LEUP Termination Question

[mhanna]

I'll try and make this short but I am confused. I had a discussion with the local BATF agent today about my inspection due this summer and I relayed to her that I was not planning to renew it this time. (I've had it since the law suit days). She said her supervisor says I need to use all the motors with over 62.5 grams of propellant and igniters that are not e-matches.

I don't believe this to be true is it? Is there some documents I can point her to that shows the 20 or so motors I have currently don't need to be used before my summer expiration date?
She seems nice and wants to work with me but also seems new to rocket motors. I have 20 or so motors (F thru I) and probably 25 Aerotech type igniters that are the concern for her.

any help or direction would be great.

 

[tbonerocketeer]

I'll try and make this short but I am confused. I had a discussion with the local BATF agent today about my inspection due this summer and I relayed to her that I was not planning to renew it this time. (I've had it since the law suit days). She said her supervisor says I need to use all the motors with over 62.5 grams of propellant and igniters that are not e-matches.

I don't believe this to be true is it? Is there some documents I can point her to that shows the 20 or so motors I have currently don't need to be used before my summer expiration date?
She seems nice and wants to work with me but also seems new to rocket motors. I have 20 or so motors (F thru I) and probably 25 Aerotech type igniters that are the concern for her.

any help or direction would be great.

https://www.atf.gov/explosives/docs...ium-perchlorate-composite-propellant/download

 

[Steve Shannon]

You don’t need to use the motors.

 

[UhClem]

The ATF sent letters to permittees a long time ago. If you have those APCP F-I motors logged into your magazine, then you really are confused.

 

[mhanna]

Nice, that explains the APCP but I'm still cloudy on what its saying about my Aerotech igniters? Are they still regulated and none of us should have them without LEUP?

Thanks

 

[cwbullet]

Commercial hobby and high power motors are not regulated. We have had this issue in SC and I had to end a copy of the lawsuit to a local that was being harrassed. They backed off.

 

[mhanna]

Ok, I re-read it a coupled of times, sounds like if the igniters are used for "recreational or cultural" purposes they are not regulated.

Thanks everyone

 

[dhbarr]

Nice, that explains the APCP but I'm still cloudy on what its saying about my Aerotech igniters? Are they still regulated and none of us should have them without LEUP?

I don't even play a lawyer on TV, but I had thought that initiators shipped by the manufacturer along with the motor weren't of concern.

 

[Steve Shannon]

Use the igniters up somehow. Igniters, purchased separately from motors are regulated items. That never changed and we have been quietly warning people not to bring attention to them for 12 years now.
APCP motors are not listed as explosives any more. That’s what the lawsuit accomplished.
Regulations on BP motors didn’t change because of the lawsuit.
The exception for recreational or cultural usage refers to black powder and BP firearms, not igniters.

 

[hball55]

Lucky you’re not in California.

 

[jderimig]

You simply need to zero out your magazine inventory and send all your records to the Cleveland ATF office.

 

[Rocketjunkie]

I talked with my ATF agent at my last inspection. I will not be renewing. I was told to use what's in the magazine before then. (Just Thermalite and BP.) Can always buy more BP and I have found alternatives to Thermalite. Burn offs will be done in front of a video camera to document if needed. You can always use MJG FireWires (Not regulated) for ematches.

 

[mhanna]

I have 10 motors and their igniters left and have told them they would be used before my August renewal. We'll see if that does it.

 

[Steve Shannon]

I have 10 motors and their igniters left and have told them they would be used before my August renewal. We'll see if that does it.

You do not have to use the motors. Take them off your inventory and refer to the letter Chris Short posted. If you need help PM me.

 

[FredA]

Yep - I put a copy of that letter in my log and got all the non-compliant material out of my magazine that day!
You shouldn't have any motors in your magazine after July 2009.
No disposition needed -- the BATFE has no say over what you do with those motors today.

 

[cwbullet]

Yep - I put a copy of that letter in my log and got all the non-compliant material out of my magazine that day!
You shouldn't have any motors in your magazine after July 2009.
No disposition needed -- the BATFE has no say over what you do with those motors today.

Or how you store them. I keep mine in Ammo cans and an old magazine that has been repurposed. My black powder Is now in my gun safe.

 

[Zbench]

Mark, what agent were you talking to? I have a lot of experience with the Independence Crew as I used to be a Class 7 FFL holder. They are very reasonable, not like the ATF of old that was looking to jam you up at every turn. They now recognize if they harass all their licensees, that has a negative affect on compliance and willingness to surface issues when they inevitably arise.

Looking forward to seeing you at Amherst soon!

 

[mhanna]

Just got off the phone with my agent and they are backing off - mostly. She still maintains the igniters are the issue. She told me to let her know when the motors and igniters are gone and she will stop by to check the magazine is empty of controlled items, take the last five years of my receipts and daily use records. Won't be an issue.

With decent spring weather I will have no problem using the igniters in question one way or another. My LEUP doesn't expire until August so I have plenty of time.

Thanks for all your help.

 

[mhanna]

So I'm assuming anything new I buy should not go near my Magazine or BATF records?

 

[Zbench]

Mark,

The ATF operates on what's in your bound book records. If it's not in the book and not in the magazine, it doesn't exist in their eyes. I think you are in good shape. She will take your records and they get digitally scanned and are then maintained at their storage site in WV for the next 20 years. At least that is the storage requirement for FFLs and 4473s.

 

[Steve Shannon]

She’s right about igniters. Igniters are specifically called out in law by name, not something that ATF interpreted incorrectly. That’s the way Congress wrote the law. Unfortunately they used the term without defining it.
That’s also why you seldom see manufacturers refer to them as “igniters.” Instead you see motor initiators or starters. Also pyrogen on the bridge wires has been reformulated by some manufacturers in order to reduce the likelihood that they can be confused with the regulated items.

 

[UhClem]

So I'm assuming anything new I buy should not go near my Magazine or BATF records?

If you look at that open letter from the ATF you will see where they recommend storing your exempt APCP in a magazine. No records required.

When I let my permit expire I had no records. ATF regulations require that only five years of records be kept and since I regularly purged old records, I had nothing left.

 

[cobra1336]

If you look at that open letter from the ATF you will see where they recommend storing your exempt APCP in a magazine. No records required.

When I let my permit expire I had no records. ATF regulations require that only five years of records be kept and since I regularly purged old records, I had nothing left.

I was inspected in October, she said they are checking the motors but not the igniters. I know she was wrong but didn't question her since I usually buy onsite and use them. I always renew, low cost and who knows what the future holds. You terminate your permit, laws change, it's going to be a bear renewing it if allowed at all. Just my thoughts.

 

[Ez2cDave]

I always renew, low cost and who knows what the future holds. You terminate your permit, laws change, it's going to be a bear renewing it if allowed at all. Just my thoughts.

If the laws change, it won't matter if you have a current license or not. Your license would simply no longer prmit the purchase, possession, or use of whatever materials they deem to be forbidden.

Dave F.

 

[cwbullet]

I have a large magazine that i bought when I was planning to get an LEUP. The law changed and now I just use ti to store motors. Hopefully, it does not change again.