I received a newsletter from the local Tripoli organization recently, and just got around to reading it, and there is something in there which got me so angry I must comment on it. (For the recoed, I belong only to NAR, but have attended many TRA launches and am on the local mailing list.)
There is reprinted in the newsletter an article from Extreme Rocketry (I do not read ER), excerpts & comments inline follow:
"Under the HSA/SEA, all possessors of "H" and above motors are required to have an LEUP/LUP and acessible to[sic] a magazine."
Wrong. After some early confusion, it is clear that so-called "easy access" still exists, and will continue to until such time as NPRM 968 is formally adopted. OTOH, the loss of the in-state exemption is a big blow to many.
"The individuals who are certified for "H" and above motors have a very limited set of choices. Either come into compliance or exit the HPR aspect of the hobby."
How long will it take for like this writer to realize that for many, such as myself, even if we WANTED to comply, we can't. I live in a major metro area. I live in a condo. I CANNOT meet storage requirements, even for indoor storage. I DO NOT KNOW ANYONE I could use for a non-storage permit. The nearest club whose storage I could use is in ANOTHER STATE. Furthermore, getting an LEUP/LUP opens you to a level of scrutiny which many would rather not be subjected to. This is not like a fishing license, or a hunting license, or even an FCC amateur radio license (which I have).
"By coming into compliance, this will bring a level of professionalism and legitimacy that has been absent from the hobby for years."
Taken at face value, this would seem to be an indictment of TRA past practices. I single out TRA because I am not aware of NAR having a reputation for "Outlaw Biker Rocketry" (that phrase comes from the article, not me).
"The regulatory problems being faced...have been around since the late
80's ...If compliance issues had been addressed then, we would not be facing the massive headaches that we have today."
Perhaps if 27CFR55.141-a-8 had been pursued aggressively from the beginning then the current mess might not exist.
"One of the reasons why the BATF has been so forceful is our own hobby's lack of self-governance."
I tend to increasingly agree with Jerry Irvines's view that BATF(E)was invited to the party, and once they got their foot in the door took over. Also, this statement can be taken as another indictment of TRA past practices.
"The choice is rather simple. Come into compliance, or walk away."
This article is nothing more than COMPLETE CAPITULATION. Since the local Tripoli organization has chosen to "strongly recommend" an LEUP and Day-Box for "easy access" motors in order to launch at their site, I'm SOL. The only other alternative is to drive over 120 miles. I sold my remaining (perfectly legal) "H" reloads locally (no shipping involved), and my casing since I have no forseeable further use for it. I AM out of HPR, but not by CHOICE. I've been pushed out. With help from within.
"The Amateur Rocketry Society of America's (ARSA) goal is to enable US citizens to enjoy all forms of amateur rocketry. Our local societies permit amateur rockets to fly along side high power and model rockets at the same site and at the same time. There is no certification process or requirement for rocket motors or flyers."
from
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"You can become a member by simply sending us your name, mailing address and email address. While ARSA is oriented towards rocketry in the United States, you do not have to be a U.S. citizen to join."
see the ARSA safety code at
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you will not find any requirements for LEUPS or storage there :)
-- Amateur Rocketry Society of America Safety Code (Revised 9/14/02)
Introduction
The following are guidelines meant to allow you to enjoy Amateur Rocketry and to encourage safe and constructive involvement in it. Realize that no Safety Code can assure 100% safety this is up to you!
1.0 ROCKET MOTORS:
1.1 Commercial custom motors and experimental motors may be used at all launches, without being listed on TRA, NAR or any other organizations "Certified Motor List".
1.2 All rocket motors will be electrically ignited.
2.0 ROCKETS:
2.1 Rockets will be built as light as possible for the intended purpose of the rocket.
2.2 Rockets will have a suitable means for providing stabilizing and restoring forces necessary to maintain a substantially true and predictable upward flight path.
2.3 Rockets shall be constructed so as to be capable of more than one flight. It will be provided with means for a slow and safe descent. If a rocket is to descend in more than one part, then the parts should have means for a slow and safe descent.
