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boatgeek

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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?
CFRs incorporate other regulations by reference all the time. They probably didn't use FAR 101 because Class 3 (P motors and above) is unlimited. There isn't a handy distinction in there between the very high end of our hobby (R? S?) and rockets intended to go 300km downrange. If they had used FAR 101, every rocket over O could be considered ITAR, and we wouldn't have threads here about those cool projects.
 

Richard Dierking

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Joe, are you just not admitting that you are a lawyer? "Exception to the exception" sure sounds like lawyer-talk to me. ;-)

I think there needs to be some well thought-out rules/codes about what's allowed. Like in that NFPA revision coming up. Somebody is going to do some foolish thing (hum, what have we seen, what could that be) and we would probably end up with a poorly written knee-jerk regulation that will severely limit our development in this hobby. At least if we had something concise on the books, when someone does something stupid, we could point to the code and say we already knew that was wrong; so, no reason creating some new regulation.
 

Steve Shannon

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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.
NFPA 1122 says nothing about guidance. Same for 1127.
 

boatgeek

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NFPA 1122 says nothing about guidance. Same for 1127.
Is that something that NFPA would be willing to add/something that TRA would want to get into? As discussed as nauseum in this and other threads, it would be really nice to have some guardrails that are written down as opposed to extrapolated from the NAR and TRA Safety Codes.
 

Steve Shannon

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Is that something that NFPA would be willing to add/something that TRA would want to get into? As discussed as nauseum in this and other threads, it would be really nice to have some guardrails that are written down as opposed to extrapolated from the NAR and TRA Safety Codes.
Probably not; most regulators don’t comment on non-regulated activities. Simply state the regulations. If something isn’t regulated you don’t include a statement to that effect. It would be confusing and possibly in conflict with other regulations.
It’s simple. If something isn’t mentioned in regulations it’s not regulated.
 

Richard Dierking

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So, more than a week past without any additional posts.
I'm a bit disappointed about Steve's last comment. But, on the other hand, I understand his position on this. It might be a good idea to keep our "ear to the ground." Or, would that be the sky?
There is that nagging note in 22 CFR 121.1, but I'm not going to loose any sleep on that one! All my questions answered.
I"ll post something separate about my little project. To be honest, I know what I would like to do and don't currently know how I'm going to get there. Just going to plug away. I will be focusing my efforts on control of direction, like straight up! Start by leaning rocket away from the flight line, then at some point, rolling the rocket as necessary, and pitching it up and trying to keep it straight up to apogee. All, with two control surfaces. Perhaps someday I will try to use GPS, but I want to wait and watch a bit before thinking about doing that.
 

Steve Shannon

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So, more than a week past without any additional posts.
I'm a bit disappointed about Steve's last comment. But, on the other hand, I understand his position on this. It might be a good idea to keep our "ear to the ground." Or, would that be the sky?
There is that nagging note in 22 CFR 121.1, but I'm not going to loose any sleep on that one! All my questions answered.
Snip…
I understand your disappointment. I’ll try to explain the logic.
Regulations or rules are either prohibitive or inclusive but logically cannot be both, at least not easily. Although it’s not a legal regulation an example of an inclusive rule is the Tripoli Research Safety Code rule that inclusively lists which sugars may be used as the primary fuel in sugar motors. Because we list which ones may be used, no others may be used as the primary sugar fuel. That’s very straightforward. If we chose to use a prohibitive rule and list which ones were prohibited, any sugar not listed could be used, which was what we tried to prevent.
That also demonstrates that an inclusive list type rule is actually more restrictive and really only effective when there is a single rule maker. But it leaves a much greater opportunity for confusion whenever multiple regulators exist and more importantly it leads to much less freedom because it requires that the rule maker must approve everything.
Prohibitive rules work much more narrowly by only listing those things which are prohibited. That’s really how we should want regulations to work. That’s how most of the NFPA rocketry regulations work. Attempts to clarify a prohibitive rule by adding inclusive language simply creates confusion.
For instance, if we make a rule that prohibits blue rockets and then add a rule that permits red rockets, every other color has a question mark attached.
 

jqavins

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That example suggests possibilitites like my exception interpretation from a few posts back. Blue rockets are prohibited, (implying that all other colors are allowed). A clarification is added that violet is not, under this regulation, considered blue, and is therefore not prohibited. So far so good. Then comes the exception to the exception: pale violet, which may also be called lavender, is considered blue and is therefore prohibited. When laid out step by step it's understandable, but it brings on confusion in practical terms.
 

Steve Shannon

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That example suggests possibilitites like my exception interpretation from a few posts back. Blue rockets are prohibited, (implying that all other colors are allowed). A clarification is added that violet is not, under this regulation, considered blue, and is therefore not prohibited. So far so good. Then comes the exception to the exception: pale violet, which may also be called lavender, is considered blue and is therefore prohibited. When laid out step by step it's understandable, but it brings on confusion in practical terms.
Exactly correct and why that exception to an exception (that’s how I interpreted it also) is terribly written.
 

boatgeek

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Exactly correct and why that exception to an exception (that’s how I interpreted it also) is terribly written.
I think I saw above that NFPA doesn't have any regulations on guidance. That (to me anyway) indicates that the only restriction is from the NAR and TRA safety codes. That's assuming that guidance on our rockets doesn't go to the Munitions List because our range is less than 300 km from the launch point. Is that accurate?

