Hmm. So, hypothetically, do we have to consider our teams’ software to have value? Based, perhaps, on the number of student-hours taken to write it times minimum wage or something? (Remembering that “fair market value” is supposed to be used for cost accounting, rather than the money you actually had to spend to get the thing.) If I, as a mentor, contribute directly or indirectly to the code, should I charge my hourly rate to the CAW?
Software development is labor. Assuming there’s a 2020 rule equivalent to 2019’s R14:
R14. The BOM cost of each non-KOP item must be calculated based on the unit Fair Market Value for the material and/or labor, except for labor provided by team members (including sponsor employees who are members of the team), members of other teams, event provided Machine Shops and shipping.
If done by a team member, you may exclude the value of that labor from the BOM.
So, WPILib does not come in the Kit of Parts, or the Virtual Kit of Parts, and with rare exception, is not made by team members. How do you account for the thousands of commits on this crucial piece of robot code infrastructure, given that there’s no easily calculable value, but you can’t deny that Thad, Peter, and the others time has value?
Or maybe we need to consider that this rule change was simple in theory and has ramifications beyond what they intended, as I doubt they want almost every single team to be too expensive before they even have a single component made.
I think that with respect to costing, however, the fair market value for anything that the code’s license allows you to use for free is $0. I think it’s a pretty unreasonable reading, for example, for this rule to require you to estimate the development cost of Linux if you stick a Raspberry Pi on the robot. Same goes for vendor libraries–while they certainly have a development cost, and I think at least some of them have licensing that only allow you to use them with their products, they are free for any team to download, install, and use, so they should have a FMV of $0.
I think this pokes at an interesting question, which is, “what is ‘fair market value’”? Is it the cost to reproduce something? The cost to purchase an identical item? The cost to buy this specific item?
Let me give an example. This is a RAD750 computer:
That board costs several hundred thousand dollars at least, because it’s space qualified and radiation hardened. The purple chip in the bottom right is the RAD750 itself, and the five gold chips across the top are its RAM.
Here is one of those RAM chips in my hand:
I have a box of them because I’ve been around the aerospace industry for a while.
Now, here’s my question. Suppose my team decided to use one of my rad-hard RAM chips on our robot. What would be the “fair market value”? Would it be the $10,000 that BAE would charge for a new one? The price that I could get for one on ebay ($40-$100 or so, depending on gold content)? Or the $7 price of a functionally equivalent, but non-rad-hard, 32MB SDRAM chip on Digikey?
The phrase “fair market value” was used in R14. It wasn’t defined anywhere, that I can find.
Granted, I’m unlikely to actually use a space-qualified SDRAM module on an FRC robot. For a slightly more relatable example, what is the fair market value of a Spike relay (ignoring any KOP exemptions)? There isn’t really a manufacturer’s price, because no one makes them anymore. Is the FMV what IFI originally charged, or is it the price you can buy a Spike for on ebay?
Ah, yes, sorry about that. My local PDF of the manual must be outdated.
But I think my question about the FMV of a Spike still stands. Obviously individual ebay sellers don’t count as VENDORS, unless they have really large quantities of Spikes. But then… what is the FMV of a Spike? Is it $0, since there are no VENDORS (that I can find)? Is it the most recent VENDOR-advertised price? And, getting back to my original example, what would be the FMV of a BAE rad-hard SDRAM chip? Bear in mind that BAE won’t even give you a quote for one unless you’re a national space agency or major contractor; my $10,000 figure was an estimate.
Am I nitpicking? Sure. But I’m opposed to the idea that you can disregard corner cases in your specifications (rules) just because you don’t think anyone’s likely to exercise them.
Blue box, Example E, is the closest thing in this particular case. That said, for a discontinued item, I would ask the question in Q&A of “If no Vendor sells a particular item (as it is discontinued), but it can be obtained used from other Teams, online auctions, etc., would the FMV be the price obtained for it or the most recent Vendor price?”
For the rad-hard SDRAM chip, I would follow the “better safe than sorry” approach and either do a scattershot Google search for prices of similar items, contact the company indicating that you have somehow acquired these and for cost accounting purposes you need to know an approximate FMV, or just not use them. I wouldn’t use the Ebay or functional-equivalent cost.
I’m opposed to the idea of covering all the corner cases, because that leads to really thick rulebooks. If it can be done REASONABLY (e.g. a line or two for several of these), that’s awesome. But that’s partly what the Q&A’s for, and partly what the LRI/Head Ref are there for.
To use the Spike example: If I’m an LRI, and someone comes up to me and says, “Hey, I think a team’s skipping the FMV of a Spike”, then I’m going to ask two questions. The first is “How close is the team to the maximum BOM limit, and how many do they have?” (Given my time in FRC, I know the Spikes are under the individual item limit even if I don’t know the exact price. Offhand, they’re under $200 from manufacturer, new, IF they were still being made.) If the team isn’t close, I’ll ask the team to do some research before their next event, point them in the right direction, and pass them anyways. If the team IS close, then the goal is to work with the team to figure this stuff out–including “can we open up the BOM a little more”, a message to Big Al and his co-chief, and possibly even a message to VEX/IFI. You’re right, I’m dodging the question. But it gets the team legal faster. Quite possibly there’s a followup in the next rules update as well.
I agree that that’s a good Q&A question, for posterity’s sake if nothing else. I’ll submit it in the 2020 Q&A, assuming nobody beats me to it.
Good luck with that
I get your point. You’re saying that (L)RIs should apply reasonable judgement, and, for example, not demand proof of FMV for Spikes from a team that’s otherwise at $2000 total. I don’t disagree with that at all, and I’m in favor of overlooking purely procedural violations in order to let a team get on the field.
I guess my sticking point is that “reasonable” is subjective, and that there’s no real concept of stare decisis in FRC. If (L)RIs have previously declared your grey-area design to be legal, that doesn’t keep (L)RIs at your next event from declaring the same thing illegal. I believe Marshall refers to this as “LRI-a-roo”. My position is that it’s better to have more restrictive but consistent rules, rather than leave a lot of latitude to LRIs at individual events. Or, alternatively, to have less restrictive but consistent rules, and accept that some teams may profit from it.
Ultimately, I think that it’s better for a team to fail inspection at their first event, than to pass at their first event and fail at their second event without changing their robot.
I recognize that that’s a philosophical judgement, and eventually the decision on that point needs to flow down from FIRST HQ.
So, there is a question that we deliberately did not ask that speaks to FMV and the subject of “when”. I’ll post it here and someone else is more than capable of running with it if they want to:
Can you clarify when (in time) to evaluate the cost of materials. The text preceeding R11 seems to imply that costs from the time of Kickoff 2019 would be used as the cost of the robot is being reverted to that time. Is the time to evaluate costs at purchase time, at use time, at inspection time, or at the time of Kickoff 2019? In addition, can you clarify how prices should be evaluated to adjust for inflation? Should the standard Consumer Price Index (CPI) valuation be used or would it be acceptable to use the Retail Price Index (RPI)?
It needs some editing before being asked. Also, shout out to Planet Money and The Indicator podcasts that myself and other Zebracorns are fans of.