Exempt Rocket motors Defined

[CoyoteNumber2]

can RCS [...] offer static tests as a service?

That's kind of what they do.

http://www.specificimpulse.com/about.html
The question is: how much are you willing to pay for it?

 

[AlexBruccoleri]

That's kind of what they do.

http://www.specificimpulse.com/about.html
The question is: how much are you willing to pay for it?

ISP is not for hobbyists.

 

[CoyoteNumber2]

ISP is not for hobbyists.

Oh. Silly me.

 

[Steve Shannon]

@Steve Shannon , I have a very specific question. can RCS or @Loki Research offer static tests as a service? @charrington and myself are in a similar situation. We live in apartments and homemade motor mixing and testing is out of the question for a lot of reasons including safety. RCS sells a goody bag of components and grains. Assume the static tester has no design input. They simply follow my instructions for the motor.

Again, IANAL, but nothing in NFPA prohibits any appropriately licensed entity from making and static testing your motor designs on their premises as a service. I don’t see know why design input would be a factor. Tripoli has no authority over what that entity does in the privacy of their own facilities.

But they couldn’t charge you for that service and then bring them to a Tripoli launch and static test them at the launch as a commercial service. My understanding is that our insurance doesn’t cover commercial use like that. Several people have tried to use Tripoli insurance to cover their commercial ventures and we have to keep reminding them that commercial activity is not covered by Tripoli insurance.

 

[AlexBruccoleri]

Again, IANAL, but nothing in NFPA prohibits any appropriately licensed entity from making and static testing your motor designs on their premises as a service. I don’t see know why design input would be a factor. Tripoli has no authority over what that entity does in the privacy of their own facilities.

Thank you for the reply and understood you are not a lawyer. The concern with design input is the motor could then be considered an Ex motor being sold and flown at a Tripoli launch to a flier. My example is somewhat real world. At some point I would like to design and launch my own motor designs. If I could first have one of the manufacturers test it, that would be great for my rocket and safety. In summary I would like to design a motor from a collection of components, then have my design tested. Once tested I would make a copy for a flight at a Tripoli. Is that allowed in your opinion?

 

[StreuB1]

Sans case, closure, nozzle, o-rings a 6” O costs me $875.00, I would thing CTI gets a much better deal on materials and chem’s than I do, but then they have to also pay labor costs which would put them over a grand

OP stated material costs. Labor (fixed costs) would not be included in material (variable) costs.

 

[Steve Shannon]

Thank you for the reply and understood you are not a lawyer. The concern with design input is the motor could then be considered an Ex motor being sold and flown at a Tripoli launch to a flier. My example is somewhat real world. At some point I would like to design and launch my own motor designs. If I could first have one of the manufacturers test it, that would be great for my rocket and safety. In summary I would like to design a motor from a collection of components, then have my design tested. Once tested I would make a copy for a flight at a Tripoli. Is that allowed in your opinion?

I don’t know why it wouldn’t be allowed.
I don’t understand why you don’t just bring it to a launch and static test it there. Or reach out to club members. It can be done by simply inverting it in the ground and igniting it. Then fly it. There have been presentations on characterizing motors by flying them.

 

[AlexBruccoleri]

I don’t know why it wouldn’t be allowed.
I don’t understand why you don’t just bring it to a launch and static test it there. Or reach out to club members. It can be done by simply inverting it in the ground and igniting it. Then fly it. There have been presentations on characterizing motors by flying them.

Okay good enough. To answer your question. It may take a few iterations to get everything right and doing that at a launch may not be practical. Static testing is much better suited for controlled areas with safety measures and data acquisition systems in place. Anyway thanks for replying and I appreciate your patience with all these questions.

 

[jsdemar]

Okay good enough. To answer your question. It may take a few iterations to get everything right and doing that at a launch may not be practical. Static testing is much better suited for controlled areas with safety measures and data acquisition systems in place. Anyway thanks for replying and I appreciate your patience with all these questions.