If so, then either TRA or NAR (or both) could issue position papers on what they consider acceptable under the safety codes, which can be updated as technology evolves. This process would be much like the requirements to use electronic deployment for VMax motors or what switch arrangements for altimeters effectively inhibit charge firing. Something like that would be really helpful--it's not a regulation, it's policy for use of NAR/TRA safety codes and it would eliminate these arguments that pop up every single year.
 

Steve Shannon

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I think I saw above that NFPA doesn't have any regulations on guidance. That (to me anyway) indicates that the only restriction is from the NAR and TRA safety codes. That's assuming that guidance on our rockets doesn't go to the Munitions List because our range is less than 300 km from the launch point. Is that accurate?

If so, then either TRA or NAR (or both) could issue position papers on what they consider acceptable under the safety codes, which can be updated as technology evolves. This process would be much like the requirements to use electronic deployment for VMax motors or what switch arrangements for altimeters effectively inhibit charge firing. Something like that would be really helpful--it's not a regulation, it's policy for use of NAR/TRA safety codes and it would eliminate these arguments that pop up every single year.
It’s clear from NFPA and our organizations’ collective safety codes that launching against targets is forbidden. Federal law prohibits targeting aircraft in any way. I’m not sure what else to tell you or why you’re having a problem understanding that what’s left is permitted but you need to use common sense. Most simply put, don’t be stupid and don’t make something that could be mistaken for a weapon or that brings the scrutiny of the federal agencies who could seek to regulate us out of existence. This has been explained here and other places many times but people keep insisting on having a bright line drawn. Bright lines are regulations. Regulations are almost always reactions to people doing stupid things.
 

boatgeek

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It’s clear from NFPA and our organizations’ collective safety codes that launching against targets is forbidden. Federal law prohibits targeting aircraft in any way. I’m not sure what else to tell you or why you’re having a problem understanding that what’s left is permitted but you need to use common sense. Most simply put, don’t be stupid and don’t make something that could be mistaken for a weapon or that brings the scrutiny of the federal agencies who could seek to regulate us out of existence. This has been explained here and other places many times but people keep insisting on having a bright line drawn. Bright lines are regulations. Regulations are almost always reactions to people doing stupid things.
I've pushed on this because this is the only item in the Safety Code that has regular questions about what the Code means and what is allowed. You can set your watch by the threads here asking about guidance, where different reasonably well-informed people will say that:
You can't aim at an aircraft or do something else that looks like a weapon
You can't do any kind of guidance ever
You can use guidance to aim the rocket vertical, but not at a point in the sky or over a point on the ground
You can use active guidance after a parachute has deployed (aka spot landings and the guided chute system Apogee is developing)
You can't do spot landings no matter what because that's aiming at a target even if the rocket recovers at a safe speed

I'm pretty sure all of these opinions have shown up in this thread, with real project examples of safe and unsafe guided rockets. To me, that indicates that the rule in the Safety Code needs to be updated or clarified. IMHO, it doesn't benefit anyone to have people dragging up regulations from the Munitions List because that's the only place that guided rockets are discussed. I definitely take your point that NFPA isn't an appropriate place to do that. It seemed to me that a very short statement from TRA and/or NAR giving general rules about what is allowed and what is not under their own Safety Codes would resolve most of these threads without getting any regulatory agencies involved. However, it's also clear that's not going to happen, so I'll bow out now and will stay out of future threads.
 

Steve Shannon

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I've pushed on this because this is the only item in the Safety Code that has regular questions about what the Code means and what is allowed. You can set your watch by the threads here asking about guidance, where different reasonably well-informed people will say that:
You can't aim at an aircraft or do something else that looks like a weapon
You can't do any kind of guidance ever
You can use guidance to aim the rocket vertical, but not at a point in the sky or over a point on the ground
You can use active guidance after a parachute has deployed (aka spot landings and the guided chute system Apogee is developing)
You can't do spot landings no matter what because that's aiming at a target even if the rocket recovers at a safe speed

I'm pretty sure all of these opinions have shown up in this thread, with real project examples of safe and unsafe guided rockets. To me, that indicates that the rule in the Safety Code needs to be updated or clarified. IMHO, it doesn't benefit anyone to have people dragging up regulations from the Munitions List because that's the only place that guided rockets are discussed. I definitely take your point that NFPA isn't an appropriate place to do that. It seemed to me that a very short statement from TRA and/or NAR giving general rules about what is allowed and what is not under their own Safety Codes would resolve most of these threads without getting any regulatory agencies involved. However, it's also clear that's not going to happen, so I'll bow out now and will stay out of future threads.
I respect you a ton. You’re a PE with a ton of experience including compliance. If you would like to suggest how to clarify this subject (not just that it needs more clarification) I will listen and sincerely consider your ideas.
 

boatgeek

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I respect you a ton. You’re a PE with a ton of experience including compliance. If you would like to suggest how to clarify this subject (not just that it needs more clarification) I will listen and sincerely consider your ideas.
Thank you for the kind words. I will think about it a bit and send you some proposed language, either in this thread or via PM, whichever you prefer.
 

