Active Flight Control

[georgegassaway]

Sadly nothing crazy like everyone else's. Only flying a few feet. Will be a fun low cost anti drone platform hence the temporary nickname "Interceptor"

No, that IS CRAZY. Any encouragement I might have given you on building this has totally disappeared now that you say it is for illegally being used to aim at TARGETS (anti-drone).

You'll not only be breaking hobby safety codes, but NFPA and Federal laws by trying to TARGET and hit an aircraft.

Of course, I expect your claim to be empty bragging. By what means would such an illegal missile detect and know where to steer itself and home in on a vehicle in the air?

BTW , I own and fly several quadcopters. if anyone "shot down" one of my models, I'd sic the FAA on their butt for attacking an FAA registered AIRCRAFT (that's the one upside of the FAA regulatory overstepping). Screenshot from a recent launch.

 

[VernK]

The topic of active controls in hobby rocketry comes up from time to time and there is always discussion about whether it is legal. I have never seen anyone cite an actual law against it but a while back I did run across what looks like an "off-hand comment" buried in the code of federal regulations. 22 CFR 121.1 is the United States Munitions List. Category IV paragraph (a) is about rockets, missiles, bombs, etc. Note 3 to paragraph (a) applies to us. Here is what it says:

NOTE 3 TO PARAGRAPH (a): This paragraph does not control model and high power rockets (as defined in National Fire Protection Association Code 1122) and kits thereof made of paper, wood, fiberglass, or plastic containing no substantial metal parts and designed to be flown with hobby rocket motors that are certified for consumer use. Such rockets must not contain active controls (e.g., RF, GPS).

The last sentence in Note 3 is what caught my eye. Seems like an off-hand comment since it goes into no details and does not define active controls. For complete context:, here is the US government link to 22 CFR 121.1 as of April 1, 2019: https://www.govinfo.gov/app/details/CFR-2019-title22-vol1/CFR-2019-title22-vol1-sec121-1/summary
On that web page, there is a link to a pdf version in the left hand column. Note 3 is at the bottom of page 464 in the pdf.

I am not a lawyer. I am not offering legal advice nor asking for any. However, I am curious what people think.

 

[boatgeek]

The topic of active controls in hobby rocketry comes up from time to time and there is always discussion about whether it is legal. I have never seen anyone cite an actual law against it but a while back I did run across what looks like an "off-hand comment" buried in the code of federal regulations. 22 CFR 121.1 is the United States Munitions List. Category IV paragraph (a) is about rockets, missiles, bombs, etc. Note 3 to paragraph (a) applies to us. Here is what it says:

NOTE 3 TO PARAGRAPH (a): This paragraph does not control model and high power rockets (as defined in National Fire Protection Association Code 1122) and kits thereof made of paper, wood, fiberglass, or plastic containing no substantial metal parts and designed to be flown with hobby rocket motors that are certified for consumer use. Such rockets must not contain active controls (e.g., RF, GPS).

The last sentence in Note 3 is what caught my eye. Seems like an off-hand comment since it goes into no details and does not define active controls. For complete context:, here is the US government link to 22 CFR 121.1 as of April 1, 2019: https://www.govinfo.gov/app/details/CFR-2019-title22-vol1/CFR-2019-title22-vol1-sec121-1/summary
On that web page, there is a link to a pdf version in the left hand column. Note 3 is at the bottom of page 464 in the pdf.

I am not a lawyer. I am not offering legal advice nor asking for any. However, I am curious what people think.

I'm also not a lawyer, but a solid part of my job is reading CFRs (and worse, international regulations) and interpreting them. I see a couple of things:
* Category IV, paragraph (a) only applies to rockets with at least a 300-km range. As long as we're staying in our waiver and not flying 300 km downrange, none of this applies. (see (a)(2) in particular).
* 22 CFR 121 is a list of items that may be under ITAR restrictions on export of weapons. Again, if we're under a 300-km range, it's not a weapon.
* 22 CFR 120.10 says that information in the public domain is not subject to ITAR export controls (ie if someone wanted it, they could get it freely anyway)
* 22 CFR 120.11 defines the public domain to include information which is generally available to the public, including by subscriptions where anyone can sign up to get the information (paid or not)

To me, that last point is critical. If something is posted on TRF, it is by definition (IMHO, remember IANAL) in the public domain and therefore not subject to ITAR. That probably has a bigger impact on the Research subforum here than on guidance, but IMNALHO*, TRF is actually creating more liability for themselves by having the Research subforum access limited. If it were open to all, it'd be public domain and not subject to ITAR. If it's not open to all, it might not be public domain.

