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  #1  
Old 01-23-2017, 06:47 PM
Jerry Irvine's Avatar
Jerry Irvine Jerry Irvine is offline
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Trump was elected. He wants to reduce regulation "75%". Perhaps we should get on board for reduction of regulation on small quantities of BP, slow burning solids, shipping, igniters, and even, gag, airspace access for mid HPR up to K.

What say you?

Just Jerry

http://v-serv.com/usr/index.htm

http://v-serv.com/usr/regulatory.htm

http://v-serv.com/usr/ATFexempt.htm

http://www.v-serv.com/usr/ATFE-03-16-09.pdf

http://v-serv.com/usr/FS-holygrail.jpg

2.2 mm/sec per the PA DOT investigation into AT over 10 years ago where they RULED APCP not subject to HMR!!!!!!
!!!!!
!!!!!

JJ

Quote:
Originally Posted by U.S. Rockets website
Reinstate former 27 CFR 55.141 (a) (7) with the minor revision that the former Class C DOT category which now encompasses all of class 1.4 be exempted again, as it was for decades from 1972-1998 or so.

The primary issue is, "What is covered by BATF regulations?" It used to be the case that a lot of rocket motors were not prior to 12/98, in 27 CFR 55.141, which covers Exemptions.

"The importation and distribution of fireworks classified as Class C explosives [now 1.4] 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)."

In the regulations referred to by 27 CFR 55.141 (a) (7), the DOT's 49 CFR 173.100 (u) is about toy propellant devices, defined broadly enough to include rocket motors using both cardboard and composite casings.

Then BATF changed the rules. First, they deleted the definition of Common Fireworks in the rules that became effective 12/98. Instead, they substituted "Consumer Fireworks" which sounded a lot like the earlier definition EXCEPT that it lists specific UN numbers–in this case UN0336 and UN0337–instead of the more general Class C explosives (now 1.4). Neither UN0336 and UN0337 are relevant to rocketry, and in fact are used for materials classified as 1.4G.

Exemptions:
27 CFR 55.141 (a) (7), to exempt only:

Omit:

"The importation, distribution, and storage of fireworks classified as UN0336, UN0337, UN0431, or UN0432 explosives by the U.S. Department of Transportation at 49 CFR 172.101 and generally known as "consumer fireworks" or "articles pyrotechnic."

Replace with:

"The importation and distribution of fireworks classified or listed as Class 1.4 (formerly Class C) explosives and generally known as "common fireworks", and other Class 1.4 explosives, as described by U.S. Department of Transportation regulations in 49 CFR 173.100 (p), (r), (t), (u) and (x), or a foreign country classification bureau."

The importation and distribution of substances or articles classified or listed as DOT/UN 4.1 Flammable Solid or below. Igniters which are an electrical unit with a slow burning solid on it. Time fuses or propellant tubes. Black Powder deployment tubes. A pound per type of open BP.

UN0336 and UN0337 are for fireworks. UN0431 and UN0432 are "articles pyrotechnic." UN0432 in particular is the designation given by the DOT to small black powder rocket motors, so Estes and Quest are still exempt. However, none of the UN numbers used for composite propellant motors were included, even for those classified as 1.4S, just like Estes motors are. This is apparently not what the BATF intended.

Furthermore the scope of regulations vastly exceeds the mandate of the BATFE by congress in a wide range of areas after you consider the actual text of their mandate:

Organized Crime Control Act of 1970, Title XI
Regulation of Explosives
Public Law 91-452, Approved October 15, 1970 (as Amended)
[NOTE: Any reference to the Internal Revenue Code of
1954 refers to the Internal Revenue Code of 1986
(Sec. 2, Public Law 99-514, 100 Stat. 2085, October 22, 1986.)]

PURPOSE

SEC. 1 1 01. The Congress hereby declares that the purpose of this title is to protect interstate and foreign commerce against interference and interruption by reducing the hazard to persons and property arising from misuse and unsafe or insecure storage of explosive materials.
It is not the purpose of this title to place any undue or unnecessary Federal restrictions or burdens on law-abiding citizens with respect to the acquisition, possession, storage, or use of explosive materials for industrial, mining, agricultural, or other lawful purposes, or to provide for the imposition by Federal regulations of any procedures or requirements other than those reasonably necessary to implement and effectuate the provisions of this title.

Proof of BATFE recognition of Propellant Actuated Device exemption.
Federal Court Order (pdf) establishing a burning rate threshold for burn/deflagrate.

