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
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Contacts: Andrew L. Lluberes/Sheree L. Mixell
Telephone: 202-927-8500
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:
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"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)!
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.
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.
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