I am using this thread to complain about unclear rules. Obviously FIRST is not intending to ban WPILib
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The most recent preseason rules update posted on the FRC Blog, 12/5/19 by Frank Merrick requiring software used on the robot to follow BOM and cost accounting rules has brought up some questions as to the legality of WPILib for the 2020 season.
The general consensus in threads, especially from WPILib contributors, has been that the FMV of free-to-use code (like WPILib) is 0$. At first, I agreed with this analysis, but after doing a bit more reading of the rules I discovered some interesting lines that lead me to believe the 12/5 team update accidentally bans WPILib for 2020.
I posted about it twice in the Team Update thread, but it was buried somewhat by discussion and memery relating to other implications of this rule change. I wanted to make a dedicated thread to make my analysis clear and to raise some questions about interpretations of the rules, so here goes:
(One important note: for this analysis I am going to make the assumption that 2019’s R14 will return this year as 2020’s R13 with similar text, given the omission of an R13 in the preseason rules and the shift in rule numbers from 2019. I will refer to 2019 R14 as R13, since I am making this assumption.)
Cost accounting for COTS parts is fairly simple: R13’s blue box (2019 R14, see above) says that “The Fair Market Value of a COTS part is its price defined by a VENDOR.” That price can change over time, and you are allowed to use the lowest price available from a VENDOR at the time of purchase, per past Q&A and the current interpretation of the rules.
Unfortunately, I don’t believe that WPILib is considered a COTS item. COTS in 2019 was defined as “Commercial off the Shelf, a standard (i.e. not custom order) part commonly available from a VENDOR for all teams for purchase,” and a VENDOR was defined as “a legitimate business source for COTS items that satisfies all the criteria listed in the Robot Construction Rules’ Overview section.”
According to those definitions, WPILib is not a COTS part. Arguably it is provided by a VENDOR (GitHub qualifies as a vendor even if WPILib contributors do not), but it is in no way purchasable from a VENDOR.
I think it would be a pretty large stretch of the word “purchase” to suggest that those two things are equivalent. The lollipops on your bank counter that are provided gratis would not be considered a purchase and are in no way afforded the same protections as a purchase. A coupon for a free item that rings up on a register at the grocery store (even in an order with a 0$ balance) is afforded the same protections as a purchase.
The core basis for this thread is the answer to @GeeTwo’s question. If you don’t agree with my opinion on the answer, this entire thread is a bit of a moot point.
Regardless, continuing with the assumption that WPILib is not a COTS item, the FMV for a non-COTS item is defined by the non-blue-box portion of R13 (again, 2019 R14, see above). The text for R13 is as follows:
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.
Any Kickoff Kit or FIRST Choice item received by a team in or before the 2018 season that has a FMV over $500 may be accounted at $500 on the team’s BOM.
WPILib has never been provided in the KOP or FC, and the contributors of WPILib do not sponsor every team, nor are they members of every team, nor are they all current members of teams. This means that the FMV of WPILib is defined by the FMV of the labor used to create it. That FMV, while nearly impossible to fully calculate, is undoubtedly much higher than $500 and would disqualify WPILib from being a legal piece of software on the robot in 2020.
I’ll list the questions that I think have to be asked to determine if WPILib is legal. My answers to these questions are pretty firm and shown by what I said above. FIRST’s answers will not be able to be determined until after kickoff because R13 (2019 R14) and the definitions of FMV, COTS, and VENDOR were not in the preseason rules releases, making them ineligible for the current Q&A.
- Is WPILib (or has it ever been) distributed by a VENDOR? (I said yes)
- Is WPILib (or has it ever been) a COTS item? (I said no)
- What is the FMV of WPILib? (I said over $500)
If you say no to 1, then 2 must also be no, and 3 “over $500”.
If you say no to 2, then 3 is “over $500”.
If you say yes to 1 and 2, then 3 is $0.
