturers who have hangars (where fabrication occurs) located directly on airport taxiways - I know, I've been to all of them recently.
 
The FAA has been in business for 56 years and not until now has it had a problem with whats stored in hangars. Coincidence? No way.
 
Storage

I really hope someone's boat or car dealership isn't the reason why I've been on a hangar list for three years. :eek:
In any case, I wrote paper to both Senators and my Representative on this problem and the medical issue.
 
Let's at least spell Hangar properly.

I agree... but when I mention it to our town, they say the zoning codes and fire codes use the improper "hanger" spelling.

When I was building my hangar, a friend gave me this cartoon, which still hangs in our house -

hangar_zps2c73a644.jpg
 
This is ridiculous, amazing that the FAA has spent time on this vs. the third class medical issue that they continue to delay. I wonder how long it took to create this garbage vs. the third class medical comment period. Oh ****, I forgot it's only still planned to start sooooooooooooooooooooooon.
 
Upon scouting out hangar space at Princeton airport (39N) I came to learn that not only is the airport property being used by a local car dealership to store inventory, but so are most of the hangars.

This airport is privately owned.
 
I just commented, adapting others and adding some work process suggestions. Current count is 49 but I think they only update that daily. I think instant updating is beyond the capability of govt websites, that requires reading past chapter 2 in "Website Building for Dummies."

My comment:
I am a 1000 hour private pilot, instrumented rated, former Cessna and Bonanza owner, and now builder and owner of an ELSA RV12.

Aircraft construction IS MOST DEFINITELY an aeronautical activity. Aircraft construction and maintenance has been performed in airport hangars since the dawn of aviation. This policy statement shows a complete lack of touch with the real world - most small maintenance facilities are, indeed, located in "hangars" with a taxiway leading to the runway. This statement would make virtually ALL maintenance facilities fall outside of the definition, and potentially put them out of business.

Many home builders build their plane in a rented hangar. Why is this bad? I did partially this for my RV12.

Hundreds of small companies construct aircraft components and aircraft in buildings which they use as hangars located directly on airport taxiways. This policy will devastate them - they will be out of business.

Defining hangar usage in this way will provide a legal basis for the destruction of aviation activities. I can not see how any reasonably educated person could refuse to acknowledge that aircraft construction and maintenance are not "aeronautical activities". This portion of the policy is clearly wrong and needs to be re-written.

The building of, and maintenance of aircraft MUST be considered to be a conforming "aeronautical use" of the airport and hangar.

WHY can't you folks talk to even a few pilots or EAA or AOPA in some friendly "Hey, take a look at this before we put it out to see if we are missing something that will unnecessarily rile people and worsen an already adversarial relationship?" Because again and again, you put forth proposals that haven't been thought through and make us pilots shake our head in wonderment.

What is it about the work process that produces proposals like this, that so often contain language that exhibits a profound lack of understanding about the area being regulated? That seem, to the educated layman, to lack basic common sense?

The FAA has both position authority AND knowledge authority. It has true experts. Where are they in this process? Yet so frequently things like this come out and we get embroiled in a needless fight. (Recent examples: sleep apnea and Aircraft Certification Service (AIR) Draft Orders.)

How difficult would it have been to, as part of the process, have someone other than lawyers look at it (because clearly no pilots or aviation experts did)? To send it - fax or email, to say the ALPA, AOPA, EAA, etc. with a cheery note that says "Hey y'all - here's something we are kicking around. Do you see any showstoppers? Any forehead-slapping thing that we might have missed? Hey, we're all human! Howzabout a friendly review before we go public?"

Why do we have to always start things out adversarially because of a (to put it mildly) lack of consideration of the screamingly obvious real world effects of the proposed change?

Why can't there be a volunteer group of knowledgeable aviation professionals, reflecting a cross section of interests, and interested parties that could assist in the initial formation of proposals like this? I am not talking about "lobbyists in the back room writing the regulations" but some kind of input to the process so it is not waaaaaay off of the rails from the very start. That really makes for hard feelings, suspicion, and a lack of respect on all sides. This does NOT have to happen!

I would not suggest this except for it keeps happening over and over. Parts issues. proposed crazy ADs. the stuff we read about and get "alerts" on every month. The FAA doesn't seem to have a handle on it. The good, knowledgeable, experienced people in the FAA don't seem to be anywhere NEAR this work process. It hurts everyone.
 