* In my not-a-lawyer humble opinion

 

[Yukon@K-9 Rocket Tech]

No, that IS CRAZY. Any encouragement I might have given you on building this has totally disappeared now that you say it is for illegally being used to aim at TARGETS (anti-drone).

You'll not only be breaking hobby safety codes, but NFPA and Federal laws by trying to TARGET and hit an aircraft.

Of course, I expect your claim to be empty bragging. By what means would such an illegal missile detect and know where to steer itself and home in on a vehicle in the air?

BTW , I own and fly several quadcopters. if anyone "shot down" one of my models, I'd sic the FAA on their butt for attacking an FAA registered AIRCRAFT (that's the one upside of the FAA regulatory overstepping). Screenshot from a recent launch.

No I used the wrong word, more than anti drone this was to be more of a project to attempting to shoot a model rocket at a drone. This was nothing to do with the hobby of rocketry or building an anti drone system, but rather a fun project and personal challenge. The drone having a bad day would've been mine, not someone else's. Also it's not active point to point based guidance, it's just a system to keep the rocket flying stable. It won't guide into anything, the accuracy of taking down a drone is up to the ground launcher's aim.

I thought if it works it would be a cool example of developing an anti drone system at a low cost, but your right bad idea, and shouldn't leave the hands of it being my own project in a controlled environment. Due to my ignorance, I failed to notice the fact that a FAA registered UAV is techncially legally classed as an aircraft which changes the story entirely. I got this entire project idea after lookingat commerical ant drone platforms and assumed they're legal. I do want to note this is not a new idea, and there are commercial rocket systems in development that use model rocket parts and a integrated net with intent to be available for civilian for taking down drones. I got inspiration from it. Another one of those "Oh that looks cool I should try that" projects, anyways thank you for your concern

 

[jderimig]

No, that IS CRAZY. Any encouragement I might have given you on building this has totally disappeared now that you say it is for illegally being used to aim at TARGETS (anti-drone).

George is right, also you are going to miss your target alot. There are simpler and more reliable methods to accomplish what you are seeking.

 

[jderimig]

The topic of active controls in hobby rocketry comes up from time to time and there is always discussion about whether it is legal.

Legality is not the entire issue. If you are "publically" successful implementing a trajectory control system for a rocket you may end up on someone in the government's radar so to speak.

Doesn't matter if its for a peaceful purpose like vertical stabilization. The z-vector is as arbitrary as any other vector capability wise.

 

[boatgeek]

No I used the wrong word, more than anti drone this was to be more of a project to attempting to shoot a model rocket at a drone. This was nothing to do with the hobby of rocketry or building an anti drone system, but rather a fun project and personal challenge. The drone having a bad day would've been mine, not someone else's. Also it's not active point to point based guidance, it's just a system to keep the rocket flying stable. It won't guide into anything, the accuracy of taking down a drone is up to the ground launcher's aim.

I thought if it works it would be a cool example of developing an anti drone system at a low cost, but your right bad idea, and shouldn't leave the hands of it being my own project in a controlled environment. Due to my ignorance, I failed to notice the fact that a FAA registered UAV is techncially legally classed as an aircraft which changes the story entirely. I got this entire project idea after lookingat commerical ant drone platforms and assumed they're legal. I do want to note this is not a new idea, and there are commercial rocket systems in development that use model rocket parts and a integrated net with intent to be available for civilian for taking down drones. I got inspiration from it. Another one of those "Oh that looks cool I should try that" projects, anyways thank you for your concern

Even if the rocket doesn’t have guidance to track and follow a drone, launching at a target is most definitely no good. A drone, even your drone, is a target if you are aiming at it. Just save everyone a lot of hassle and don’t do it. Seriously.

 

[les]

One big point - maybe there isn't, or perhaps other ways could be interpreted as there are, any rules against active guidance.

BUT - once active guidance becomes reasonable, I would almost guaranty that new rules would be created and our hobby could get over-regulated like what appears to be happening with drones and model aircraft.

