[F-FT] RMS delay question/comment

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In article snipped-for-privacy@corp.supernews.com, Jerry Irvine at snipped-for-privacy@gte.net wrote on 4/8/05 10:40 AM:
That's bogus, and has nothing to do with the "DOT, CPSC, NFPA and the national user groups", other than incorrect and inflammatory reporting by HPR.
I'm offering the following for the benefit of users and dealers who are finding themselves under attack from the ATF...I have received two calls today from individuals (a dealer and a consumer) who appear to be targets of a recent "crackdown" by their ATF inspectors.
The ATF did not regulate or attempt to regulate non-detonable rocket motors of any size and in any manner prior to 1994 (see "ATF Communiqué 4-25-94").
The original ATFE exemption at 27 CFR 55.141 (a) (7) allowed "Toy Propellant Devices" (an old DOT classification that applied to all AeroTech 62.5 gram per grain and smaller reload kits) to be sold without permits and with no restrictions on intended use (such as when used together in a multiple grain motor). See "ATF Exemption Paper Trail". Not to mention the "Propellant Actuated Device" exemption at 27 CFR 55.141 (a) (8), with NO weight limits.
In 1994, the ATF began to express a view that its rocket motor-related exemptions only applied to motors containing less than 62.5 grams of propellant. Eventually they denied that the "Propellant Actuated Device" exemption ever applied to rocket motors at all. That left the "Toy Propellant Device" exemption as the only one that applied to rocket motors.
In 1998, the ATF re-wrote the "Toy Propellant Device" exemption to replace the old Class A, B & C DOT terminology with the new UN standard. Unfortunately, the ATF inadvertently left out the equivalent UN numbers for hobby rocket products that were previously exempted. AeroTech notified the ATF of this error (see "A-T to J. Zamillo 11-4-99") and the ATF responded stating that they had made a mistake and that they would "amend the regulations to reflect this exemption". See "Letter From ATF 1-13-99". The ATF even sent a memo to all their division directors stating that:
"no enforcement action is to be taken regarding the importation, distribution, and storage of the following explosives...
2. Model rocket motors classified by the U.S. Department of Transportation at 49 CFR 172.101 as UN0349, UNO351, UN0471, NA0276, or NA0323; consisting of ammonium perchlorate composite propellant, black powder, or other similar low explosives; containing no more than 62.5 grams propellant weight; and designed as single use motors or as reload kits."
See "ROL ATF News 1-21-99". The UN numbers listed included all AeroTech model rocket motors and reloads and all "Easy Access" high power reload kits.
Things remained fairly stable until August of 2002, when the ATFE published an "opinion" in their newsletter that asserted that multiple 62.5 gram grain motors were now regulated:
"ATF does exempt from control sport rocket motors and rocket-motor reload kits containing small amounts of APCP or other similar explosives, however this exemption applies only to rocket motors containing up to 62.5 grams of propellant and to rocket motor reload kits whose contents cannot be utilized to produce a rocket motor whose total propellant weight is more than 62.5 grams. The 62.5-gram exemption does not extend to reload kits that can be used to create motors containing more than 62.5 grams of propellant or to propellant modules of any weight that are not part of an exempted reload kit."
"In the near future, ATF will engage in rulemaking to solicit comments on the continuing use of the 62.5- gram exemption threshold. Persons having specific inquiries regarding ATF¹s regulation of sport rocket motors should contact the Public Safety Branch in ATF Headquarters."
ATF "policy" is not law. Clearly the ATF is breaking federal law by inferring that any "policy" is law, as determined by the judge presiding over the NAR/Tripoli vs. ATF lawsuit (see the "Memo of Opinion 6/24/02" by Judge Reggie Walton), without observing the statutory notice-and-comment period. The fact that the ATFE has initiated rulemaking proposing to restrict its rocket motor exemptions to 62.5 grams loaded weight (see below) is ample proof that the earlier exemptions do not restrict the total motor weight.
It is also DOT "policy" to require new facilities of the holder of an EX-number to be inspected, or product made there tested, or both, prior to shipment of any product manufactured in the facilities. You can search all day in 49 CFR...but that is not a law either.
In January of 2003, the ATFE published a proposed rule (NPRM), including a new exemption for "model rocket motors", written in a manner to restrict the exemption to those motors that have a loaded weight of no more than 62.5 grams:
"(v) Model rocket motors consisting of ammonium perchlorate composite propellant, black powder, or other similar low explosives; containing no more than 62.5 grams of total propellant weight and designed as single use motors or as reload kits capable of reloading no more than 62.5 grams of propellant into a reusable motor casing."
This was the first time that the ATF made an effort to legally change the rocketry-related exemptions. From our perspective, the fact that the ATFE has initiated rulemaking proposing to restrict its rocket motor exemptions to 62.5 grams loaded weight is proof that the earlier exemptions do not restrict the total motor weight.
The NPRM is still in the comment evaluation phase and is not yet law. There is no estimate when the process will be completed, especially in light of the ongoing litigation between the ATF and the national user organizations.
