Depends on what you want to do.. The Pyro (ejection) change and squib very well might require a LEUP depending on who you ask, and what you plan on using. This is the part that most people miss when the claim Hybrids are "permit free"... These motors will often require an ejection charge!
Daveyfire (squibs) pretty much dropped out of the business due to the new regs, and it seems that it's hard to find someone who sells BP without a permit...
What is the deal with "depending on who you ask"? Either you do or you do not... No? Or is it different state to state? If not I am not sure what the "depending on who you ask" thing is all about. I would want to know the actual law not someones interprutation of it. I have had a little too much of that recently on another rocket list I am on.
Kevin... You missed the point about the pyro.. (4fg BP, etc). Orxal squibs may also require a LEUP, and the same with any other replacement to the Daveyfires. Daveyfire NEVER was thrilled about selling to us rocket folks, and their "closing down" just eliminated the backdoor thru the fireworks crowd.
I'm not talking about firing the hybrid, but the ejection charge! How many folks fly hybrids without some type of recovery? And now many of those plan BP with a squib triggered by electronics?
End result, is that to do hybrids, you need to use (common route) a squib and BP - either one of which may require a LEUP based on who you talk to. So, hybrids (any - even if they don't use APCP to start it), to be actually be used, may still require a LEUP!
I've yet to hear of any HB manufacturer which ships BP for an ejection with their reloads.
Yes, the ATF restrictions hit ALL motors... Not just APCP!
Then you don't understand the mess this whole thing has been in for the last couple years! Some folks go by "EA" being unregulated, some don't.. Some don't consider a reload kit regulated, and other's do,,,
Don't blame me if the rules aren't clear.. Our "leadership" at NAR and TRA can't give you a clear answer either! Go ahead and pose the question to NAR and TRA and be sure to post their answers here!
Basically, if the AFTE thinks it's regulated, you may want to be able to show a permit, reguarless of what is said on any message board. "what hybrid motors (G and above) can you safely fly in a rocket without any need of permits as requested by any ATF agent in the US?" I'll bet the resonse includes "depending on who you ask...."!
Most of the answers to your permit questions can be found at:
The cost depends on the permit type.
Renewal period depends on the permit type.
Type 34, User of Low Explosives, is the permit you most likely want and is currently $100 for the initial application and is good for three years. After that renewal is $50 and also good for three years.
The Limited Permit is only limited in your privledges, not in paperwork or requirements. It is $25 for the first year and $12 per year thereafter. It has a yearly renewal cycle.
3) The term "this part" in 27 CFR 55.841(a) has a specific legal meaning, in context. It refers, specifically, to the particular Part of the particular Title containing the phrase "this part". In other words, it refers to Part 55 of Title 27 of the Code of Federal Regulations (aka 27 CFR 55). This reading is made even more obvious by the fact that the sub-section 841(a) mentions several other sections within the part it's talking about specifically by number.
4) The provisions of sections 55.180 and 55.181 relate to "plastic explosives", which are defined in 27 CFR 55.180(c)(4) as "(4) Plastic explosive means an explosive material in flexible or elastic sheet form formulated with one or more high explosives which in their pure form has a vapor pressure less than 10-\4\ Pa at a temperature of 25 deg.C, is formulated with a binder material, and is as a mixture malleable or flexible at normal room temperature. High explosives, as defined in Sec. 55.202(a), are explosive materials which can be caused to detonate by means of a blasting cap when unconfined."
5) I don't think anyone has ever even alleged that the rocket motors we are talking about are "formulated with one or more high explosives", so the provisions in sections 55.180 and 55.181 of this part (part 55) are clearly not applicable.
6) Since 27 CFR 55.180 and 55.181 are clearly not applicable, what we are left with is an exemption from all of 27 CFR 55. As you can see by perusing
55 regulates all aspects of "Commerce In Explosives", from licensing to storage, to disposal, transportation, or what to do if any is stolen. See 27 CFR 55.41 for general information on Licenses and Permits, for instance.