In the past, one needed skill (and a fair amount of money) to fly an RC aircraft and the people involved were responsible with their "toys" and self regulated with the AMA. After Drones with the self flying capabilities & low cost, anyone could get and fly one. And people started doing irresponsible things so the regulations started....
I can see the day where with active guidance, especially one that can "shoot down a drone", we will lose a lot of our freedom to fly.


Also, wrt to Boatgeek's comment

To me, that last point is critical. If something is posted on TRF, it is by definition (IMHO, remember IANAL) in the public domain and therefore not subject to ITAR.

If I take information that I know is ITAR and post it on a public forum, that does not mean that info is no longer ITAR.
It means I violated the law and will be subject to punishment, but does not mean the info itself is no longer classified as ITAR

I will also state I am not a lawyer, but work for a company that has to deal with ITAR data and employees are required to get yearly training, and that point is one they beat into our heads every year.

 

[Richard Dierking]

First, Joe quoted something from K-9 that I didn't see. Maybe I missed something? If this quote was revised/deleted, good call K-9!
Good discussion, and I appreciate all the comments, including yours Cris. Things occasionally need to be clarified because situations change. And, I believe you can prohibit bad intent and still allow good development. We should support and encourage the development of technologies within our hobby.
Kind of a side note; if you are trying something like an active system, or really anything out of the norm, it's probably a good idea to get in touch with the Directors/Advisors/Prefect before the launch and describe your project before the launch. We should be open and honest about what we are doing, and seek discussion and maybe even criticism.

Hum... the use of the word "target." Maybe that needs to be clarified a bit with the organizations. Pretty clear to me, but maybe not to some folks. Up and down part. ;-)
Here's an example of using this word. I'm living on a trip, and I'm going to Chicago. Or, my destination is Chicago. I'm living on a trip, and my target is Chicago.

If you think the safety code needs to be revised, how would you word it?
BTW, this thread is kind of coming to a conclusion for me. So far, no one has quoted any law, code, or ruling that prohibits the things I mentioned in Q1 and Q2.

 

[jqavins]

I'm leaving on a trip to St. Louis. I'm not going to make it in one day, so I'm targeting Columbus, Ohio for an overnight stop.

 

[Steve Shannon]

Launching a model rocket towards a target is prohibited by nfpa 1122 4.7:
4.7 Model Rocket Flight Paths. A model rocket shall not be launched on a flight path aimed at a target.

NFPA 1122 does not define what a target is, but tells how to determine definitions that are not specified:
Merriam-Webster’s Collegiate Dictionary, 11th edition, Merriam- Webster, Inc., Springfield, MA, 2003.
Which defines a target as:
a: a mark to shoot at
b: a target marked by shots fired at it
c: something or someone fired at or marked for attack
d: a goal to be achieved

As others have said, Active Control is certainly not prohibited. FAR 101.29(b)(4) requires that information about flight controls for Class 3 rockets be submitted with the application for a certificate of waiver of authorization:
(4) A description of all major rocket systems, including structural, pneumatic, propellant, propulsion, ignition, electrical, avionics, recovery, wind-weighting, flight control, and tracking,
but I’ve not found anything similar for Class 1 (model rockets) or Class 2 (high power rockets).

Laws are made in reaction (or sometimes in anticipation) of undesirable situations. Although there are no laws right now that prohibit flight control it would only take one misuse of a hobby rocket to ruin that for all of us. Sometimes all it takes is for an idea like Yukon K-9’s to catch the eye of the wrong person.

As George pointed out a rocket launched to intercept a drone violates federal laws which make it against the law to shoot at aircraft. It doesn’t matter one iota that the person attempting it owns both drone and rocket.

 

[boatgeek]

...
If you think the safety code needs to be revised, how would you word it?
BTW, this thread is kind of coming to a conclusion for me. So far, no one has quoted any law, code, or ruling that prohibits the things I mentioned in Q1 and Q2.