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Gary/RCS
Reply to
Gary C. Rosenfield
perspective.
You've proposed nothing but delusional fantasy and self-serving propaganda.
Reply to
raydunakin
This link makes reference to ATF and specifically your nationally distributed display ads coining the terms "easy access"-sm and "restricted access"-sm which were used to refer BY NAME to BATFE treatment.
There are no such terms in 27 CFR or BATFE parlance and never were. Further per your own admission today per 27 CFR 555.141-a-8 ALL rocket motors of any mass are exempt.
Thus those display ads "poked a sharp stick in the eye of the ATF".
Jerry
snip of excellent and highly useful references put into an executive summary.
Reply to
Jerry Irvine
In article snipped-for-privacy@corp.supernews.com, Jerry Irvine at snipped-for-privacy@gte.net wrote on 4/8/05 1:53 PM:
The link is anecdotal and proves nothing.
Yes, but the paper trail is not as bulletproof as the a-7 exemption.
Nope, "Easy Access" was simply a way for AeroTech to differentiate those high power products that ATF representatives admitted were UNREGULATED under the a-7 exemption during the 1994 NFPA meeting in SLC. They fully understood the concept. In fact they stated that they would only have an issue with it if someone were trying to "make an 'O' motor out of 62.5 gram grains". We told them that a 'J' motor was probably the practical limit and they had no objection to that.
If the ATF didn't like the ads (and I've seen no direct evidence to prove that claim) then I'd say we were double-crossed.
You will come around to the truth, eventually. :)
Gary/RCS
Reply to
Gary C. Rosenfield
No, you're right. It is more so.
Here's the law that shows that:
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.
Thereby buying into and adding to the KNOWN confusion.
How can you deny that?
Therefore you openly admit to FORSAKING 27 CFR 555.141-a-8, thus making you even more evil than I have proffered and proven.
The HUGE expenses of the lawsuit prove my point.
If only "anecdotally".
Jerry
Reply to
Jerry Irvine
In article snipped-for-privacy@corp.supernews.com, Jerry Irvine at snipped-for-privacy@gte.net wrote on 4/8/05 4:43 PM:
Snipped from earlier message:
I knew it wouldn't last.
Gary/RCS
Reply to
Gary C. Rosenfield
Wait - Jerry's company was the manager of a consultant who taught Scotty and the rest of the Star Trek crew all about anti matter. Of course the company had less than two employees.
Reply to
Phil Stein
Different topic.
You and TRA clearly led the way INVITING ATF into HPR.
You by having your vendors require ATF permits for transfer of ANY goods (contrary to law), and TRA for demanding ATF permits prior to motor cert (contrary to law).
Both were AFFIRMED as unnecessary by a judge when deciding a lawsuit on the obvious.
Here's the JUDGE's words verifying it.
"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."
Here is the court order that is from:
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Just factual Jerry
Reply to
Jerry Irvine
In article snipped-for-privacy@4ax.com, Phil Stein at snipped-for-privacy@ArielSystems.spamsks.net wrote on 4/8/05 5:20 PM:
I guess I'm just an optimist.
Gary/RCS
Reply to
Gary C. Rosenfield
If you wouldn't define "truth" in your own image (idolotry) you might find yourself pointing your open mind in yet another direction and allowing yourself to be convinced of others' views on some topics.
Such as reducing (self-imposed) rules limiting consumer access.
I hope we --can-- agree we could all do with 4x as many customers.
or 20x.
Jerry
Reply to
Jerry Irvine
Irvine
Jerry Irvine
exemption.
manufactured,
But as you are well aware, the ATF's current position is that sport rocket motors are not PADs.
Reply to
raydunakin
No one invited the ATF.
What law? There's no law that says they can't do that. Nor is it clear that manufacturers and vendors of PADs are exempt from ATF permits either. As you've been told before, the ATF requires permits for manufacturers of other materials that have exemptions, such as smokeless powder and BP.
That's only a fraction of the story, as you well know. Here's some more of it:
"ORDERED, that the plantiffs' request for the Court to (1) order the ATF to recognize sport rocket motors as propellant actuated devices and (2) order that the Question and Answer sheet currently posted on the ATF's website either be removed or revised are DENIED. It is further ORDERED, that the parties shall proceed with the litigation of this case as previously scheduled by the court."
That's from the October 2004 ruling.
We won't find out the rest of story until the lawsuit is fully concluded.
i
Reply to
raydunakin
You for got not having to drop off film, then remember to pick it up.
My wife and I have rolls of film that are over 18 months old that we keep forgetting to take in to get developed. Don't have that problem since we went digital in late February.
If you're moving to an SLR, it's also easier to learn -- I can take a picture, check the result, adjust settings, and keep going doing that until I get the results I want. With film, I have to write down detailed notes, get it developed, then check.
Since much of what I do is electronic anyway, I also don't have to scan, or pay someone to do it for me.
-Kevin
Reply to
Kevin Trojanowski

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