7) An unequivocal exemption from essentially all of 27 CFR 55 (with the twin exceptions of the sections relating to plastic explosives I mentioned above) means that LEUPs are not needed. It also means that LEMPs are not needed for manufacturing PADs. Assembling a PAD is an unregulated activity, at least as far as the federal explosives regulations in 27 CFR 55 are concerned.
The judge said that exemptions at 55.141 apply to our rocket motors. Section 55.141 (a) begins: General. This part shall not apply with respect to..." (and then enumerates the various exempted circumstances).
The exemption relieves us from the ENTIRE burden of compliance to all regulations of "part 55", not just from only those parts dealing with user permits. Also in part 55 are to be found requirements for manufacture, storage, etc., and the definition of "explosive materials" (in section 55.11) that invokes the "List of Explosive Materials provided for in section 55.23". That means that BATF can "list" things as "explosive" all they want, but that doesn't act to bring PAD's within the definition of "Explosive Materials" - neither their creation and distribution (whether or not considered "commercial"), nor their acquisition, storage and use, are subject to Part 55.
What part of "this part shall not apply to..." are you having such trouble understanding?
Where does is "commercial manufacturer of what is classified as a LE" excluded from the exemption?
"In addition, the Court finds that the ATF's pronouncement that sport rocket motors are not PADs is invalid because it was made without compliance with the notice-and-comment rulemaking procedures of the OCCA and the APA."
27 CFR 555.11, Propellant Actuated Device. Any tool or special mechanized device or gas generator system which is actuated by a propellant or which releases and directs work through a propellant charge.
27 CFR 555.141 exemptions (a) (8) Gasoline, fertilizers, propellant actuated devices, or propellant actuated industrial tools manufactured, imported, or distributed for their intended purposes.
They can and do.
2-2.2 In addition to the above the applicant must obtain and submit an "EX" number assigned for a particular propellant formulation by the U.S. Department of Transportation/ Research and Special Programs Administration (US DOT/RSPA). This agency issues this number on a recommendation by the Bureau of Explosives (BOE), Canada Center for Mineral and Energy Technology/Canadian Explosives Research Laboratory (CANMET/CERL), or any other agency approved by the competent authority of the United States. The recommendation for classification is given when the applicant provides propellant and other required information for testing. The applicant must also provide TMT with a copy of a BATF Low Explosive Manufacturer's license prior to acceptance of motors for testing. This requirement is by Tripoli Board motion and vote on 23 January 1994.
Who told you that? LEUPs have nothing to do with getting certified at Level 2, or any other level. They are completely and utterly irrelevant to flyer certification.
Why are you asking about this stuff here, instead of asking your local vendor and/or club? Obtaining the motor for your cert (and any subsequent flights) is between you and the vendor. Each vendor has his or her own policies, so only the vendor can advise you on what they require. Many vendors and/or clubs have arrangements available to assist flyers who don't have a LEUP, and if you really want a LEUP, they can help you with that too.
Well, the problem with that is, the "actual law" isn't always very clear, and even when the law is clear, ATF's "interpretation" of it may still contradict the actual law. In some cases they have policies which are not even internally consistent. For instance, the ATF will tell you that ALL rocket motor igniters are regulated explosives requiring a LEUP and storage. Yet they are not requiring LEUPs and storage for Estes igniters, and there is nothing in the law nor the ATF policy that justifies or explains this discrepancy.
Frankly, I'm getting a little suspicious of these recent, often anonymous, posts in various rocketry forums asking about things that are better kept between the vendor, buyer and/or local club. Why on earth would anyone come here to ask what is required for purchase or use of high power motors, instead of asking their vendor or local club? Perhaps it's really just an ATF fishing expedition.
Until the court case is finalized, there are very few if any "clear answers". TRA/NAR can tell you what the law says, they can tell you what the judge says, and they can tell you what they think it all means. But they are not the ATF, and the ATF has their own ideas about these things.