One approach that I see in the international maritime industry is the Unified Interpretation. The regulation (ie the Safety Code) stays the same because that's really hard to change, but there's an extra description of how it's supposed to work. The USCG does something similar with technical notes for domestic rules. I think this is a spot where TRA and NAR could leave the Safety Codes as they are, but issue guidance on how stabilization and spot landings should be done. That should probably be run by the NFPA rep even if NFPA itself doesn't approve the guidance. In my dream world, the guidance would look something like:
* Active trajectory control is allowed as a safety measure. This includes directional control to reduce tilt/increase altitude, stay within the waiver cylinder, and/or other goals. Rockets may not be aimed at a designated point or moving target except at safe speeds under recovery devices as described below.
* Once a recovery device has been deployed and the rocket is descending at a safe speed, directional controls may be used to return the rocket to a designated point or zone, provided that location has been approved by the RSO and is well clear of areas where spectators may be present.
* "Spot landing" competitions with rockets that are guided or unguided during descent under parachute are acceptable, as long as the landing spot is well clear of spectators and all rockets are intended to land at safe speeds under recovery devices.

That will obviously take some wordsmithing, but you get the idea.

 

[Dudeman247.]

I'm leaving on a trip to St. Louis. I'm not going to make it in one day, so I'm targeting Columbus, Ohio for an overnight stop.

I see what ya did there.

 

[Yukon@K-9 Rocket Tech]

First, Joe quoted something from K-9 that I didn't see. Maybe I missed something? If this quote was revised/deleted, good call K-9!
Good discussion, and I appreciate all the comments, including yours Cris. Things occasionally need to be clarified because situations change. And, I believe you can prohibit bad intent and still allow good development. We should support and encourage the development of technologies within our hobby.
Kind of a side note; if you are trying something like an active system, or really anything out of the norm, it's probably a good idea to get in touch with the Directors/Advisors/Prefect before the launch and describe your project before the launch. We should be open and honest about what we are doing, and seek discussion and maybe even criticism.

Hum... the use of the word "target." Maybe that needs to be clarified a bit with the organizations. Pretty clear to me, but maybe not to some folks. Up and down part. ;-)
Here's an example of using this word. I'm living on a trip, and I'm going to Chicago. Or, my destination is Chicago. I'm living on a trip, and my target is Chicago.

If you think the safety code needs to be revised, how would you word it?
BTW, this thread is kind of coming to a conclusion for me. So far, no one has quoted any law, code, or ruling that prohibits the things I mentioned in Q1 and Q2.

Yes I deleted that part to not spark anything furthur. Basically I thought it would've been a fun project to build a rocket that could take down drone via a net after watching videos on it, but I should've really dug in the laws. Bad Idea, should not pursue such project, stick to stabilization, and ask a adult who knows their stuff before I even think if trying.

 

[Yukon@K-9 Rocket Tech]

Even if the rocket doesn’t have guidance to track and follow a drone, launching at a target is most definitely no good. A drone, even your drone, is a target if you are aiming at it. Just save everyone a lot of hassle and don’t do it. Seriously.

Yes agreed, I really should've checked more things and asked an adult who knows about the laws and things. A YouTube video of such systems dosen't necessarily make it logical for me to assume it's legality. I'll stick to stabilization and not pursue such a project. Let's say I find a way to do it legally, still won't. I am very well convinced now that it is just a general bad idea legal or not.

 

[jqavins]

I am very well convinced now that it is just a general bad idea legal or not.

Glad to hear it. We all live and learn (if we're paying attention).

 

[Richard Dierking]

OK K-9. Yes, that plan was messed up.
Years ago, someone suggested launching rockets and trying to hit some balloons above the range. They're just balloons and it sounded fun to them. Of course I said no (Section/Adult Advisor, NAR #690). I knew the safety code, but more, I knew what our hobby is about. So, it's not just knowing the codes. We have to do our job. And, I know you'll do your part too; keeping our hobby safe and smart.

 

[Steve Shannon]

One approach that I see in the international maritime industry is the Unified Interpretation. The regulation (ie the Safety Code) stays the same because that's really hard to change, but there's an extra description of how it's supposed to work. The USCG does something similar with technical notes for domestic rules. I think this is a spot where TRA and NAR could leave the Safety Codes as they are, but issue guidance on how stabilization and spot landings should be done. That should probably be run by the NFPA rep even if NFPA itself doesn't approve the guidance. In my dream world, the guidance would look something like:
* Active trajectory control is allowed as a safety measure. This includes directional control to reduce tilt/increase altitude, stay within the waiver cylinder, and/or other goals. Rockets may not be aimed at a designated point or moving target except at safe speeds under recovery devices as described below.
* Once a recovery device has been deployed and the rocket is descending at a safe speed, directional controls may be used to return the rocket to a designated point or zone, provided that location has been approved by the RSO and is well clear of areas where spectators may be present.
* "Spot landing" competitions with rockets that are guided or unguided during descent under parachute are acceptable, as long as the landing spot is well clear of spectators and all rockets are intended to land at safe speeds under recovery devices.