An interesting observation. KHGR Near me has a very large hangar that will hold over 11 737's and is rented to the govt for records storage removing a significant resource for aeronautical use. In addition there is a hangar that holds at least 10 king air class airplanes rented for truck storage. This is an airport that recieved what was the largest grant issued to a non-air carrier airport ever. Wonder how that will go down?
 
It seems the latest technique in DC is to create diversions when they wish to avoid attention to something important. They had to know this was stirring a hornet's nest. What do you suppose they are diverting attention from? The possibilities are frightening.

Easy later to just say this was a misinterpretation while we are all so focussed on it that other things got done that were/are not good for us....
 
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An interesting observation. KHGR Near me has a very large hangar that will hold over 11 737's and is rented to the govt for records storage removing a significant resource for aeronautical use. In addition there is a hangar that holds at least 10 king air class airplanes rented for truck storage. This is an airport that recieved what was the largest grant issued to a non-air carrier airport ever. Wonder how that will go down?

Add that one to the comment section.


It seems the latest technique in DC is to create diversions when they wish to avoid attention to something important. They had to know this was stirring a hornet's nest. What do you suppose they are diverting attention from? The possibilities are frightening.

Easy later to just say this was a misinterpretation while we are all so focussed on it that other things got done that were/are not good for us....

User fees.
 
Connecting the Dots...

It is well known that the virtual explosion of homebuilt aircraft building/buying/flying activity in the last 15+ years has been a renaissance to GA and literally kept it from sinking below the horizon. But these benefits have come at a cost to some influential actors?.namely the certified manufacturers (Cirrus, Cessna, et al). Despite cogent arguments that EAB is a different market segment, and as a result, that its ascendance has not hurt the certified marketplace, they do not see it that way.

Let?s look at some recent history?

1 - It was just a scant few years ago that the FAA undertook a major effort to materially diminish homebuilding activity with its proposed changes/clarifications to the 51% rule.

2 - Despite essentially no change in the safety record for EAB aircraft in recent years the FAA THIS YEAR has identified EAB?s safety record as a priority for improving. [Yes, everyone agrees that fewer accidents and fatalities is a good thing, but let?s not fall into the trap that brands anyone calling out the real motives for this emphasis as being against improving safely!]

3 - And now we have the tortured reasoning supporting the new proposed rule - that aircraft building is not a legitimate aeronautical activity!

This is not a mistake, nor is it the result of bureaucrats with otherwise good intentions being disconnected with the real world. It is the latest in a series of deliberate assaults on an activity that for various reasons, and due to pressure/encouragement from predictable actors, is deemed to be undesirable by the very people that are supposed to represent our interests.

The FAA has been in business for 56 years and not until now has it had a problem with whats stored in hangars. Coincidence? No way.

Rocketbob is correct. If this latest ?attack? on homebuilding by the FAA is viewed in isolation, then we run the serious risk of missing the BIG PICTURE!

There is one more dimension to consider here, and that is punishment.

The FAA has been slow (to say the least) in responding to thoughtful and statistically supported efforts by the AV community at large to make material changes to the rules regarding what activity should be governed by, or require, a 3rd class medical. Due to this lack of responsiveness, pilot-citizens and alphabet groups working together have communicated with, and built support from their elected legislators. As a result, both the House and Senate have introduced legislation that would decide these matters, thus usurping the FAA from its otherwise regulatory role. Having dealt with government bureaucracies in my business over the years, their turf is EVERYTHING. And if you step on their toes they will retaliate when they can. One only has to read the news to see a range of federal agencies accused of/engaged in just this type of retaliatory behavior?IRS, EPA & Immigration just to name a few.

To conclude, we need to enlist more assistance from our friends in Congress to push back on the FAA?s ongoing attacks through additional legislative efforts. We will never prevail in this fight if we do not correctly recognize who the adversary is, or be so foolish as to bring a proverbial knife to a gunfight!!
 
Is it really that onerous?

The intent of this policy is to ensure that the Federal investment in federally obligated airports is protected by making aeronautical facilities available to aeronautical users, and to ensure that airport sponsors receive fair market value for rental of approved non-aviation use of airport property.

A first time builder, I started my RV8 in Jan 2008 and flew it in Feb 2012. My construction took place entirely in my hanger here on the Space Coast of Florida. I understand that some folks take 10 years or more to complete their projects.

While I was building my RV there were (and still are) about 100 names on the airport waiting list here at KCOI and many of those hanger hopefuls had aircraft rotting away out on the ramp in this god awful Florida coast environment.

I had a building space alternative and that was my garage or a rental storage place of which there are many in this area.