2.4 Any equipment, devices, or material which relies upon flammable, smoldering, or otherwise combustible substances, which are not a motor, shall be designed, built, and implemented or otherwise used in a manner which will minimize the possibility of a fire after launch.
3.0 LAUNCH PADS AND IGNITION SYSTEMS:
3.1 A launching device, or mechanism, must be used which is sufficiently rigid and of sufficient length to guarantee that the rocket shall be independently stable when it leaves the device. This launching device shall be sufficiently stable on the ground to prevent significant shifts from the planned launch angle, or the accidental triggering of any first-motion ignition devices.
3.2 A launch angle of less than 15 degrees from the vertical must be used when flying rockets.
3.3 Any and all ignition systems on rockets must be remotely and electrically activated.
3.4 The launch of any rocket must be completely under the control of the person launching it. When flying alone, the individual person is responsible for range safety, and launch control safety. When flying at an Amateur Rocket Society of America sponsored meet, the Range Safety Office (RSO) will turn over control of the launch, for the duration of the countdown, to the designated Launch Control Officer (LCO) when the launching range is deemed safe to launch. It is permitted for the RSO and LCO to be the same person.
3.5 The launch system firing circuit must return to the off position when released (if a mechanical launch system is used) or reset (if an electronic launch system is used).
3.6 Excessive lengths of fuse, or complex pyrotechnical ignition arrangements should be avoided. The simplest and most direct ignition trains are encouraged to promote range safety.
3.7 Igniters should be installed at the last practical moment, and once installed, electrical igniter wires should be shorted and/or pyrotechnical systems mechanically protected to prevent premature ignition from EMI or heat sources.
4.0 LAUNCHES AND CONDITIONS:
4.1 All launches of rockets must be conducted in compliance with Federal, State, and Local law.
4.2 Rocket flights must be made only when weather conditions permit the average person to visually observe the entire flight of the rocket from lift-off to the deployment of the recovery system. It is recommended that no rockets be launched when winds exceed 20 miles per hour.
4.3 No rocket shall contain en explosive warhead type device, nor will they be launched at targets on the ground.
4.4 An amateur rocket flying field must be equipped with an appropriately rated fire-extinguishing device. Each launch pad should have a water container within 10 feet of the pad. A well-stocked First Aid kit and a person, familiar with their use is recommended.
4.5 Advanced Rockets shall be launched from a clear area, free of any easy to burn materials, and away from buildings, power lines, tall trees, or flying aircraft. The flying field must be of sufficient size to permit recovery of a given rocket within its confines.
4.6 At no time shall recovery of a rocket from power lines, or other dangerous places, be attempted. Any rocket that becomes entangled in a utility line (power, phone, etc.) is a hazard to the utility line and untrained persons who may be attracted to it. The owner of the vehicle will make every effort to contact the proper utility company and have their trained personnel remove it.
4.7 No rocket shall be caught during descent.
4.8 All persons in the vicinity of any launches must be advised that a launching is imminent before a rocket may be ignited and launched. A minimum fivesecond countdown must be given immediately prior to ignition and launch of a rocket.
4.9 A spectator line will be established parallel with the launch controller?s table. Launch pads for motors exceeding J class, or clusters of G, H, and/or I?s shall be set 200 feet from the spectator line.
4.10 Commercial motors and experimental motors must be permitted to fly on the same launch days.
4.11 Experimental motors deemed unusually dangerous or hazardous by the RSO will be permitted to fly, but must be placed further away from the launch table and spectators so that all participants are safe. The only exception to this rule is if there is a field fire danger associated with the operation of this motor that exceeds the ability of the participants to put out. In this case, the RSO may prohibit the operation of the experimental motor at the launch.
The editorial you quoted is one man's opinion, nothing more. And as you noted it is full of mistakes and BS. I don't know why your local prefecture chose to reprint it, but you should not confuse it with TRA policy.
I hate to do this (), Izzy, but here goes. Comments in-line.