FINAL FEDERAL COURT ORDER 16 March 2009:

"ATFE’s own burn rate threshold for deflagration is 1000 millimeters (or one meter) per second."
Tripoli Rocketry Ass’n, 437 F.3d at 81-82

This means a burning rate under the BATFE threshold for deflagration (<1000mm/sec) involves mere burning, not deflagration (>1000mm/sec), or detonation (>1138 fps, Mach 1, the speed of sound).

Last edited by Jerry Irvine : 01-24-2017 at 12:27 PM.
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  #2  
Old 01-23-2017, 08:57 PM
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tbzep tbzep is offline
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Let's include thermalite in the igniter definition.
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  #3  
Old 01-23-2017, 09:54 PM
Ltvscout Ltvscout is offline
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Remember, no political talk!
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  #4  
Old 01-24-2017, 07:44 AM
Joe Wooten's Avatar
Joe Wooten Joe Wooten is offline
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Quote:
Originally Posted by tbzep
Let's include thermalite in the igniter definition.


Seconded!!!!
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  #5  
Old 01-24-2017, 08:04 AM
Woody's Workshop Woody's Workshop is offline
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It's too bad someone don't start a Rocketry Forum where real life friends and internet friends can discuss openly about these upcoming changes. How they may, or may not be favorable and why. Outside the rocket community (which is here online only) I'm stuck here in the apartment with little to do but build rockets. Sometimes I like to express myself. And Facebook or any other social thingy don't thrill me. Only use facebook to keep track of family.
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Old 01-24-2017, 08:20 AM
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tbzep tbzep is offline
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Quote:
Originally Posted by Woody's Workshop
It's too bad someone don't start a Rocketry Forum where real life friends and internet friends can discuss openly about these upcoming changes. How they may, or may not be favorable and why. Outside the rocket community (which is here online only) I'm stuck here in the apartment with little to do but build rockets. Sometimes I like to express myself. And Facebook or any other social thingy don't thrill me. Only use facebook to keep track of family.

I believe discussion of regulations would be within the scope of the forum, but a few will use it to bash one party or other, one ABC organization or other, or one POTUS or other, so I doubt the thread would last very long.

You do have an option to discuss just about anything with other folks of the rocketry community in The Sagitta Cantina. http://www.starportsagitta.net/


.
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  #7  
Old 01-24-2017, 09:18 AM
Woody's Workshop Woody's Workshop is offline
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Thanks for that link.
How many from here, go there?
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  #8  
Old 01-24-2017, 09:56 AM
Jerry Irvine's Avatar
Jerry Irvine Jerry Irvine is offline
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Quote:
Originally Posted by tbzep
I believe discussion of regulations would be within the scope of the forum,
I am hoping my monologue of a summary of regulatory issues stands because I hope and believe regulatory discussion is independent of any political party and of direct impact to rocketeers. We have been successful in relaxing NAR (Irvine, Miller), NFPA (Stine, Rosenfield), FAA (Irvine, Miller) and ATF (Irvine, NAR, TRA, flyrockets.com, Bundick) and CSFM (Shecter) rules and I hope that trend continues without argumentation.

Other forums do not have the eyeballs of major manufacturers and association leaders as this one does. This (YORF) is the only viable forum for such a discussion at this time.

Last edited by Jerry Irvine : 01-24-2017 at 01:56 PM.
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  #9  
Old 01-24-2017, 11:13 AM
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Unfortunately not many from here go over to the Sagitta Cantina.
Due to that fact, I'm never there anymore...just too little participation.
The owner of that site and I usually don't agree on much, but we do agree on the rules/moderation policy over there...next to NONE.
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Old 01-24-2017, 12:31 PM
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Quote:
Originally Posted by Woody's Workshop
It's too bad someone don't start a Rocketry Forum where real life friends and internet friends can discuss openly about these upcoming changes. How they may, or may not be favorable and why. Outside the rocket community (which is here online only) I'm stuck here in the apartment with little to do but build rockets. Sometimes I like to express myself. And Facebook or any other social thingy don't thrill me. Only use facebook to keep track of family.


There is, it's called the "Sagitta Cantina" started by Bernomatic here on YORF, as an alternative forum for those who are mature enough to discuss topics that others famously here on YORF and the Terribly Run Forum simply cannot read differing viewpoints without getting their panties in a wad...

http://forum.starportsagitta.net/

Come on over and check it out. Not a HUGE amount of discussion, but it's free and open discussion and differing viewpoints are welcome-- but don't think that folks can't or won't disagree-- such is the nature of FREE SPEECH!

Also none of the stupidity that goes on (like word association games) on the Terribly Run Forum or the overmoderation that cripples that place and stymies open discussion of otherwise relevant topics on YORF because it might make someone's tiny little feelings feel all butt-hurt...

Later! OL J R
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