Question: Was it fair of me to occupy a hanger for 4 years while flying aircraft sat exposed?

The rest of the story: My Steen Skybolt was also in the hanger which flew regularly and eventually was perched on top of an Aero Lift when I went into the final assembly phase. But you get the general drift of my comment.

I don't see this as anti-builder; rather it seems to be trying to correct some legitimate issues. It also "clearly" legitimizes experimental aircraft construction (albeit in final assembly). Melbourne Florida used to prohibit that activity as well as maintenance in your hanger.

Here's the link to the proposal:
https://www.federalregister.gov/art...-non-aeronautical-use-of-airport-hangars#h-13
 
I sent mine in

I just sent my comment in. I also read that the page updateds at 11:59 each night. Only 49 comments as of last night, can't wait to see how high that number jumps tonight!

I?ve been flying since 1985 and would have quit flying in 1997, if I had not been able to build an experimental aircraft at my airport, in a hanger. I have now built two aircraft in my hanger and am enjoying flying very much. I have also become an A&P mechanic and do all of my own maintenance in my hanger. If I could not have been able to build and do maintenance in my hanger my enjoyment of flying would have been very short lived. I do agree that hangers that are not being actively used for aviation purposes should be made available to people who will use them. I believe that the FAA needs to rewrite the policy statement on hanger use to keep airports from running off the people that are actually using the hangers for what they should be used for.
Bobby R. Hester Jr. ? Rans S12xl and Van?s RV7A Builder and A&P mechanic ? Hopkinsville, KY

Yea, Yea, I spelled hangar wrong, if you can figure out what I'm talking about then get over it.
 
I'll respect the Feds interest in their financial stake in airports....

... when they force greedy Chicago politicians to re-open Meigs.
 
Maintenance

Just where exactly does the FAA expect aircraft maintenance to take place? This probation in some hangar leases has always confounded me.

Cheers

P.s. Flying home today but will make a comment on this.
 
Another gentle reminder.....it's hangar..

Hangar

HangAr

HangAr

:)

Now that's funny.

What's not so funny is that one of our local RV guys was recently called in to the airport admin office to discuss things in his hangar. Like a power strip, work bench and even a metal airplane figurine he has mounted on the wall.

He has a super neatly organized hangar with nothing but his RV-8 and maintenance tools (wing cradle included). Results were that the power strip had to go.... Ouch (can't figure that one out). All tools, etc could stay if it was used for annual inspections/maintenance.
 
I'm not convinced it will help, but I submitted the comment below.

While I do support the primary goal of this policy, keeping hangars out of the hands of people storing cars, boats, campers, etc. or running non-aviation related business, I do have to take exception to the view that constructing aircraft is not an aeronautical use.

The assertion that building primary structures is an endeavor best suited to other venues is not necessarily valid. In many cases there is no other location available for aircraft construction other than the local (or not so local) airport. Not everyone has a garage at home and many that do have their uses severely constrained by other regulatory agencies or boards. Many, if not most, self-storage locations have prohibitions against doing anything in the actual storage space. In these cases, a hangar at the airport is the only option.

There is another, perhaps more cogent and important consideration to building an aircraft at an airport and that is access to experienced, skilled assistance. At most airports there is access to licensed mechanics, experienced pilots that are knowledgeable about aircraft construction as well as other builders (or at least those that have been through the building process and can provide guidance and encouragement). The availability of such knowledge and experience can greatly increase the quality of aircraft construction which can ultimately lead to increased safety of the operation of such aircraft.

I would, therefore, respectfully and sincerely request that the definition of "Aeronautical Use" be amended to include the construction of aircraft and/or aircraft components.
 
...How will this language prohibit me from conducting condition inspections, oil changes, panel upgrades, etc on my RV-6 and storing items in the hangar required to conduct these operations?

"...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."

I know of an airport where owner maintenance and bringing in an I/A for an inspection was not allowed as the operator felt it was taking money from his maintenance operation. I.E, an "alternate location on the airport." I agree careful reading of the proposal is needed, but the way I read the above, it looks to me like the FAA has no problem with a sponsor prohibiting someone from even changing their own oil.
 
I wonder what affect this will have on the small business/individual A&P mechanic making a living from a rented hangAr?

So glad and fortunate to own my own hangar and not having to deal with beaurocrats and politicians.
 
I guess the airport's own maintanece hangar that stores the lawn tractors and snow plows has to go since the do not directly fit the definition of aeronautical use.
 
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