Re: [FFT] Cert vs LEUP Q


I've been buying 29mm and 38mm easy access motors since they first came out back in 1990. No dealer that I've bought from, including Magnum, Als, Ring, Red Arrow, Microbrick, Rocket R&D, or any one else ever asked for a copy of my LEUP for those purchases.
    Bob Kaplow    NAR # 18L    TRA # "Impeach the TRA BoD"         >>> To reply, remove the TRABoD! <<< Kaplow Klips & Baffle:    http://nira-rocketry.org/LeadingEdge/Phantom4000.pdf www.encompasserve.org/~kaplow_r/ www.nira-rocketry.org www.nar.org
"I tell you, freedom and human rights in America are doomed. The U.S. government will lead the American people in and the West in general into an unbearable hell and a choking life."
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kaplow snipped-for-privacy@encompasserve.org.TRABoD (Bob Kaplow) wrote:

There is no weight or size limit to 27 CFR 555.141-a-8.
Intended use.
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Jerry Irvine, Box 1242, Claremont, California 91711 USA
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bob kaplow said:

I don't think this is correct Bob... NFPA codes consider it HPR if its an H motor, with no mention of propelant weight... ANY HPR model requires a FAA waiver...
shockie B)
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Shockie,
Bob is correct. Read the FAA regulations again.
Sec. 101.22 Special provisions for large model rockets.
Persons operating model rockets that use not more than 125 grams of propellant; that are made of paper, wood, or breakable plastic; that contain no substantial metal parts, and that weigh not more than 1,500 grams, including the propellant, need not comply with Sec. 101.23 (b), (c), (g), and (h), provided: (a) That person complies with all provisions of Sec. 101.25; and (b) The operation is not conducted within 5 miles of an airport runway or other landing area unless the information required in Sec. 101.25 is also provided to the manager of that airport.
Found at: http://www.access.gpo.gov/nara/cfr/waisidx_04/14cfr101_04.html
(note that Sec. 101.25 is the notification requirement)
The FAA doesn't care what the NFPA codes call the motor: model, high power, water, it just doesn't matter. What the FAA cares about is propellant and gross takeoff mass.
shockwaveriderz wrote:

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David W. Schultz
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It's quite correct. FAA regs have nothing to do with NFPA, BATFE, NAR, TRA, or any other rules. A waiver is required ONLY if your rocket exceeds the 1500g or 125g limits. It is VERY possible to build an L1 rocket, or for that matter an HPR rocket flown on an H motor, and fly it under 101.22 notification, as long as the rocket is not over 1500g and the propellant doesn't exceed 125g. We did it all week at NARAM-42, when at the last minute the FAA pulled the waiver that the event had counted on having.
You still have to comply with other terms of the HPR safecy code, such as absurdly large field sizes and safe distances. But you CAN fly some H motors under 101.22 notification.
Motors that are 101.22 legal include the H73, H123 (note these first two propellant weights are incorrectly stated by TMT because they compute it as initial weight - empty weight, which includes liner and nozzle erosion, plus delay and ejection weights), H128, H180, H210, H220, H238, H242, and probably a few I've missed.
    Bob Kaplow    NAR # 18L    TRA # "Impeach the TRA BoD"         >>> To reply, remove the TRABoD! <<< Kaplow Klips & Baffle:    http://nira-rocketry.org/LeadingEdge/Phantom4000.pdf www.encompasserve.org/~kaplow_r/ www.nira-rocketry.org www.nar.org
"I tell you, freedom and human rights in America are doomed. The U.S. government will lead the American people in and the West in general into an unbearable hell and a choking life."
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I stand corrected..thanks for that info..
shockie B)
writes:

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Nope and I am tired of repeating why. Fetch.
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Jerry Irvine, Box 1242, Claremont, California 91711 USA
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david: comments inline
shockie B)
"David Erbas-White" wrote:

This is 100% TRUE and is codified in NFPA 1127....

Ahhh the wonders of self-regulation....