David Erbas-White
Ismaeel Abdur-Rasheed wrote:
Why are TRA and NAR singled out specifically? What about CAR? If there is specific problems with TRA or NAR certification, why not list them? If there is no specific problem, why list them by name? Should there not be ANY separation (simply as far as launch distances, perhaps) for commercial made vs. experimental motors? And the phrase 'commercial custom motor' eliminates the 'commerical stock motor', such as the standard QuEstes engines from being 'allowed' under this rule.
What defined electrical ignition? Are ANY rockets truly purely electrically ignited? Can an electrical ignitor light a fuse? Does this allow 'flashpan' launches, or not? Is an 'electric flashbulb' ignition system still electric, when the heat of the flashbulb is conducted mechanically, rather than electrically, to another ignition element?
Within what parameters? If I build a rocket that's intended to go 1000' high, and someone else builds one for the same purpose, but it's lighter, is mine in violation? Within what parameters? What if I want to build a sturdy rocket, that will withstand rough handling? If your response is that building it that way changes the intended use, then what is the POINT of this item? Wouldn't it be better to say something like, no more than X percent of a rocket's weight must be the actual propellant? Or that the weight of the rocket must be no more than Y percent of the calculated capability of the supplied propellant?
What is 'suitable'? How fast must it 'restore' to its 'substantially true' upward flight path? How does this accomodate clustering? How would this statement accomodate a multi-stage rocket that isn't pointed directly upwards when the upper stage ignites? Shouldn't this be more properly defined as a CG/CP type of statement (or something similar)? I'm very leery of such vague wording as 'suitable' and 'substantially'. Or if not necessary, why have this statement?
What is defined as slow and safe? Is it dependent upon total mass of the falling object, or the total kinetic energy that it carries? For example, an Estes rocket on a streamer causes me little concern, but a heavier rocket falling at the same speed sure would. Again, your wording is too vague as to have any meaning.
So, a motor doesn't have to be designed, built, implemented, or used in a manner to minimize the possibility of a fire? Great news!
Again, vagueness. What is a 'significant shift'? Who defines it? Is it wind-dependent? Launch-weight dependent? I don't have as much of a problem with the 'vagueness' of the first sentence, because it ends with the declarative "the rocket shall be independently stable when it leaves the device," which is pretty unequivocal.
In all conditions, including winds? If so, please state.
Define remote. Must it be wireless? Relay activated? If I'm three feet away from a K motor, is that remote?
At last! An (almost) completely declarative statement! The only lack is the 'deemed safe' part, which based on the rest of the document, has LOTS of holes in it.
A fully declarative statement! We're finally progressing!
Darn. Back to vagueness again. What is excessive or complex? Who decides? If there are no parameters, why have this statement (unless it's simply to get the last sentence in there to "show where our pure intentions lie")?
What is practical? If someone decides it's "practical" to install their ignitors in their garage before leaving for the launch, is that acceptable? If not, say so. If ignitors should only be installed at the pad, or within X minutes of launch, then say so.
Here's where I reverse course (). Because of the complexity and interlocking (and often contradictory) nature of the Federal, State, and Local laws, I would actually change this to "must be conducted in substantial compliance" with Federal, State, and Local law. I would further recommend that where necessary, if it is believed that there might be conflicts in law, that the rocketeer be 'recommended' to carry a copy of the citation that supports his interpretation of said laws when conducting amateur rocketry.
Really? So the average (untrained) person can track a rocket to, oh,
10K altitude all the way, and will see the chute deploy, and track it to landing? Is this with or without optical aids (such as binoculars)? Is the 20 MPH truly a recommendation, or a requirement? Is this gusting, average, peak?
I guess that stops all spot-landing contests. I understand the 'warhead' statement, but if you've already said that they can't launch more than 15 degrees from vertical, than how, exactly, does this 'add' to safety? And given today's environment, wouldn't it be FAR better to state that they won't be launched at targets (you know, such as airliners, police helicopters, curious Cessnas, etc.)? And then add an exclusion to the effect that the combination of launch AND VALID RECOVERY towards a target point (i.e., spot landing) is not considered launching at a target.
