[Planet News] ATF publishes final rule on model rocket motors

WASHINGTON, District of Columbia USA - The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) published in the Federal Register today a final rule that amends the regulations to clarify that the requirements of 27 CFR Part 555 do not apply to model rocket motors consisting of ammonium perchlorate composite propellant (APCP), 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.
The final rule is intended to provide rocketry hobbyists with guidance to enable them to enjoy their hobby in compliance with the safety and security requirements of the law and regulations. ATF is the federal agency with jurisdiction for regulating the explosives industry, enforcing the Safe Explosives Act and investigating explosives incidents. More information on ATF and its programs is at http://www.atf.gov .
Contacts: Andrew L. Lluberes/Sheree L. Mixell Telephone: 202-927-8500

You may also want to note http://www.atf.gov/press/fy06press/081106pad_amendeddefinition.htm .
Anthony J. Cesaroni President/CEO Cesaroni Technology/Cesaroni Aerospace http://www.cesaronitech.com / (941) 360-3100 x101 Sarasota (905) 887-2370 x222 Toronto
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Interesting:
"..., or other similar low explosives. Such motors and reload kits would be subject to all applicable federal explosives controls pursuant to federal explosives law, the regulations, and applicable ATF policy."
Could this be an easy follow onto hybrids and other launch systems? Possibly they may view the weight or whole of the gas and plastics, as an "assembled device of potential explosive behavior"... etc... or further challenge the use of metal enclosures or containment also...? So no matter what is used, "similar" might by construed as a legal quip for any desired control of any method... even if the substance does not technically classify as a low explosive.
Because it states "motors" and "reload kits", it is focusing on method of use, and thrust, not explosive power. So one can store a bunch of <62.5 gram sizes, as long as it is not combined to give more thrust. I do not understand how it can go from explosive substances to thrust combinations. What does that have to do with "explosives" law? What happens when a weaker mixture of APCP is used that cannot be classified as even "low explosive"? Composition levels are not being defined. So instead, they have now further made legal, those compositions that would be highly volitile and dangerous to handle, but remain <= 62.5 grams, as long as it is intended for "hobby rocketry"?
Notably missing are explicit standards for defining explosives; as such everything can be, and is explosive. The message is, "The little toys are OK, but the big stuff is scary and not well understood, and so you must be deemed safe if you want to use it."
However, those who will use it for wrongful purpose will do so anyway, and not abide self restraint, let alone the ATF rules or the explosives laws. It doesn't seem to make a lot of sense, but what can you do?
~ Duane Phillips.
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APCP is on the explosives list. No components of a Hybrid motor are on the explosives list (at least not those which use non-pyro ignition). Aside from the lack of science, putting PVC pipe on the list would be pretty funny and putting N2O on the list would draw the wrath of the Hot Rod community.
They may be able to claim that an assembled, fueled, motor should be regulated but since all commercial hybrids currently available are vented ones they aren't fueled until right before use - there is no storage or transportation to speak of.
Ejection charges still present a problem. We can joke all we want about how our use of BP falls under the cultural or recreational firearm exclusion but I doubt that would stand up in court. The PAD exemption might qualify for fully assembled charges but not for bulk BP.
Duane Phillips wrote:
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The problem is, the phrasing...
"or other similar low explosives"
This does not say "what is on the list", nor can I take if for granted that is inferred. Add to that *any* concern given for a "thrust" combination, and we've now been limited in configurations instead of explosive policy, that has nothing to do with the original intext of explosives control in the first place. In other words, there is no storage or transportation *being* spoken of here. In other words, it appears that it does not matter as much how many < 62.5 you transport and store together, only that you don't have a long range rocket without being *known*.
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Duane Phillips wrote:
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Are you saying that plastic pipe and N20 are low explosives, and that they are "similar" to APCP?
Let's not make things out to be worse than they are. The phrase "similar low explosives" can't possibly be construed to apply to inert materials that can be combined to form a propulsive device.

I am saying if any other method becomes widely available and used, I believe it too will be onerously regulated.
APCP, in the solid form our community uses, is not explosive. No specifications for composition levels are listed, so *any* AP content automatically drags it into the class. With the verbage "or other", with no further limiter defined, leaves it wide open... legally it is a catch all phrase.
In practice, they do not currently regulate in that manner. Without a "win" in the courts on the APCP issue to set a precedence, however, the whole "field" will go to the mercy of your local agent, abitrarily, ambiguously, and permanently.
Right now the focus is on solid composite propellants, because they are the most widely available and used.
If you disagree, then please explain why anyone at all would care if we stack grains, especially on reloads, which are shipped outside of their intended enclosure, and pose no explosive threat? I personally can understand some regulations on manufacturers, as they deal with the powdered and raw elements that are significantly more volitile.
But the regulations as written are limiting thrust and configuration, not explosive power.
For example, I believe a lot of people would agree that a BP motor in HP class would be a little scary. It's BP. So we found a different method that gives far better thrust-to-weight, and is fundamentally less explosive in solid form than BP. So what are they regulating? Rockets... under the guise of explosives.
Nothing short of a court ruling in our favor on at least one flavor will stem that mis-direction of control. Otherwise the "safe" form is permanently labelled as MODROC. All others will be identified and inspected.
~ Duane Phillips.
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Duane Phillips wrote:
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No, read the entire explanation. Congress directed the ATF to publish a list of explosives. They did. They put APCP on it. Congress gave the ATF the responsibility to regulate everything on that list. That's what they are doing. Their story hasn't changed much in the 10 years I've been watch it.
PVC is not on the list. I would hope the plumber's union would get a little upset if it appeared. Until then, PVC can not be regulated as an explosive.
Getting APCP off the list is our only chance of temporary relief. Getting Congress to write an exemption into law is the only permanent solution. Any wagers on how soon that would happen in today's environment?