There should be TRA members in your area (Las Vegas?) that could help with the static testing. It doesn't seem cost-effective to pay a professional company. You could also look for a land owner that would let you come over more often to do static firings. It's fairly simple to cover safety precautions for 38mm and 54mm tests. Building your own test stand with data logging could be a fun project. Lots of people on here would help.

Most people get a start in Research motors through a mentor. Hopefully, this would minimize the number of iterations and loss of hardware.

Start a new thread! Everything in this one has been covered.

 

[AeroTech]

@Steve Shannon , I have a very specific question. can RCS or @Loki Research offer static tests as a service? @charrington and myself are in a similar situation. We live in apartments and homemade motor mixing and testing is out of the question for a lot of reasons including safety. RCS sells a goody bag of components and grains. Assume the static tester has no design input. They simply follow my instructions for the motor.

In theory, yes.

 

[AlexBruccoleri]

@Loki Research I hope you are following this because I think I found your answer. Instead of trying to sell uncertified motors and go that route. Instead you can become a goodie bag of quality components who offers testing services. You could also sell design manuals, books, and a whole bunch of other tools. This keeps you compliant and furthermore it keeps this within the spirit of your university customers. Their students would learn more if their students did the design and data analysis work. Better yet, I suspect very strongly you would make more money going this route too. Students would probably want to test their stuff over and over, and you could sell a lot of components. You could also offer courses too. I took one from Jeff Taylor back in 2003. Anyway I hope this helps.

 

[AlexBruccoleri]

There should be TRA members in your area (Las Vegas?) that could help with the static testing. It doesn't seem cost-effective to pay a professional company. You could also look for a land owner that would let you come over more often to do static firings. It's fairly simple to cover safety precautions for 38mm and 54mm tests. Building your own test stand with data logging could be a fun project. Lots of people on here would help.

Most people get a start in Research motors through a mentor. Hopefully, this would minimize the number of iterations and loss of hardware.

Start a new thread! Everything in this one has been covered.

I live a 25 minute walk from downtown Boston.....Also I have "been there and back again" with static testing and gaining permission. It took months of solid negotiating. I also machined a high quality test stand too with a solid data acquisition system. That being said, that activity is not appropriate for me, especially as a hobby activity. Maybe if I move to the country side, but for now it is out of the question. I also have little interests in ex motors, except I want a lower thrust 54 mm baby M for my Paper and Plywood Challenge to 100k ft. That is where I could see working with @Loki Research where allowed. For the record, I would prefer he certify the motor too so others could enjoy it. I still think his complaints on certification are bizarre, but it is his business and maybe he knows something we do not.

 

[jsdemar]

I live a 25 minute walk from downtown Boston.....Also I have "been there and back again" with static testing and gaining permission. It took months of solid negotiating. I also machined a high quality test stand too with a solid data acquisition system. That being said, that activity is not appropriate for me, especially as a hobby activity. Maybe if I move to the country side, but for now it is out of the question. I also have little interests in ex motors, except I want a lower thrust 54 mm baby M for my Paper and Plywood Challenge to 100k ft. That is where I could see working with @Loki Research where allowed. For the record, I would prefer he certify the motor too so others could enjoy it. I still think his complaints on certification are bizarre, but it is his business and maybe he knows something we do not.

Write up the requirements for your 54mm M motor. I'll design it for you for free, make the hardware at cost, and static test it at the cost of materials. We'll make the design public domain so others can make their own, even Loki.

 

[Steve Shannon]

I live a 25 minute walk from downtown Boston.....Also I have "been there and back again" with static testing and gaining permission. It took months of solid negotiating. I also machined a high quality test stand too with a solid data acquisition system. That being said, that activity is not appropriate for me, especially as a hobby activity. Maybe if I move to the country side, but for now it is out of the question. I also have little interests in ex motors, except I want a lower thrust 54 mm baby M for my Paper and Plywood Challenge to 100k ft. That is where I could see working with @Loki Research where allowed. For the record, I would prefer he certify the motor too so others could enjoy it. I still think his complaints on certification are bizarre, but it is his business and maybe he knows something we do not.

