pros and cons list for Pro38 and Aerotech engines.

Ask Dick Embry @ TRA as well as Mark Bundick at NAR (given already)

But once they were "NFPA compliant" they would then be compliant in all

50 states. All non-NFPA states, and all NFPA states (perhaps except CA).

You'll be very welcome.

Yes, all USR has to do is take one of their certified motor production lines to another facility and run the line there such that they have control of the production. Or they can have the manufacturer certify the motors and stick their name on it.

Those would be two reasonable actions to balance a manufacturer's catastrophe against public safety.

Joel. phx

all very well said, Shockie

- iz

shockwaveriderz wrote:

Maybe in the UK storage and permits are easier to get then they are over here? I doubt there would be much complaint here if the permits were cheap, simple and readily available.

if in your AER rocketry activities your rocket meets the definition of a "High Power Rocket", then its motors must be certified as per NFPA 1125

NFPA 1127 - Code for High Power Rocketry, 2002 Ed. (excerpted for editorial review)

first lets make sure the code applies:

1.3 Application. This code shall apply to the design, construction, limitation of propellant mass and power, and reliability of high power rocket motors and motor components produced commercially for sale or for use by a certified user for education, recreation, and sporting competition.

1.3.1 This code also shall apply to the design and construction of high power rockets propelled by the high power rocket motors specified in Section 1.3.

1.3.2 This code shall apply to the conduct of launch operations of high power rockets specified in 1.3.1.

1.3.3 This code shall not apply to the design, construction, production, manufacture, fabrication, maintenance, launch, flight, test, operation, use, or other activity connected with a rocket or rocket motor where carried out or engaged in by the following entities:

(1) National, state, or local government

(2) An individual, a firm, a partnership, a joint venture, a corporation, or other business entity engaged as a licensed business in the research, development, production, testing, maintenance, or supply of rockets, rocket motors, rocket propellant chemicals, or rocket components or parts

(3) College or university

4.5.1* Only certified high power rocket motors or motor reloading kits or motor components shall be used in a high power rocket.

alot to say its does, and nothing to say that it doesn't

ok, so when is my rocket a "High Power Rocket"?

3.3.15.1 High Power Rocket. A rocket vehicle that (1) is propelled by one or more high power rocket motors; or (2) is propelled by a combination of model rocket motors having an installed total impulse of more than 320 N-sec (71.9 lb-sec); or (3) is propelled by a combination of model rocket motors having more than a total of 125 g (4.4 oz) of propellant weight; or (4) weighs more than 1500 g (53 oz) with motor(s) installed.

ok, so when it contains high power motor, or a combination of model rocket motors over a aggregate impulse or propellant weight, or the rocket itself exceeds a weight threshold.

ok, what is a motor a "High Power Rocket Motor" or a "Model Rocket Motor"?

3.3.17.1 High Power Rocket Motor. A rocket motor that has more than 160 N-sec (36 lb-sec) but no more than 40,960 N-sec (9208 lb-sec) of total impulse, or an average thrust greater than 80 N, or more than 62.5 g (2.2 oz) of propellant, and that otherwise meets the other requirements set forth in NFPA 1125, Code for the Manufacture of Model Rocket and High Power Rocket Motors.

3.3.17.3 Model Rocket Motor. A rocket motor that has a total impulse of no greater than 160 N-sec (36 lb-sec), an average thrust of no greater than 80 N, a propellant weight of no greater than 62.5 g (2.2 oz), and that otherwise meets the other requirements set forth in NFPA 1125, Code for the Manufacture of Model Rocket and High Power Rocket Motors.

ok, when any motor falls within the stated performance or propellant weight thresholds, but it refers to NFPA 1125, so lets see if that changes anything.

NFPA 1125 - Code for the Manufacture of Model Rocket and High Power Rocket Motors, 2001 Ed. (excerpted for editorial review)

3.3.26.2 High Power Rocket Motor. A rocket motor that has more than 160 N-sec but no more than 40,960 N-sec of total impulse, or that produces an average thrust of greater than 80 N, or that contains greater than 62.5 g (2.2 oz) of propellant.