That will obviously take some wordsmithing, but you get the idea.

NFPA has annex sections to help flesh out sometimes sparse wording. The challenge, as you obviously understand, is saying no more than what is meant. It’s way too easy to imply something that has no legal basis. We try very hard to limit the rules in NFPA.

 

[Richard Dierking]

Oh, and btw, I've changed my plans too. I'm not planning on having my rocket come down from apogee with no deployment then activating the recovery system. I saw that plan was not well received. So, I'll deploy small parachutes, or side hatches to slow the recovery around apogee. When you do this, it introduces some randomness that might be important to this discussion.
For me, seems controlling the rocket flight on the down part might be of greater concern. So, maybe control so the rocket comes down closer to vertical after apogee? Perhaps we can discuss acceptable velocity after apogee and before other events like main deployment a bit later or in a different post.

 

[cerving]

Do you know if this ruling is written down somewhere? It would be really helpful for these arguments to be able to point to a ruling made by NAR or TRA (or better yet, both) of the point above and that guidance intended to keep the rocket vertical/within the waiver/away from the flight line is OK. Then we could just pull that out whenever this thread pops up again.

Well, NAR sanctions spot landing contests and have had presentations on this subject over the past several years, so I think it can be implied that they are sanctioning controlled landings and active technologies to keep the rocket stable and pointed "up".

 

[georgegassaway]

BUT - once active guidance becomes reasonable, I would almost guaranty that new rules would be created and our hobby could get over-regulated like what appears to be happening with drones and model aircraft.

Became easily possible in 1988, when anyone capable of soldering a couple of 555/556 type IC's on a simple board could do it. Became "reasonable" at least 5 years ago when off-the-shelf model plane autopilots could be used for vertical guidance.

Oh, actually "active" guidance has been used in this hobby since around 1968 or so when the first R/C Rocket Boosted Gliders were flown. I've flown actively guided rocket boosts since 1980 (R/C rocket gliders).

Many self-guided models flown at NAR and TRA launches since the early 1990's. Many self-guided rocket projects entered in NAR R&D competition thru the years. All this before some of you "just discovered" there's guided model projects on the interwebnets.

But the thing is, NOBODY has EVER tried to use any of it against a target.

I don't care what excuses anyone uses that they'll only try to hit THEIR OWN drone or anything else. Doesn't matter.

Don't F*** with ANY SYSTEM that can track and hit an airborne target!

The beauty of sunguidance is that only in theory it could hit a target. But due to lack of Newton-Seconds and a bunch of other major rocket science issues, it will always fall "approximately" 1.0 Astronomical Units short of getting there.

 

[jderimig]

Oh, and btw, I've changed my plans too. I'm not planning on having my rocket come down from apogee with no deployment then activating the recovery system. I saw that plan was not well received. So, I'll deploy small parachutes, or side hatches to slow the recovery around apogee.

I'd still like you to noodle the idea of hitting a specific apogee location. If you can model (or maybe) measure the winds on the way up, then there is a solution for an apogee target and recovery deployment that returns the rocket to another desired spot.

 

[boatgeek]

...
If I take information that I know is ITAR and post it on a public forum, that does not mean that info is no longer ITAR.
It means I violated the law and will be subject to punishment, but does not mean the info itself is no longer classified as ITAR

I will also state I am not a lawyer, but work for a company that has to deal with ITAR data and employees are required to get yearly training, and that point is one they beat into our heads every year.

Fair point. There's some wiggle room here though, because published books on composite propellant would be in public domain. Likewise, published scholarly work is considered public domain. I'm absolutely not saying that this would work for material that was already designated ITAR data, but there's likely some room for published work here to become public domain. Lawyers would of course need to get involved to be sure.