Again, then why do they regulate the stacking of grains?
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Duane Phillips wrote:
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By law they can regulate any amount of APCP. They're just being "nice" and allowing under 62.5g to be unregulated. They regulate the stacking of grains because we found a loophole and it took them more than a few years to close it.
Remember, this is the Government - it doesn't have to make sense.

Alex Mericas wrote:
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Then we should drop the lawsuit, apoligise and send in our fingers?
Well, I disagree. The laws do have to make sense, and rules can't be arbitrarily changed ("calvinball").
Glen Overby

How is that a loophole? You can still *have* many more than one of those on hand. Making a stacking limit is pure regulation of rocketry, not explosives. Regulation of the explosives is just the method.
Why else would they *attempt* to prove HP hobby rockets bad by trying (and failing) to shoot them at a drone?
Make no mistake, it is all about the rockets. They cannot control altitude, that is FAA territory. CPSC cannot control it either. The FAA's structure does not allow it to inspect one's life and deem one safe. Relying on various states to do so is mighty unweildy. Police are too local, and focus primarily on standard civilian issues, not to mention the local heat they would take for irregular inspections of private quarters.
Consider other branches or governmental organizations. So what organization do you have left?
Consider also:
We see on the news how a certain factions shoot unguided stuff indiscriminately into Israel or other contested areas. Such is also heard of elsewhere.
62.5 grams is not enough to get far enough with any kind of damaging payload, without going through some heavy configuration hurdles. You can knock out with a sniper rifle the guy who tries to do so.
Almost all other current lofting methods of significant power are either cost restrictive or take too much science and knowlege, or ground support equipment, to assemble, and would require more involvement from more people... not just your sideline average "I will die for you" personality.
All the rest of the "rocketry" parts can literally be made by almost anyone out of anything, and are completely untrackable.
So we are left with 2 common denominators...: the bureau and and motors.
New rocketry legislation would have take literally years to pass. Heightened explosives control slipped through pork barrell style piggy-backed on the Patriot Act, after being formerly rejected twice when it stood on its' own.
In this case, it is all about the rockets... not the explosives. Explosives control, in this case, is the vehicle, not the destination.
Without a significant court win on APCP, everything else follows that becomes as widely accessible as APCP currently is.
Remember, this is the Government - it doesn't have to make sense... to everyone.
~ Duane Phillips.
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Duane Phillips wrote:
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Please cite. There is no evidence this ever happened. It is an urban myth. And I mean verifiable data, not some posts on RMR or a quote from someone who talked to someone who was there. I know someone who knows someone who was abducted by a UFO. Seriously.

I with-draw that sentence, as I have been unable to verify it. My apologies.
But there are others that I can put in place of it:
You're skipping the whole major scope of my point.
So your answer is apparently, "oh well."...
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Duane Phillips wrote:
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IIRC, stacking is a limit of the state of the art. Somebody mentioned that grain stacking quits working when the l/d gets to something like 17:1? Can't remember but it's probably googable. The burning fuel under g-loads starts schluffing.
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That is good infomation.
However, the rule does not state how many grains you can stack, only that the combined total weight is under the specified limit.
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You buy a mini H, or a big G, for that matter (HPR G, as these do exist) and if the propellant weight is over 65.5, it's regulated in a few weeks.
"Easy Access" had 62.5 g grains, but that's gone (in OCT) due to the rule.
I'm surprised how many posters here don't have a clue as to the history of the whole mess, and are now making bogus (uninformed) statements.
No wonder that the "self regulation" aspect of TRA and NAR is in question, as it's clear that many newbies don't understand the "self regulation" that was in effect in 2000!
62.5 was in effect for almost a decade, but AT (the one in Vegas, not to be confused with the one in UT!), got an exception, that everyone else used. That exception is gone.
The world changed on 9/11 for things like hobby rocketry, and many here are voicing the same issues that folks did pre-9/11, but it's got even less of a chance now...
Get a LEUP, a LEUP with storage elsewhere, or sign on to the club LEUP.
I know it's a bitch, as I had (keyword is HAD) an LEUP that expired in June. There was NO WAY I could store a mag in my city, and my "contingent storage" is gone (and he charged for getting/storing a reloaded each time).
I've said for a long time, that the money spent on the legal battle would have been better spent on getting NAR clubs and TRA prefectures to set up legal storage available to club members, and view this was even prior to 9/11, the "Patriot Act", and the "SEA"!
Not the same world today as the one that existed pre 9/11, and the legal battle has been going on prior to that.
Face it, as we now hear day to day about "rockets" being launched across borders.
Duane Phillips wrote:
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I hear you. 'Tis what I fear... Who knows what this fall will bring. I hope... but...
Cheers!
~ Duane Phillips.
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Please try to find it. I have not seen anything on g-load limits for segmented propellant grains. However, long skinny motors are more espousing, heavy, etc. Average thrust gets high, but as long as the optimal nozzle exit diameter is not greater than the motor diameter, things should be OK. The real problem is that it just does not work with large 4" motors using thin 62.5 gram grain segments.
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Not even that is safe. As I read the latest rule, it uses the CPSC definition, regulating anything over 62.5g or 80 NS. that makes even a G motor regulated.