3.3.26.4 Model Rocket Motor. Arocket motor that has a total impulse of no greater than 160 N-sec, an average thrust of no greater than 80 N, and a propellant weight of no greater than 62.5 g (2.2 oz).

nope, this doesn't add anything.

so as long as my rocket exceeds a certain weight, OR contains motors whose aggregate performance falls within specified thresholds, OR contains motors whose propellant weight exceeds certain thresholds, it is a "High Power Rocket" regardless of its construction, materials, origin or certification status.

and furthermore, it cannot be sold or used by anyone other than a certifed user:

NFPA 1127 - Code for High Power Rocketry, 2002 Ed. (excerpted for editorial review)

5.1 Sales Only to Certified Users. A high power rocket motor or motor reloading kit shall be sold to, shipped to, stored by, and used only by certified users.

yes, only

8.1.3 Model rocket motors, motor-reloading kits, and components offered for sale, exposed for sale, sold, used, or made available to the public shall be examined and tested to determine whether they comply with the standards and requirements detailed in 8.1.7.

8.2.3 High power rocket motor, motor-reloading kit, and components offered for sale, exposed for sale, sold, used, or made available to the public shall be examined and tested to determine whether they comply with the standards and requirements detailed in 8.2.7.

in any NFPA state, no motors meeting the criteria for "Model Rocket Motor" or "High Power Rocket Motor" may be sold or used unless they are certified by TRA, NAR or any other recognized authority of which their are currently zero.

sorry, but it's true (see above)

as long as they have a certification monopoly they do

as long as their collective vote outweighs any future organization on the NFPA Pyrotechnics committee they do

it is improbable that any third certification body would be recognized by the NFPA or AHJ if the current monopolists oppose it

sorry, but that is true, unless and until an alternate certification authority is recognized by the NFPA or AHJ (see above)

I think recognition of such an alternate authority unlikely if opposed by TRA/NAR, unless the SFM promotes it in the Pyro committee. But yes, it's theorectically possible but decidedly not the case today.

there is no alternate certification authority at present, or in the foreseeable future

other than to the extent that TRA/NAR are successful in conributing to certification requirements

yes

1. they prohibit certification of motors whose propellant whose hazard class is "unregulated"

1. they are arbitrary in their stipulation of who is an acceptable testing authority for the purpose of determining hazard class

theoretically, yes. Are they equipped (and willing) to do so, and who would fund it? you are talking about a supposition, not reality. The reality today is that TRA/NAR hold monopolistic control over all motor manufacture, sale and use in NFPA states for motors meeting the definitions provided in NFPA 1127 (and 1125)

NFPA states that the certification authority must be one whicb is recognized by the AHJ. Suppose you have a state that happens to recognize a facility, will other states recognize the same one? How many different facilities and tests will be required to satisfy all 50 states.

those certification authorities specified by the NFPA (of which only TRA and NAR are at present) automatically enjoy acceptance in all NFPA adoptive states.

so in a practicel sense, yes, a case can be made for restraint of trade.

- iz

Is it? Hasn't Jerry been selling motors to amateur flyers all along? Is he not currently selling them?

I think it might be more accurate to say that the NFPA feels that way, not NAR/TRA. I don't think NAR/TRA give a hoot what non-certified manufacturers and flyers do outside of NAR/TRA launches.

I believe that's always been the case. NAR/TRA simply provided a legal mechanism through which people could enjoy rocketry without having to jump through all the extra hoops needed for amateur rocketry.

Don't be ridiculous. If that were true, Thiokol would be unable to make commerical motors for sale to NASA or corporate launches.

in practical terms, this is a fallacy because AHJs are like an onion - they encompass and supersede one another (sometimes in either direction)

in order for a recognition by an AHK of an alternate certification to be effective, that AHJ must have overriding authority.

in New Yoik, for example, New Yoik Sidy supersedes New Yoik State. But outside the city, Nassau County, for example, must have regulations as strict or stricter than the New Yoik State SFM - unless a local variance is issued.

I can't, as a land owner whose girlfriend is an insurance inspector declare my brother a certification authority and any motor he "certifies" be legal under NFPA rules (in an NFPA adoptive state).

The SFM or county fire marshall will have me fined or worse, because he has overriding jurisdiction.

- iz

This is a crock. As you have noted, it is possible to do amateur rocketry outside of NAR/TRA venues. Yes, there are more legal requirements that must be met to do that legally, but that has always been the case. It is not the result of some evil conspiracy. NAR/TRA have simply provided EXCEPTIONS to those restrictive amateur rules, under which model and high power rocketry can be conducted.