I also would rely on the fact that the Munitions List specifically excludes rockets that carry payloads less than 300km, as well as components (guidance, etc.) for rockets with a range less than 300km. It does include propellants with a specific impulse over 240-260s depending on the formulation. For reference, the CTI K740 C-star has a specific impulse around 225s. As I understand it, that's a pretty high performance solid propellant so we might not really see that many propellant mixes at higher Isp in the Research forum.

 

[jqavins]

I, too, have had employer provided ITAR training annually for many years (but not anymore as I have changed industries). I'm pretty sure that the research forum doesn't need to be restricted for ITAR reasons; I gather that the forum owners' attitude is "better safe than sorry". It's very very unlikely that someone will post original or non-public work there which is potentially subject to ITAR protection, but one never knows for sure.

 

[Richard Dierking]

Vern, I think the statement in note 3 is more of an assumption than a requirement; like you said, kind of an off-hand statement. The section seems to cover the scope of weapons (i.e. things that are intended to do damage), and not things designed for amateur recreation or research. Maybe they made this statement based on their assumption and knowledge of amateur rocketry at the time?

So, over 2 weeks since the original post on June 2nd, and what Vern mentioned is the closest thing to any regulation I've seen regarding prohibiting guidance on amateur rockets. Again, intended for improved recovery, safety, and stability.

Are we done here?

Going forward, does anyone think something needs to be done regarding our safety code for flight control during ascent or landing?

 

[alexzogh]

Darn you Vern!

I have watched these threads ebb and flow for years, and have never seen anyone come close to finding any law or regulation discuss active controls on hobby rockets. I had to find it myself....



Seems pretty clear to me, although I wonder how or why the State Deparment felt the need to wade into NFPA territory and whether or not this is actually enforceable. A "Note" to a paragraph that doesn't apply to our hobby, in regulations that don't apply to our hobby.... Would be like the ATF putting a "Note" in their regulations discussing cable television.

 

[Richard Dierking]

When was this regulation and the note actually written?

Yes, this whole section of regulation isn't relevant to what we do. If you are designating an empty location in the sky, or perhaps a desolate place on a dry lake bed that's within an authorized amateur rocket recovery area would this even be relevant to this regulation? We don't aim at targets.

If it's just intended to prevent research and capability, then time to switch to collecting stamps.

 

[jqavins]

The way I read it, as neither a lawyer nor an expert in interpretting regulations, it seems to say that our hobby is exempt from whatever else that section is regulating, provided no active guidance is used. In other words, it's an exception to the exception. So the rest of the section applies if guidance is used. If one complies with the rest of the section then the exception to the exception doesn't matter.

 

[boatgeek]

Darn you Vern!

I have watched these threads ebb and flow for years, and have never seen anyone come close to finding any law or regulation discuss active controls on hobby rockets. I had to find it myself....

View attachment 421364

Seems pretty clear to me, although I wonder how or why the State Deparment felt the need to wade into NFPA territory and whether or not this is actually enforceable. A "Note" to a paragraph that doesn't apply to our hobby, in regulations that don't apply to our hobby.... Would be like the ATF putting a "Note" in their regulations discussing cable television.

I would bet (though not much money) that this note was added as part of a rulemaking comment process. I'm thinking the State Dept put out a Notice of Proposed Rulemaking with changes to the Munitions List, and someone at a hobby rocketry company noticed. They then put in a comment asking State to clarify that they didn't intend to regulate our hobby. State agreed, and threw in the note. The "active controls" line was probably someone either at State or the rocketry company worked up to try to clarify the NAR Safety Code "no guidance" rule to allow things like George's sun guidance or Jim Jarvis' vertical guidance systems.

Incidentally, does NFPA 1122 have anything about guidance? I think I saw that NFPA 1122 was up for revision before too long. This would be an excellent time to get some clarifying language into the governing regulations.

 

[heada]

Why in the world would a gov agency use a non-gov definition (NFPA is private, not gov) when they have a gov issued definition (FAR 101)? This seems very backwards to me.

22 CFR 121.1 references NFPA quite a lot actually. Did you know you can't export certified motors having more than 5 pounds of propellant? 22CFR 121.1(D) note 1 How does AT and CTI export anything M or larger?

And if your guidance system is not for export, does the state department's munitions export control list (22 CFR 121) even apply?