A Simple Yes or No would be nice

No Ray...

Nailgun=rocket (no restriction from the fed to buy/build/own) Cartridge=holder for multiple motors (say, to hold a cluser of three motors) (same as above) Cartridge charge= rocket motor (the part you can only get assembled without the feds OK) Nail = thrust out the back (legal in all states, by anyone!)

I think I understand what Jerry means by "living the lifestyle": suppose the BATF does propose a new rulemaking, and after due notice, comment, and publication, it comes to be contested in court (as can be done between the publication of a "final rule" and its effective date): a claim against a new rulemaking (i.e., one that somehow excluded rocket materials from the PAD exemption) might carry more weight if it could be argued that the new rule imposed a new and unreasonaple constraint on existing field practice... it might spoil the pitch if the BATF could truthfully claim that the issue was moot because "everybody's been getting permits for the rocket stuff anyway".

-dave w

No bullshit here, sir.

NAR and TRA have little to do with the law unless they continue to poke and prod the beast, which will FORCE the government to define 'the grey areas'.

Hopefully NAR and TRA and the people that enjoy the hobby will realize that 'grey areas' can be a very good thing.

I looked at similar hobby's when I first became aware of the legal positions... it would be EXTREMELY easy to equate 'fireworks' and 'rockets'... or to a myriad of other activities that 'should' require regulation.

We don't need further defintions or clarifications. Precedents are already in place to curtail Amatuer and HPR.

Let sleeping dogs sleep...

Hmmm... seems to be some cross-talk here.

I subscribe to a lifestyle that says "ANYTHING GOES UNLESS EXPLICITLY PROHIBITED".

And even then... I would ask what the definition of 'is' is. ;)

You don't want them to define what a 'tool', 'mechanized device' or what 'work' is, do you?

If we keep pushing... they WILL define it for us... and I promise the definition of 'WORK' won't include launching a Rocket.

Not convinced.

We need to quit poking the beast. NAR and TRA need to quit poking the beast. Do what you believe is legal. Argue your case in court if you have to...

So do I. However, the ATF has insisted that rocket motors were not PADs, and thus were not exempt from regulation. So TRA/NAR took them to court and got a judge to correct the ATF.

I don't know. Maybe they were told to be precise, and are telling only, exactly, what was said. Maybe they or their counsel feel that this aspect must be further researched. Maybe there's some other reason.

I'm no expert. But if you can show me where people are required to have an ATF permit to buy either cartridges OR reloads for PADs or PAITs, please do.

Do you see the word "cartridges" mentioned in the PAD/PAIT definitions?

So you're saying that a nailgun is NOT a PAIT? Is that your opinion, or ATF's? If it's the ATF's position that nailguns are not PAITs, please show me where they say so.

You buy a nailgun "fully assembled". You also buy cartridges separately from the nailgun. The judge said that "fully assembled rocket motors" are PADs. That makes them equivalent to nailguns (PAITs) or other reloadable types of PADs, right? If that's not right, please provide a specific reference.

If I'm right, and a nailgun IS a PAIT, and a rocket motor IS a PAD, then it stands to reason that a reload is comparable to a cartridge.

Like a cartridge, reloads have been designed and fashioned specifically for the purpose of being loaded into a PAD ("rocket motor"). You seem hung up on the fact that nailgun cartridges are cased in metal. That fact alone doesn't make them a "device" or "tool", nor does it make them essentially different from a reload. A reload is contained in a paper or phenolic casing. Do you know of any specific regulatory language that states that PAD/PAIT cartridges must be contained in a metal casing?

I think this might be a way around the 'bag o' grains' problem.

If that bag o' grains were put into a metal cylinder with light gauge screw-on endcaps at both ends, one of which would sport a small hole, you'd have a device which would fully fit the definition of a 'fully assembled (low-pressure) rocket motor'; though it would be a very, very lousy one and, if it ignited, the head end cap would probably blow off and the grains would just burn up. Yup, it would be a truly suck-ass, LOUSY rocket motor, but it still would fit the definition of a rocket motor. Now, if you had your druthers would you rather be in a room with THAT thing igniting, or the same grains in a proper reloadable going fully propulsive? Safety first, now!

Seems like a box of those low pressure things would be far less of a hazard in an accidental fire than a box of loaded reloadables catching fire, which would likely go propulsive. The first one of THOSE that flew into your face at 400 mph would make a lasting impression on you. But wait, ....THOSE are perfectly ok! See my point?

So, that miserable 65psi "motor" would serve as sort of a ....one COULD consider it a "storage container for grains" (thus eliminating the ugly and allegedly dangerous 'bag o' grains'); which under normal circumstances would likely be transferred to a full-up reloadable; however, it COULD be demonstrated that the 'storage container'/rocket motor *could* develop enough thrust to get airborne, ....or NOT. Who says it has to be a 'well-engineered' rocket motor? I'm not aware that BATFE has written the specs on the minimum operating pressure a rocket motor must develop. (Please enlighten me if I missed this.) Suppose you can prove that the 'low pressure motor'(storage container) is inherently SAFER that the loaded high pressure reloadable? Out at the launch site, you're presumably free to, say, move grains from one motor to the next. Let me just speculate that ....most of those grains would wind up being transferred into the "less safe" but already BATFE-blessed high-pressure reloadables.

regulations....

Woody, by this logic a nailgun is not a PAIT, and a rocket without a motor is a PAD. You're saying that "Propellent Actuated Industrial Tool" applies to cartridges, and not to the actual tool they're used in!

The nailgun is the propellent actual tool. The cartridges are the propellent. The nail is what the nailgun applies force to.

Similarly, a rocket motor is a propellent actuated device -- the statement you keep quoting even says so! The rocket is NOT a PAD, the motor is the PAD! PAD = "Fully assembled rocket MOTOR".

If the motor is the PAD, then the reloads are like cartridges. The rocket itself is merely the object to which the PAD applies force.

No.

Or you could read and understand the obvious instead.

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.

I do rightly understand that for you Fred, that is indeed a problem.

Jerry

What is it about the name Fred?

PRECISELY.

Gold star!

And waste your time yet more and in diverse ways?

Don't bother.

Maybe they are adopting Jerry's philosphy and want to just "live the life style" instead of forcing the issue. ;)

Which is exactly what has happened. Rocket motors were considered exempt, and there was no requirement for LEUPs. Then the ATF changed that position, imposing a new and unreasonable constraint. It took a court order to reverse that.

Except that "everybody" hasn't been getting permits. Only a small percentage of rocket hobbyists have LEUPs.

Besides, the only other option would be to wait until the ATF busts someone for not having a LEUP, and let the poor sap get dragged through the legal system alone only to end up with (at best) the same partial victory we have now.

Jerry replied:

Oh, are you disagreeing with my assertion that reloads should be treated as exempt components of PADs?

I doubt he'd be alone... you rocketeers seem to stick together.

News of a fellow Rocketeer being busted for such idiocy would have you all up in arms within minutes of the arrest... and the 'what can we do to help' attitude would permeate the group.

SU motors = Yes Reloads = ?????

Bad extrapolation...

You know as well as I do that many walked away rather than getting a permit. Wonder if they'll come back.

Regards, Andy

I'll be telling our folks:

SU = Yes Reloads=Yes.

The components are useless for anything else without ridiculous extrapolation.

Regards, Andy

NPRM 968 has yet to become a final rule ... it's in trouble with the Small Business Administration and the explosives industry as a whole, it covers a lot more than just rockets.