Thank you for your background, Alex.
Tripoli rules allow you working with others to on group projects. Like any hobby, there are people who really shine at every different aspect. I wouldn’t be at all surprised if someone on this forum would be willing to work with you to accomplish what you want. As a group project (neither of you engaging in commercial activities or trying to profit from the arrangement) I don’t believe there would be any issue with you flying the motors.

 

[AlexBruccoleri]

Write up the requirements for your 54mm M motor. I'll design it for you for free, make the hardware at cost, and static test it at the cost of materials. We'll make the design public domain so others can make their own, even Loki.

You have yourself a deal! I will send a pm.

 

[Steve Shannon]

Write up the requirements for your 54mm M motor. I'll design it for you for free, make the hardware at cost, and static test it at the cost of materials. We'll make the design public domain so others can make their own, even Loki.

This is what I love about this hobby and the people in it.
Thank you, John!

 

[Loki Research]

I've been on the road since I postrd this. I'll be back later with some more specific questions.

Scott claims that NFPA 1127 doesn’t apply to him and thus the prohibition in 1127 against selling non-certified motors should not be applied to his motors.

110% correct. Welcome back Steve.

The 1.3.3 exemption grants me this as a licensed business (county license, BATF license, fed EIN, state tax ID# etc.) whom makes solid rocket motors and parts. It is the TRA codes that specificly limit me from (1) selling research motors not under development (Exempt motors) to other exempt entities (universities, not "the public"), (2) making a profit on them, (3) allowing them to fly or (4) selling Demonstration motors that are under development and being allowed to call them Loki motors when they fly at TRA launches.

8.2.3 High-power rocket motors, motor-reloading kits, and components offered for sale, exposed for sale, sold, used, or made available to the public shall be examined and tested to determine whether they comply with the standards and requirements detailed in 8.2.7.

This is what the bold section is talking about by making available to the public in the above code. What I am talking about IS NOT being offered to "the public", has never been offered to the public, but only to other specific 1127 exempt entities. How does this violate 8.2.3?

8.2.3 simply limits certified users (who are not exempt from 1127 as I am) from selling anything that is not certified to the public.

 

[AlexBruccoleri]

The 1.3.3 exemption grants me this as a licensed business (county license, BATF license, fed EIN, state tax ID# etc.) whom makes solid rocket motors and parts. It is the TRA codes that specificly limit me from (1) selling research motors not under development (Exempt motors) to other exempt entities (universities, not "the public"), (2) making a profit on them, (3) allowing them to fly or (4) selling Demonstration motors that are under development and being allowed to call them Loki motors when they fly at TRA launches.

Off topic, but brief. Is an ATF permit required to manufacture APCP commercially?

 

[Loki Research]

Off topic, but brief. Is an ATF permit required to manufacture APCP commercially

No, but it does allow you to purchase materials from many vendors who would otherwise not sell to you without one.

 

[Loki Research]

The caveat is if you use black power as part of you manufacturing process, then yes you do.BP is regulated by batf in commercial use.

 

[Steve Shannon]

I've been on the road since I postrd this. I'll be back later with some more specific questions.

110% correct. Welcome back Steve.

The 1.3.3 exemption grants me this as a licensed business (county license, BATF license, fed EIN, state tax ID# etc.) whom makes solid rocket motors and parts. It is the TRA codes that specificly limit me from (1) selling research motors not under development (Exempt motors) to other exempt entities (universities, not "the public"), (2) making a profit on them, (3) allowing them to fly or (4) selling Demonstration motors that are under development and being allowed to call them Loki motors when they fly at TRA launches.



This is what the bold section is talking about by making available to the public in the above code. What I am talking about IS NOT being offered to "the public", has never been offered to the public, but only to other specific 1127 exempt entities. How does this violate 8.2.3?

8.2.3 simply limits certified users (who are not exempt from 1127 as I am) from selling anything that is not certified to the public.