How familiar? Must they have any kind of certification? If not, why have the statement? If so (for a meet, for instance) why not say so? What is a well-stocked first aid kit? I have two in my car that I bought. One has bandaids and a tube of ointment. The other has just about everything but a fold-up stretcher. I bought both of them, intact, at a pharmacy, and they both have most of their original contents. Are they both 'well-stocked'? Are there certain minimum things that should be REQUIRED? Given possible chemical problems, for example, should an eyewash container be included (just a throw-away comment)?
What is an 'advanced rocket'? I haven't seen that defined. Is there a distance people must be from the launch pad?
I would add that if the owner of the vehicle doesn't make every effort, that the RSO/LCO must do so.
Really? Why is that? If I have an Apogee Saturn V that I've put months into building, and it's coming down slowly enough to catch, but I catch it, I'll be violating the rules. What happens then? Perhaps this could be changed to something like "only rockets descending slower than XX FPS may be caught", or "only rockets desending with a total kinetic energy of less than YY may be caught".
What about misfires? Any delays? What is the 'vicinity' considered to be? If there are more than X number of people, is a PA required?
Okey dokey.
Must? So, if a site owner gives permission for commercial motors, but not for experimental motors, they MUST be permitted to fly?
Vague, but since you've defined the responsible party, perhaps acceptable.
The article in the newsletter was annotated with comments by one of the prefectures members (possibly the newsletter editor) agreeing with what was stated. Also, at recent launches, I've been told they give you a form at the registration table which tells you to have an LEUP & Day Box for any motor over "G". I think this partly is because the launch site is a state park, and pertly because for over the past year they've been in the "The BATFE could raid us at any moment" mentality. I also see by their figures that attendance was down 30% in 2003 compared to 2002. I wonder why? - Duh. The other site I mentioned, which is over a 120 mile drive for me, has a "don't ask don't tell" policy.
Sometimes, both reasons can be true. If on one hand you adopt self-regulation, and on the other hand disregard it when it suits you, then both can be true. In physics, if you ask if light is a wave or a particle, quantum mechanics says...both.
I think one major problem is that rocketry has TWO hobby organizations. Look at some other hobbies:
Amateur Radio: ARRL Model Avation: AMA Model Railroading: NMRA
But here in rocketry, we have both NAR & TRA. Sometimes I think the left hand doesn't know what the right hand is doing. And an off-topic question: Where did TRA come up with the goofy terms prefecture & prefect? Can't they just use "club" & "president"?
When is ARSA going to start getting vendors to see the light and quit requiring a LEUP for the users? What is ARSA going to do about cert level requirements by the vendors to buy >H motors?
But they did. And this is the sort of attitude that PERVADES Tripoli and its clubs. The FUD campaign is real. It is from within the outlaw biker organization known as Tripoli.
Nope. You should COMPARE it to TRA policy!
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2-2.2 The applicant must also provide TMT with a copy of a BATF Low Explosive Manufacturer's license prior to acceptance of motors for testing. This requirement is by Tripoli Board motion and vote on 23 January 1994.
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Twelve issues per year, handled by HPR Publishing. Note that the following prices are special Member Only prices. Regular First Class US Delivery $52.00__ $78.00__
It makes no difference. The LAW does NOT require it and Tripoli and its clubs DO. That is enough for all but the most militant Tripoli at all cost zealots.
The applicant must also provide TMT with a copy of a BATF Low Explosive Manufacturer's license prior to acceptance of motors for testing. This requirement is by Tripoli Board motion and vote on 23 January 1994.
It maybe as simple as CAR certs are recent and the only effect they have in most places is by virtue of being cross-listed with TRA and NAR, listed AHJ's in the NFPA codes and recognized international organizations. CAR is a small domestic organization at this time. They didn't list the German or the Swiss or the Norweigan national clubs either.
Snip of a Version 1.0 safety code which is not being imposed on anyone at this time anywhere in the world.
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