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

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Anthony J. Cesaroni President/CEO Cesaroni Technology/Cesaroni Aerospace (941) 360-3100 x101 Sarasota (905) 887-2370 x222 Toronto

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

With the final rule on 62.5 per motor (not per grain) now final, at least in the short term, there seems to be no "easy access" any more.
The proposed rule on PADs seems a logical next step for the BATFE to take, as the lawsuit could go on for some time yet (what ever side loses, will probably appeal).
Anth> You may also want to note

This doesn't match the statement on the BATFE web site, or the 7-Aug federal register publication:
"WASHINGTON The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) published a PROPOSED rule in the Federal Register today to clarify that hobby rocket motors are not propellant actuated devices, due to the nature of their design and function. Therefore, hobby rocket motors are not covered by the exemption such devices have from the requirements of Federal explosives law and regulations."
Per the Federal Register, this is yet another PROPOSAL with a COMMENT PERIOD that runs for the next 90 days. I don't see anything there about a final rule. It's a revision to one part of their NPRM from January 2003, and is not a final rule.
And it's yet another example of JBGT arrogance. These folks are domestic terrorists and should be arrested and jailed.
Bob Kaplow NAR # 18L >>> To reply, there's no internet on Mars (yet)!

Bob,
One is a final rule:
One is a NPRM:
Two separate CFR publishings by BATFE.

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:

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*.

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.

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?

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.

Again, then why do they regulate the stacking of grains?

Exactly.
Make no mistake... the control is over the perceived safety level of rocketry, not the explosive power, but the tool of current argument is APCP. If this is not set right... a testable (and has been tested) non-explosive composition, then the boding is not well for the future.
On the other hand, I would and do still enjoy MODROC, but I don't want to have to become papered and inspected just to enjoy a harmless hobby above that level. Sadly, HP will be limited to the rich and the few. Most of us are lucky to get a couple HP launches off per year. Those extra hurdles just makes it all the more co$tly to even want to deal with it... but that's the whole point, right?
Cheers!
~ Duane Phillips.

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.

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.

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."...

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.