Again it states in NFPA 1127 that you can purchase a single H motor for cert purposes...
And yes, a person could go to dealer to dealer to accumulate a number of H motors But you would be violating your self-regulation....

sounds good to me.....
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beyond
in
heh.
OK, Bit Eimer, I've read through the thread, and I think I can clarify it and at least keep the politics neutral.
The wrinkle you describe has been discussed for years, but it only impacts just a few people in practice. My feeling is that you ought to take the steps along the way, and a single H is technically simpler than a cluster of G's on the field.
You seem to be slightly confused about the nature of the permissions needed. There are three main components: the BATFE, the FAA, and the clubs themselves. Once you see where each rule is coming from, it makes more sense. The BATFE is concerned with the amount of "explosive" material being used and stored; the FAA is concerned with performance levels and specifically what airspace the rockets are likely to reach.
You do not need a LEUP to certify, and you don't need to be certified to get a LEUP. Those are two different things (LEUP is really designed for things like dynamite anyway). The cert levels 1 and 2 roughly correspond to the levels where you would need FAA FAR-101 notification and multigrain reloadable motors (L1), and the point where you would need a LEUP and FAA air traffic clearance of some kind (L2) -- but very roughly, and in the environment of ten years ago. Certification is mentioned in the law by reference, but it was created by the clubs in negotiation with authorities.
You do need a L1 cert to fly a 3x G64 cluster at a NAR or Tripoli launch. With appropriate FAA clearance, and insurance in place, you could fly them independently without any certification at all. You do not need a LEUP to fly a 3xG64 cluster, but you do need FAA permission because the total propellant burned exceeds 125 grams. (In my humble opinion, you will find certification easier, and the club environment worth the trouble.)
Under the current rules, you must fly an H motor to obtain the certification. You do not need a LEUP to buy an H reload, but according to the BATFE's current (and admittedly controversial) interpretation, you do need one to store it overnight or transport it across state lines. (For this reason many dealers will deliver previously-ordered motors to the flying field, and may also be willing to store the motor for you if you buy it and can't fly it until next time.) In this way you can buy one motor at a time for certification, or buy several and have your cert mentor(s) keep them for you.
You'll get the help you need. Remember, your dealer and your club want you certified so you'll burn more motors.
--
P.



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<snip>
OK, Bit Eimer, I've read through the thread, and I think I can clarify it

Thanks P.
Actually, I was never confused (or concerned) about the FAA aspect, since I now do nearly all my flying through a NAR/Tripoli sactioned club. Of course, as you point out, that means I need the L1.
Thanks for the clarification that I should not (theoretically) need a LEUP to buy the H, as long as I buy it and use it at the field. Now its just a question if our local on-site vendor will cooperate.
--
...The Bit Eimer NAR 84054 L0
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Who told you H (or whatever) was the threshold? Be specific.
Thank you in advance.
Jerry
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Jerry Irvine, Box 1242, Claremont, California 91711 USA
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wrote:

Jerry and David Schultz each have a point to make, and resolving it would get into politics again. The legal restriction is by the weight of "explosive" material in one container, which may be a motor or a magazine. Like the L1 and L2 boundaries, the "H" threshold for HPR is somewhat arbitrary and only approximately matches up with legal transitions.
I put "explosive" in quotes because the BATFE lists AP propellants as such in apparent disagreement with the legal definitions. The concept of "Easy Access" is that propellant is sold in smaller units than the threshold, separately packaged -- that is, subgrains sealed in separate plastic baggies. So, there's hedging and smirking going on both ways.
I've flown very few rockets since 9/11/01, and only distantly read of the SEA, so David's correction is good reading. However, the last word hasn't been spoken yet; there are procedures in transition as always. Better to take all of these issues into consideration and consult a legal database for the actual thresholds.
--
P.



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It would be helpful if everyone simply agreed to discuss ONLY the law as it exists, and leave it to the lawyers to spank the ATF for going beyond it. The judge has already stated inclinination in that direction, so we even have guidance my proposal is a good one. Besides of course the common sense of going by the regs as written today.

A Vendor construct. Aerotech in particular from 1992.

