Model Forum / General / Rockets / June 2007

Only got to page 6 so far, but sounds like an improvement.  Can I assume
you will have a full analysis on your website shortly David?

Contrast the FAA approach to the ATF approach.  What a difference!

Did I read correctly that most HPR launches would change from a waiver
to 45 day notification?  Or is that in addition?

The only think I didn't like is the requirement for fire control.  I
don't think this belongs in a FAA regulation.

on my first reading, everything seems reasonable to me.   More or less the
sme information that has been required of LMR will now apply to HPR and
AHPR; I don't see that as overly onerous.

What may be of concern is the 45 day waiting limit to get  a waiver  for HPR
and AHPR.  Does this mean the FAA will do away with "standing" waivers?
Although they did change notice time limit  from 24-48 hrs up to
24hr -3days....

terry dean
nar 16158

Dave, thanks for the heads up. Most of this looks good, as in it brings the
regs up to what we've been doing for the past decade. There are a few
exceptions I've noted below. I have to wonder what caused them to look at
this, and wonder if the recent Kentucky incident had anything to do with it?

A couple good changes:

The MR propellant limit is increased to the same 125g as LMR. The only
distinction left is total weight.

The burn time limit is gone. I can now stage a pair of F7s!

The NAR initially petitioned the FAA in 1985, not 1992. We were ignored for
7 years.

The FAA definition of HPR still does not align with the NFPA definition.
Even under the new regulations, it is possible to fly some HPR rockets as
Class 2 because they do not exceed the 125g propellant limit or the 1500g
total weight limit. For example a LOC-IV flown on an H128, a common L1 cert
rocket, is HPR by NAR / TRA / NFPA, but not according to the new FAA
definition. This creates ambiguity and possible confusion.

airport with the permission of the airport manager. In the past, I've been
at HPR launches at Chanute AFB / Rantoul airport, and back in its day at
Glenview NAS. I'm pretty sure other groups have flown from airports with the
permission of the owners / operators. In fact our new section was asked to
do a demo at an air show at a small airport that would be impossible under
this restriction.

In addition, we have many small airports in our area. I'm sure others do
too. Some are nothing more than a rarely used grass strip, yet they are
marked on the sectional charts. Is the existence of one of these within 5
miles now no longer permitted? This will cost us launch fields across the
country.

121.25 (b) should read "Within 8 kilometers (5 miles) of any airport
boundary WITHOUT THE PERMISSION OF THE AIRPORT AHJ;"

safety code, allowing the launch site to be placed closer to the field
boundary to insure that flight trajectories stay over safe areas. This rule
should be realigned to agree with the changes to NFPA 1127.

an HPR launch be provided to the FAA with the waiver request. Launch
directors do not know who will fly what until they show up at the check in
desk with the rocket at the range. Fliers usually don't know this themselves
until maybe an hour or less before they fly a rocket. As I write this
response, I myself have no idea what rocket(S) I will fly with what
motor(S), what launch pad(S), and what recovery system(S) at our club HPR
launch that starts in about 40 hours. This requirement S an absolute deal
breaker for any existing HPR launch, at least as we know them today.

On page 32818 column 1 last paragraph, the FAA admits that the old FAR
101.22 requested this information, but it was not used. So why are they now
requesting it here?

I'm sure I'll have more to say after I have a chance to look this over more
carefully.

Some of it was an improvement, but a few negative things stand out for
me.

(1)  A person can operate a car (drivers license) at 16, but has to be
18 to launch a high power rocket by himself according to the FAA.
Cars are way more dangerous than high power rockets.  The age should
be reduced to 16 years of age or lower.  I found this part
particularly interesting as I was 17 years old in 1967 when I started
flying to get a pilots license.

(2)  Reasonable fire control is wide open to interpretation.   Is that
a bucket of water and a shovel, or perhaps a fire extinguisher or an
all terrain fire truck on standby?  And what happens when the water
and shovel are given the OK by the FAA and a massive grass fire starts
during the subsequent launch burning down a home or two?  I tell you
what will happen.  The FAA will require a fire truck at future
launches and for ALL US LAUNCH SITES to protect their a.ses in the
future.   I would like to know if the FAA is going to require pilots
to provide fire control along their flight paths in case their planes
crash and start a fire.  This has happened more than one in Wyoming.
This provision should be crossed out and has no place in the FAA
regulations.

(3)  I am not very keen on the advanced high power rocket part.  "FAA
requirement - A description of all major rocket systems, including
structural, pneumatic, propellant, propulsion, ignition, electrical,
avionics, recovery,
wind-weighting, flight control, and tracking".   The amateur also has
to do a 3 sigma trajectory analysis as well.  Is he now supposed to
provide an engineering design review package to the FAA down to a
description of the igniter?  Looks to me like this is an attempt to
kill off anything above a P motor by piling on paperwork and expense.
In contrast, any idiot can take an ultra-light and buzz the
neighborhood, which they do where I live.  That is OK with the FAA.
But God forbid, some amateur rocket guy takes a Q motor out to the
middle of nowhere and launches it without having a full on engineering
review done on his design, launcher, igniter, ground operations and
flight operation procedures.   This provision should be rewritten and
based on maximum altitude of the rocket.  The higher the altitude, the
more design work and reporting is required.  People flying under
100,000 ft should not be required to provide an engineering design
review of their rocket to the FAA.

Just my thoughts.

John Wickman

Here's the FAA address for the document:

http://www.faa.gov/about/office_org/headquarters_offices/ast/nprm/amateur_rockets/

on page 1 are addresses/links that can be used for comments to be submitted
by Sept 12, 2007.

One of the ARocket list members "worked heavily on these regulations while
(he) was there" and "worked very hard to try to balance the needs of the
community with the needs of the Office."

There will certainly be concerns, and they should be sent to the docket as
described on the document.

Tim

Has anyone had any luck with the docket management system at
http://dms.dot.gov ?  I can't get a response from it of any form.