Scott,
I guess I don’t understand the issue. Entities who are out of scope of 1127 are ungoverned by it. They are either rocket motor professionals, universities, or government entities. What transpires between them is of absolutely no concern to Tripoli.
They are completely separate from Tripoli activities which do fall under 1127. As such are responsible for their own actions, insurance, waivers, etc.

No, the 8.2.3 that I quoted was from 1125 (not 1127). It does not limit certified users as you state. In fact, users of rocket motors who are governed by 1122 and 1127 are out of scope of 1125. 1125 specifically affects those motor manufacturers like you who are out of scope for 1127.

 

[Loki Research]

Well like I said, I've been on the road so not looking directly at the code. There is in Section 6 of 1127 Prohibited Activities (I forget the number) that has pretty much the exact same wording that does apply to certified users.

That being said, even though this section of 1125 does apply to me, I am not offering anything that is not certified "to the public" as the wording of the code states. The products in the link I shared to Action Rockets ARE being offered to the public. That is the difference. That was really the point of the post.

No one in this public square (or any other) has ever been offer a noncertified motor or complete motor components which do make a noncertified motor from Loki Research.

 

[AlexBruccoleri]

@Loki Research In summary you want to sell ex motors to colleges and you want Tripoli to allow college teams to fly them at Tripoli launches as ex motors?

 

[Loki Research]

To the point about any motor not "costing" $1,000, in order to have the components necessary for a certified motor,....

For me to make only one of the 98mm motors I plan on eventually certifying, I have spent in excess of $10,000 just to get the custom drawn motor case tubing only, along with a minimum order of new casting tubes and liners. Those are the only 3 materials I have for over 10 grand. I have a LOT more components and materials left to purchase to get that one first motor made.

As a manufacturer, you can't just go out and buy one of everything to get a motor certified and stay in business. I know what you were trying to say Brian, but it's not fair to look at it that way.

This "cost" doesn't even begin to cover the very large expense and time of testing and new testing equipment, both required and needed before you have a working motor that could produce 1,750lbs of average thrust.

The load cell alone required to measure this force accurately is over $1,000.

 

[Loki Research]

@Loki Research In summary you want to sell ex motors to colleges and you want Tripoli to allow college teams to fly them at Tripoli launches as ex motors?

I want to sell Exempt motors to Universities and have the TRA insure them the same as non-exempt research motors are.

I would also like to have the Demonstration motors (which are allowed, that I sell to Universities & which the TRA codes do allow to be flown by a certified student flier and be insured) also be allowed to be publicly recognized as Loki Research motors.

To date in Argonia, someone has not allowed me or the University fliers this "TRA code defined and TRA code authorized" distinction of Loki Research Demonstration Motor if they are allowed to fly them at all. Take away the Loki name and they're good to go. That really, really PO's me. Seems someone else has not been following their own safety code, again.

 

[Steve Shannon]

To the point about any motor not "costing" $1,000, in order to have the components necessary for a certified motor,....

For me to make only one of the 98mm motors I plan on eventually certifying, I have spent in excess of $10,000 just to get the custom drawn motor case tubing only, along with a minimum order of new casting tubes and liners. Those are the only 3 materials I have for over 10 grand. I have a LOT more components and materials left to purchase to get that one first motor made.

As a manufacturer, you can't just go out and buy one of everything to get a motor certified and stay in business. I know what you were trying to say Brian, but it's not fair to look at it the way I believe you implied.

This "cost" doesn't even begin to cover the very large expense and time of testing and new testing equipment, both required and needed before you have a working motor that could produce 1,750lbs of average thrust.

The load cell alone required to measure this force accurately is over $1,000.

1. Aren’t those costs necessary whether you’re developing a custom motor for a customer or a motor to be certified? Presumably your customers expect some level of reliability, which can only be demonstrated by testing.
2. R&D is expensive. It appears that your new business model is to rely heavily on new motors in new case sizes, and which require complete retooling for testing, which are all R&D expenses, while starving your existing customer base (including me) who have significant investments in pretty blue Loki cases. It’s like you’ve picked the trifecta of how to blow through capital.
3. Please leverage what you have. Rebuild your dealer network.

