With all this discussion about the BATFE, rocket motors, exemptions
and storage requirements, how are we supposed to interpret the ATF
letter, addressed to Mr. Guy Bruda, dated June 5, 1992?
It states "the finished rocket motors that you proposed to use [H
motors in this case] are exempt from regulation by the Bureau of
Alcohol, Tobacco and Firearms (ATF). You are not required to possess
any license or permits from ATF to acquire or use these devices.
There are also no ATF storage requirements that you must satisfy to
hold these rocket motors."
We have a clear statement by Mr. Brunda that he intended to use H
motors. There was no indication from Mr. Brunda that these were
single-use or reloadable and the BATFE did not specify. There was no
indication from Mr. Brunda as to the quantity of propellant contained
in these motors and the BATFE did not specify any limits on their
clearance. It was as if they did not care.
The only thing in the entire letter that bothers me is the phrase "the
finished rocket motors." However, since the BATFE had no way of
knowing, based on the contents of Mr. Brunda's letter whether these
were reloadable or single use motors, I feel comfortable that it
didn't make any difference.
Also, notice that they described them as "devices." This fits very
nicely in describing them as propellant actuated device.
18 years ago