All,
I would recommend making specific comments about safety, rules that deviate from FAA regulations or guidance, rules that far exceed the restrictions required by NFPA (fires safety codes)codes for petroleum products, etc. Citing FAA guidance when possible makes a stronger case. Rant's are not likely to get much attention.
What do you suggest they do? Start over? Let the FAA regulate how we fly unless there is a real need for special local procedures? Stop at " No person may store flammable liquids, gases, or related materials in a manner that violates the fire or
life safety codes of the City of Peachtree City and/or applicable National Fire Protection Association(NFPA) codes." as published in section 4.3?
Seek assistance from actual experienced pilots and airport users, and those knowledgeable on fire codes? Remember, your comments will likely become public record, civility is recommended.
I suspect every one is going to latch on to the 10 mph driving and taxing speed restrictions. These are bad but we could do this. There are dozens of other things that are far worse in these proposed rules. I have listed just a few below. Many of the rules, and problems, were just copied from the last set of bad rules. Don't think common sense overrides what the rules say. Don't think "they would not do that" The authority has stated that it intends to start enforcing the rules.
Remember, the authority members come and go. They tend to follow the lead of those that have been here. Hope for, but don't expect and change for the better.
Here are a few examples:
Read the rules closely (section 5.1.a for example) and tell me what approvals you would need to bring a quart of engine oil onto the field, store it in your hangar, and then put it in your engine. If you need authority approval does it have to go to a meeting and be voted on? Would you have to do this every time? Can the tenants realistically follow this rule?
(Section 4.3) What would it cost you to purchase flammable storage lockers for all the petroleum products (engine oil, brake fluid, hydraulic fluid, grease, misc lubricants, etc,) in your hangar to meet the storage requirements in these rules. In my hangar I estimate it would cost at least $8,000 if I went out and bought the required storage items to house everything in my hanger. It could easily be double this if others in my habagr had similar quantities.. The NFPA fire codes do not require any such special storage capabilities for our hangars. Do realize that we are not legal, per fire code, to perform hot work/hazardous operations such as welding, open flames, spray operations.etc. To do so would require fire suppressions systems, etc.Note, the fire codes specifically exempts all fuel and other items contained in the aircraft in the context we are discussing. It does not have to make sense, that is just the way it is.
NFPA 30 allows us to store thousands of gallons of engine oil or smoke oil, as in 13,200 gallons total quantity, and any other combustible liquids with flashpoints over 200 degrees fahrenheit with basically no restrictions. The limit is 120 gallons of gasoline. Double those amounts if kept in flammable storage lockers or safety cans but not required to be if they do not exceed the initial maximum allowable quantities. So what rational reason do they have for placing such restrictive limits on gasoline quantity and requiring expensive storage requirements for petroleum based liquid products? Almost everything they have said or printed about fire regulations over the last decade, in relation to storage of these liquids in our hangers, has been wrong. The smoke oil document that is published on the airport website, in the authority section, is almost 100 percent inaccurate. It covers many other items besides smoke oil. They obviously think those are the rules and it appears they used that inaccurate information in creating these rules. If you have any questions on the fire codes and what we can store and how please feel free to contact me.
For you Rotax guys. You need auto fuel, (mogas). Besides the very artificial limit of 5 gallons of gasoline on the field it says you must have an STC to use mogas. Experimentals, and aircraft certified for mogas cannot get an STC for it.
3.14.B Pattern altitude is listed as 1800' for all aircraft, including jets and helicopters. Not what the AIM calls for. Not safe. Same language as the current rules, Have they published this in the faculty directory?
3.14.A What is the definition of unpopulated area? It is not an FAA term that I can find. Is the golf course an unpopulated area? What about the lake with boaters on it? Does the FAA not already regulate takeoffs and landings?
Hopefully you noticed the starting engines with chocks rule. Anyone going to volunteer to pull my chocks just a few feet behind the spinning prop? Did you catch the one that you should be able to turn without undue reliance on the brakes? It's after the taxi speed limit. There are numerous certified and experimental aircraft that are designed to be turned using brakes only and have no nose wheel steering.
Look at 3.5 Read it carefully and think how this would apply, not what you want but what it says. The AOA is anything inside the
fence per the definition. This included inside our hangars. Most routine maintenance task render the
aircraft unairworthy for a period. Any non-functioning equipment typically
renders an aircraft non-airworthy.
Do you ever take off from the very end of 13? Hint, it may require back taxing. Would these rules require you to do that?
Look at 6.27 hangar inspections. They can inspect any time for pretty much anything with no notice. No requirement to tell you they did inspect. The 24 hour notice is really not needed and even if it were required we saw how they used it last time. "We will be inspecting over the next few weeks, we cannot tell you when we will be in your hangar but we will be..." Might as well say here is your notice that we will be inspecting sometime in the next year. What liability do they have if they damage something? I suspect none give the liability clause they include in this document.
Look at 1.3 A Penalties Suspension, Revocation, Lease Termination,
Fines and Civil Penalties, reporting to FAA, etc. What standards do they use besides "I feel you were unsafe, violated a rule, etc..."? Very open and undefined. Appeals under this process are right back to the
Authority that issued such violation notice.
No neutral party. Seems like
sheriff, judge, jury, and executioner all in one. This applies to any section of these rules. If they say you did something unsafe, in their minds, you could be kicked off the airport., lose your lease and be told to remove your hangar (if you own it), be fined, etc. Could this power easily be abused? Would a board composed of airport authority members, and local tenants be a better answer to who can wield this power? Would this provide a reasonable check and balance to the currently unchecked power?
The bottom line, These rules were very poorly vetted and are not something that the tenants can comply with, even if they try. So how can they be effectively enforced? What value are they/ Do they create safety issues? Do they create a material change to your lease if they require expensive storage solutions? How can they be fixed?
V/R,
John Poulter