For eight years I worked for one of the best businessmen I’ve ever known. He had a saying that I think is applicable. He would see a business trying to branch out into new directions that were not directly related to their existing customer base and he would say “They should mind their own business.” He didn’t mean they should keep their noses out of other people’s business; he meant they should pay more attention to the business they already had.
You make great rocket motors and you cover the gamut in sizes and impulse levels. That’s your bread and butter. Don’t neglect that. Allowing yourself to become distracted by the notion of non-certified custom motors could be a mistake.

 

[Steve Shannon]

I want to sell Exempt motors to Universities hand have the TRA insure them the same as non-exempt research motors are.

I would also like to have the Demonstration motors (which are allowed, that I sell to Universities & which the TRA codes do allow to be flown by a certified student flier and be insured) also be allowed to be publicly recognized as Loki Research motors.

To date in Argonia, someone has not allowed me or the University fliers this "TRA code defined and TRA code authorized" distinction of Loki Research Demonstration Motor if they are allowed to fly them at all. Take away the Loki name and they're good to go. That really, really PO's me. Seems someone else has not been following their own safety code, again.

Selling a non-certified motor to a university (an entity which is out of scope of 1127), and then having the university provide it to a student, and then having the student fly it at a Tripoli launch, (launches which substantially comply with the spirit of 1127) is absolutely not what we anticipated when allowed the use of demonstration motors. I’ll have to think about the wording in the definition.
Our intent was to allow a manufacturer, or a manufacturer’s representative, or a flyer who had been provided the motor at no cost by the manufacturer or the manufacturer’s representative, to fly the motor as a demonstration flight. In every instance it was expected that the manufacturer would not only identify the motor, but announce it to create interest for a new product “Here’s the new rainbow propellant from Unicorn Rocketry. We hope to have this motor submitted to TMT within the next few weeks. In the meantime let your favorite vendor know that you want one!” Clearly, the rule that prohibits flying a non-certified motor which has sold for a profit prohibits the model you have chosen to follow.

 

[AlexBruccoleri]

1. Aren’t those costs necessary whether you’re developing a custom motor for a customer or a motor to be certified? Presumably your customers expect some level of reliability, which can only be demonstrated by testing.
2. R&D is expensive. It appears that your new business model is to rely heavily on new motors in new case sizes, and which require complete retooling for testing, which are all R&D expenses, while starving your existing customer base (including me) who have significant investments in pretty blue Loki cases. It’s like you’ve picked the trifecta of how to blow through capital.
3. Please leverage what you have. Rebuild your dealer network.

For eight years I worked for one of the best businessmen I’ve ever known. He had a saying that I think is applicable. He would see a business trying to branch out into new directions that were not directly related to their existing customer base and he would say “They should mind their own business.” He didn’t mean they should keep their noses out of other people’s business; he meant they should pay more attention to the business they already had.
You make great rocket motors and you cover the gamut in sizes and impulse levels. That’s your bread and butter. Don’t neglect that. Allowing yourself to become distracted by the notion of non-certified custom motors could be a mistake.

I would like to add and repeat. Please focus more of your efforts on your current stock and certified motors. You have something “solid”. Please don’t mess it up on distractions. Even my suggestions to expand into RCS style components and services like testing. I really think you should expand what you have. That being said, I am not a fan of other people forcing you into anything. If you want to change the rules, it might be justified on a theoretical level. I still encourage you to drop it for your own good and the good of the hobby.

 

[Loki Research]

R&D is expensive. It appears that your new business model is to rely heavily on new motors in new case sizes, and which require complete retooling for testing, which are all R&D expenses, while starving your existing customer base (including me) who have significant investments in pretty blue Loki cases. It’s like you’ve picked the trifecta of how to blow through capital.