That is a DOT issue, not an ATF issue. It is both common and WRONG to confuse the two.
It is helpful for the consumer to ignore DOT thresholds entirely since that is the problem of the manufacturer and dealer.
The consumer need only concern themselves with CONSUMER regs such as ATF, CPSC, NFPA (which is authored by NAR and TRA BTW).

The only items in flux right now are NPRM-968 and NFPA-1125.
Jerry
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Jerry Irvine wrote: >>The concept of "Easy >>Access" is > > > A Vendor construct. Aerotech in particular from 1992. > > >>that propellant is sold in smaller units than the threshold, >>separately packaged -- that is, subgrains sealed in separate plastic >>baggies. So, there's hedging and smirking going on both ways. > > > That is a DOT issue, not an ATF issue. It is both common and WRONG to > confuse the two. > > It is helpful for the consumer to ignore DOT thresholds entirely since > that is the problem of the manufacturer and dealer. >
It is also a DOT issue because the BATFE regulations referenced the DOT regulations. Aerotech did not create "Easy Access" but simply took advantage of the ATF regulations as written.
The exemption was for "and other Class C explosives, as described by U.S. Department of Transportation regulations in 49 CFR 173.100 (p), (r), (t), (u) and (x)." Where (u) defined "toy propellant devices".
All of Aerotech's "Easy Access" motors were classified by the DOT as "Class C toy propellant devices" and therefore were exempt from BATFE regulations. It is as simple as that.
For some reason that nobody understands, the BATFE wants to remove any reference to DOT regulations from the rocket motor exemption. Meanwhile they keep these references (to UN numbers UN0336, UN0337, UN0431, and UN0432) for fireworks. One can only assume that the BATFE has a special desire to put it to the rocket hobby.
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wrote:

The OLD 27 CFR 55.141-a-7-v regs exempted all of Class C which translates in DOT parlance to 1.4.

The "real" easy access was "mailable".
USPS regs are different from both ATF and DOT.

They do now.
Jerry
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Jerry Irvine wrote: > > > The OLD 27 CFR 55.141-a-7-v regs exempted all of Class C which > translates in DOT parlance to 1.4. > >
I fail to see how:
"(7) The importation and distribution of fireworks classified as Class C explosives and generally known as ``common fireworks'', and other Class C explosives, as described by U.S. Department of Transportation regulations in 49 CFR 173.100 (p), (r), (t), (u) and (x)."
Exempts _all_ class C explosives.
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David Schultz wrote:

Does anyone have a copy of DOT codes from that period? (I tried to look those subsections up in the current DOT codes a while back, but it appeared that the section numbering had got rearranged since the ATF code constructed that reference...)
What "other class C explosives" were described in subsections (p), (r), (t), (u), and (x)? Could these descriptions have reasonably been construed to include something that is now shipped as a "class 1.4C rocket motor"?
-dave w
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David Weinshenker wrote:

The DOT rules underwent a major reorganization when they "harmonized" their hazardous materials regulations with UN standards in the early 90's. You will have go to a library that is a federal repository, like I did, and look up their copy on microfiche.

I thought I made a copy of that page but I can't seem to locate it at the moment. Working from memory, a couple of the letters had no entry. I don't know if these ever had a definition because I didn't dig that far back into the files.
One was for toy plastic and paper caps like you used to use in your cap gun.
(u) was the toy propellant device definition. Which said:
"Toy propellant devices consist of small paper or composition tubes or containers containing a small charge of slow burning propellant powder. These devices must be so designed that they will neither burst nor produce external flame except through the nozzle on functioning. Ignition elements, if attached, must be of a design examined by the Bureau of Explosives or the Bureau of Mines, and approved by the Director, OHMT."
I am a little fuzzy on what the other entry was. I think it was for explosive car alarms or perhaps just common fireworks.
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wrote:

So Estes motors were always in technical violation since they also project flame out the back called ejection charge.
Jerry
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It's not in the 1997 edition.
There is an equivelancy table (couldn't find it off hand, but I have posted the cite before) where ALL former Class C is equivelant to 1.4.
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