Richard Dierking

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No rule is going to be perfect. And, there will be exceptions. I think the most important thing is to encourage people to discuss their projects on RF, let officials at launches know well in advance of anything out of the ordinary, and for us to do our jobs keeping launches safe.

Steve can be firm, but he also knows the worst thing to do is not to listen.

Some people creating TVC systems are designing rockets that are not aerodynamically stable (e.g. CP-CG is 0 or close to it). So, when does the rocket reach a sufficient velocity to be stable? How about never. The rockets launch directly off their pad with no launch rod, rail, or tower. They don't lean their rockets away from themselves or spectators. For one of my projects, I don't even use a pad! Ironically, I wouldn't even use a blast deflector on the ground, but it's in the safety code.
What happens when people start landing their rockets under power? I've used retro rockets on my projects. But, no one will ever land a rocket under power. LOL

And, it would be a good thing to be able to direct your rocket during recovery and keep it in the established recovery area. Sometimes it's very difficult to do this with high alt projects, and even lower alts when the recovery area isn't large.

I know it doesn't seem logical to many people, but providing some guidance on what is allowed might actually encourage people to develop and test new flight control technologies. You know, here are the rules, now go for it!
 

Steve Shannon

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No rule is going to be perfect. And, there will be exceptions. I think the most important thing is to encourage people to discuss their projects on RF, let officials at launches know well in advance of anything out of the ordinary, and for us to do our jobs keeping launches safe.

Steve can be firm, but he also knows the worst thing to do is not to listen.

Some people creating TVC systems are designing rockets that are not aerodynamically stable (e.g. CP-CG is 0 or close to it). So, when does the rocket reach a sufficient velocity to be stable? How about never. The rockets launch directly off their pad with no launch rod, rail, or tower. They don't lean their rockets away from themselves or spectators. For one of my projects, I don't even use a pad! Ironically, I wouldn't even use a blast deflector on the ground, but it's in the safety code.
What happens when people start landing their rockets under power? I've used retro rockets on my projects. But, no one will ever land a rocket under power. LOL

And, it would be a good thing to be able to direct your rocket during recovery and keep it in the established recovery area. Sometimes it's very difficult to do this with high alt projects, and even lower alts when the recovery area isn't large.

I know it doesn't seem logical to many people, but providing some guidance on what is allowed might actually encourage people to develop and test new flight control technologies. You know, here are the rules, now go for it!
Thanks for the compliment. I do appreciate it.
Active systems have the potential to reduce our chances of flying outside of our authorized airspace. FAA appreciates that. But what we must be careful about making too easily available outside our community are technologies that could be misused as weapon delivery systems or for other criminal activities such as smuggling. I cringe at the thought of creating rules for this subject. Rules only limit the actions of people who care about following rules.
 

mikec

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No rule is going to be perfect.
I'd frankly rather see no rule than a overly-constraining one-size-fits-all rule. As Einstein said in a different context, "everything should be as simple as possible, but no simpler."

No hobby TVC rocket is ever going to be so foolproof and reliable that it has no chance of being unstable. We already account for instability in conventional rockets with the impulse-based standoff distance. If those standoff distances aren't far enough to account for TVC, then move such a rocket out farther. That's what I've always done as an RSO when such things have come up. But if we were to define an exhaustive set of rules, where would that process stop?

If the hobby were full of actual TVC safety horror stories I would feel differently, but I'd prefer to avoid adding rules that address things that were only hypothetical problems.

As for misuse, that is a can of worms and a slippery slope you don't want to go down, because the banning of the hobby is at the bottom.
 

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I personally vote for leaving things as they are and support Steve's initial response. It is usually the same people that have issues with something like this, and recurrently want something done to their satisfaction. TRF is a small group of people, some more verbal than others, that do not necessarily represent the majority of those building and flying rockets. Remember the recent directive regarding switches? That issue would pale in comparison to this topic if it ever evolves to making rules.
 
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DaveW6DPS

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And, I should have added that you are a good listener Steve.
Frankly, I don't know how you do it; following so many conversations and doing such a good job at it.
Especially given the twists and turns of this thread. I lost patience in the middle of page two. You remained reasonable throughout.

My compliments!
 

Steve Shannon

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Especially given the twists and turns of this thread. I lost patience in the middle of page two. You remained reasonable throughout.

My compliments!
If you mean me, I’m pretty sure I was cranky a couple times, but I really do appreciate your kindness and I apologize if my tone makes people give up.
 
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