Not at all Steve. You're guessing like many others that you know how to best run this business. I can count on both hands the number of people who have been in my very small shoes with this type of APCP busines, and about half of those people have past on now. You're not on the list.

My business plan is to do all the possible things I can do for my customers a portion of that plan includes doing the things they have been asking of me since I purchased the companyy over 10 years ago.

"When are you going to make 98mm motors again??? I'd love to buy one if you started making them again!"

This is but one portion of what I am doing for my customers. What is slowing me down, keeping customers waiting, are the NFPA requirements that must be met with the extreme variance in materials and pricing that I've had to deal with over the past 2 years. It takes quite a great deal of time to make sure everything burns exactly within spec year after year when materials keep changing due to the supply.

I've had plenty of vendors go out of business or refuse to take our purchase orders any more (we're too small for them to bother with any more) where new materials have had to be sourced. It takes time and money to work through all this. The evaporation of remaining surplus 200AP is only one of those instances we have had, and continue to work through.

These Exempt motors and Demonstration motors are just one portion of the profit area that is available to a manufacturer per the NFPA as I read the codes in context with each other. I see the TRA codes and claims of "we can't insure it without changing NFPA" from preventing manufacturers from accessing this quite large profit area growing within the university system. Major companies are throwing MAJOR money at these universities in order to train them for the positions that keep popping up left and right in the commercial aerospace sector. These motors I make fly from time to time, legally, at other venues, but they are extremely limited because of THE TRA'S RULES.

My market could explode if these Exempt motors were allowed to fly, and the Demonstration motors be recognized at every TRA launch. The people in high places, running things like the Argonia Cup, they know all of this, but it seems they don't want it to happen.

I'll tell you another thing. You and others keep telling me I need to expand my dealer base. Well guess what. That will take another full time employee, one that will be here after 6-12 months and not move on. I cannot afford to whip out $50k for a new college grad that might go poof after a year and start all over. Been there done that several times with part time help. You have zero idea how much product my two main dealers purchase each year. They keep me out of stock for the amount of product one and a half people running this business can make.

What I can afford to do is make Exempt motors and sell them for profit because they can be flown anywhere in the country. It may not matter if I ever make that motor again, but I can profit from it very quickly. I can measure Pc in flight and get acceleration data as well today. You could hardly do this 35 years ago unless you were NASA, and because of that, the codes might have been needed, back then, to prevent others form trying to make home made rocket motors..

Today you are encouraged to learn how to do rocket motor research and given a VAST trove of resources and knowledge in order to be successful at it. The safety concerns of 35 years ago are not the safety concern of today, but they are the hook which the TRA keeps hanging its hat on.

It is time for a change, an overhaul really, but for now, I'm just starting with trying to be able to do all of the profitable things the NFPA codes currently allow. Then I might be able to afford a real employee a salary they will stay here for. Then, maybe others will easily be able to start a company like this one, and then you will see the inovation and selection of brands really take of.

 

[charrington]

Selling a non-certified motor to a university (an entity which is out of scope of 1127), and then having the university provide it to a student, and then having the student fly it at a Tripoli launch, which does attempt to adhere to the spirit of 1127, is absolutely not what we anticipated when allowed the use of demonstration motors. I’ll have to think about the wording in the definition.
Our intent was to allow a manufacturer, or a manufacturer’s representative, or a flyer who had been provided the motor at no cost by the manufacturer or the manufacturer’s representative, to fly the motor as a demonstration flight. In every instance it was expected that the manufacturer would not only identify the motor, but announce it to create interest for a new product “Here’s the new rainbow propellant from Unicorn Rocketry. We hope to have this motor submitted to TMT within the next few weeks. In the meantime let your favorite vendor know that you want one!” Clearly, the rule that prohibits flying a non-certified motor which has sold for a profit prohibits the model you have chosen to follow.

The question I am having is why wont Tripoli allow Loki to sell a research motor that is going to be flown by a university team at a research launch like BALLS? There's so many EX motors that are not certified there anyway that I don't see how this could be a safety or insurance issue.