Again, this is a crock. There are major commercial rocket motor manufacturers who do business daily without any involvement or interference by NAR/TRA. NAR/TRA only restrict what can be used at their launches under their rules.

Who says?

Correct. And NAR provided a legal means for people to engage in model rocketry without the restrictions that were ALREADY in place on rocketry in general. The NAR did not create those restrictions, they worked with the authorities to create an exception to the restrictions. And that's what TRA did later for high power rocketry.

I think it was more the other way around. Amateur rocketry was already perceived as dangerous, and NAR used motor certification as a means of proving that model rocketry was not dangerous. I do think that they eventually pushed the "basement bomber" thing too far though, but that's a separate issue.

Wrong. They can fly uncertified motors as long as they are not at a sanctioned launch AND follow the laws for amateur rocketry.

You seem to think that NFPA = NAR/TRA. NAR/TRA are only a small part of NFPA, with limited influence. If you have a problem with NFPA codes, blame the NFPA, not NAR/TRA.

Wrong. NFPA created the NFPA codes. NAR/TRA only had a small voice in the process, they do not control the process.

Wrong again. It's the NFPA that writes the codes.

Why do you list these as "pros and cons" for people deciding whether to purchase motors from these companies? Exactly how do these manufacturing and shipping regulations affect the end user's decision to buy AT or Pro38?? Oh, and BTW _both_ manufacturers have to abide by DOT rules for shipping.

The biggest effect that regulations have had on manufacturing is in reducing the market (people leaving/avoiding the hobby due to fear of restrictive regulations). That applies across the board to all manufacturers, not just AT.

They haven't _stopped_ making motors! Filing for Chapter 11 has not prevented them from remaining in production.

Yes, lets all just sit back and say "it can't be done" and wine and moan in our beer. Much better than a manufacturer sending some motors to UL and getting an approval, yes?

Joel. phx

No, but you can write who you believe is the authority and ask them for approval. If you're a manufacturer, most likely they will be coming to inspect your facility anyway.

Ok, these seem to be the 2 points (add if I missed any).

There are lots of certified users currently flying certified motors. So this is not stopping anyone from flying a motor certified by a 'new' body. Even if that were not the case, how long would it take that Axxx group to set up a {user} certification body?

The fire marshal is not currently zero. Who has requested information from an insurance agency to determine which lab they would require motors to be tested at? Hmm? No one? Who has asked the BATFE of all people if they would be willing to test some motors? I don't suggest asking for a video though.

This point seems to be basing an assumption that the authority must be recognized by NAR/TRA for some reason. It doesn't. Submit motors to the authority of the state. Request from the authority of the state what an appropriate certification body would be. Describe that the 2 current groups are exceeding 1125 for motor certifications. Ask if UL would be acceptable.

I really fail to understand why we need to keep hashing this out when it's up to a manufacturer to get off their can and make things happen. They're obviously not waiting for the first point. And from what I know, most are simply following the rules of TRA/NAR (not that they like it). So if we're going to point fingers at the "current" situation, how 'bout it be the manufacturers who """bend over""" and those who don't """stand up""" {for themselves}?

Joel. phx

Thanks for the cites, I found 1122, but 27 is buried somewhere.

competition.

organization.

inconsistencies".

Propounded and promoted by TRA!!!

Only Chapter 7 does that.

Since you dispute none of his points with cites or even logic, this post is a crock.

Based on this, EX is illegal in any state that has passed NFPA 112X unless you are one of the above exemptions or unless it is participation in TRA EX and they "certify" the engine before flight. Right?

Bob

We've been through all this before. The manufacturer is supposed to submit the motors and paperwork. Only the manufacturer can verify that they have the proper shipping and manufacturing permits.

Maybe not, but if the manufacturer has gone through the requirements to manufacture and ship legally, he's met the requirements of the certifying orginizations. As long as the motors work most of the time, it's trivial to get them certified compared to getting legal for commercial production.

Tom

Wrong. It won't be a high power rocket and may be under more restrictive laws and regulations. Unless the state has written into it's laws that any non NFPA rocket motor is illegal.

Tom