Exemption of NFPA1127 using section 1.3.3

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Greetings,

I know this must be a very uncommon question but I was hoping someone could help me out.

I own a licensed corporation that is going into the business of selling rocketry components for HPR, whereas I am beginning to do market research on HPR. Because of this, we need to test our components on high-power rockets, however, as everyone knows you need to hold a certification through NAR/TRA/CAR to purchase/use HPR motors.

Pursuant to section 1.3.3 of 1127 any of the following entities are exempt from 1127 (and the certification requirements thereof); an individual, a firm, a partnership, a joint venture, a corporation, or other business entity engaged as a licensed business in the research, development, production, testing, maintenance, or supply of rockets, rocket motors, rocket propellant chemicals, or rocket components or parts.

As my corporation is in the research and development of rocket components and parts my business qualifies for the exemption stated in 1.3.3 of 1127, therefore my corporation is exempt from the high power certification requirements contained in NFPA 1127.

My question relating to all of this is: does anyone know of a high-power motor supplier (Apogee Components, Wildman, MadCow, Etc.) that would honor the exemption, and allow my corporation to purchase high-power motors without holding a certification (L1/2/3) with the NAR/TRA?

Thanks so much for the help!

Noah
 

tsmith1315

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I own a licensed corporation that is going into the business of selling rocketry components for HPR, whereas I am beginning to do market research on HPR. Because of this, we need to test our components on high-power rockets, however, as everyone knows you need to hold a certification through NAR/TRA/CAR to purchase/use HPR motors.

You are going to sell components targeted at the HP crowd with no HP experience? Interesting business strategy. Why not just get certified? Up to level 2 is a pretty simple process. Then youll have some credentials behind your business.

This can't be overstated. Flyers look to their vendors for expert advice.
 

COrocket

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If you are going to be building the rockets yourself and purchasing the motors, might as well just get certified. Sounds like a bigger hassle to work with the exemption rather than just filling out a few forms at the launch site. Its also gonna be a lot easier to fly your rockets at a local NAR/TRA launch, since you won't have to get airspace approval on your own.
 

prfesser

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I will go farther...I'd strongly suggest that you fly a LOT of HPR before thinking about making motors for your own use, let alone to sell. Understanding the problems that can occur with HP motors, solving those problems, giving others expert advice is going to take more than three or four high-power flights.

An HPR motor manufacturer had to discard a (quite expensive) run of casing stock because specifications had been insufficient. Do you know what tolerances are needed? Over-specifying can become very expensive, very quickly. Under-specifying can be even more expensive.

"Can I use XYZ accessory with your 54 mm motors?"
"Why did your starter do this with my motor?"
"The delay was too long! What are you going to do about it?"

All sorts of questions and complaints will need to be fielded.

I know a fair bit about motor-making. I have never, ever considered becoming a manufacturer. It might be fun to think about sometimes but I know my limitations.

Best,
Terry
 

mtnmanak

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I will go farther...I'd strongly suggest that you fly a LOT of HPR before thinking about making motors for your own use, let alone to sell. Understanding the problems that can occur with HP motors, solving those problems, giving others expert advice is going to take more than three or four high-power flights.

An HPR motor manufacturer had to discard a (quite expensive) run of casing stock because specifications had been insufficient. Do you know what tolerances are needed? Over-specifying can become very expensive, very quickly. Under-specifying can be even more expensive.

"Can I use XYZ accessory with your 54 mm motors?"
"Why did your starter do this with my motor?"
"The delay was too long! What are you going to do about it?"

All sorts of questions and complaints will need to be fielded.

I know a fair bit about motor-making. I have never, ever considered becoming a manufacturer. It might be fun to think about sometimes but I know my limitations.

Best,
Terry

It doesn't appear from the OP's first post that they want to manufacture motors, they just want to be able to buy commercial motors without a NAR/TRA cert.

What isn't clear is if this is an existing business that is already manufacturing non-rocket parts and they want to leverage previous manufacturing business experience to get into HPR parts or, is this a new venture that is exclusively trying to manufacture HPR parts? More importantly, there is no mention of what kind of parts this person wants to manufacture, which would have a significant impact on the answer to the question at hand.

Maybe this company already manufactures parachutes or aviation electronics and wants to modify them for rocketry, for example. Who knows?

But, I do think the more pertinent question is whether they plan to use these motors in actual flight tests. If they just need them for static testing, then I can see an argument for not being certified to get the test motors. If they want to actually fly test rockets, then, as has been noted, there is not a lot of reason to get the motors unless they plan to fly somewhere private and handle their own FAA waivers. The motor manufacturers and vendors, I think, would be reluctant to sell motors without these details. As for going to the vendors, it does seem rather odd, since you would have to pay retail prices, whereas you could workout wholesale costs with the manufacturers if the motors are for test purposes.

At the end of the day, the request for info is currently bereft of details and can't be answered properly. The OP is saying, essentially, "I have a company and I want advice". What is needed is the details about what it is, exactly, the company is going to do.

Or, it could just be someone trying to obtain motors without a cert. We have no idea.
 

Steve Shannon

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Greetings,

I know this must be a very uncommon question but I was hoping someone could help me out.

I own a licensed corporation that is going into the business of selling rocketry components for HPR, whereas I am beginning to do market research on HPR. Because of this, we need to test our components on high-power rockets, however, as everyone knows you need to hold a certification through NAR/TRA/CAR to purchase/use HPR motors.

Pursuant to section 1.3.3 of 1127 any of the following entities are exempt from 1127 (and the certification requirements thereof); an individual, a firm, a partnership, a joint venture, a corporation, or other business entity engaged as a licensed business in the research, development, production, testing, maintenance, or supply of rockets, rocket motors, rocket propellant chemicals, or rocket components or parts.

As my corporation is in the research and development of rocket components and parts my business qualifies for the exemption stated in 1.3.3 of 1127, therefore my corporation is exempt from the high power certification requirements contained in NFPA 1127.

My question relating to all of this is: does anyone know of a high-power motor supplier (Apogee Components, Wildman, MadCow, Etc.) that would honor the exemption, and allow my corporation to purchase high-power motors without holding a certification (L1/2/3) with the NAR/TRA?

Thanks so much for the help!

Noah
I agree with all those who think that it’s a bad business plan to try and sell components to a group of people that you choose not to join.
You’re right, exceptions exist to purchase motors without certification.
I’m curious if you have tried reaching out to any of the vendors directly? They would be the ones to ask. They field similar questions from universities.
 
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Hello again,

First and foremost thank you to everyone who responded to my question, I was really concerned that nobody would respond due to the obscurity of the question posed. So thanks for all of the advice!

I do not ever plan on becoming a motor vendor, simply just needed a motor to two (h or I) for a static firing to have data to test avionics systems (my product). I am busy, I also have a full-time job and at first glance, it seemed like a lot of work to go through to get certified and a time-consuming endeavor, but who knows it may just be easier.

Noah
 
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I agree with all those who think that it’s a bad business plan to try and sell components to a group of people that you choose not to join.
You’re right, exceptions exist to purchase motors without certification.
I’m curious if you have tried reaching out to any of the vendors directly? They would be the ones to ask. They field similar questions from universities.
I have not, I wanted to first get some advice (here) so I would not sound stupid if I asked a vendor to buy one without a cert.

But I will ask directly.

Thank you!

Noah
 

Steve Shannon

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Hello again,

First and foremost thank you to everyone who responded to my question, I was really concerned that nobody would respond due to the obscurity of the question posed. So thanks for all of the advice!

I do not ever plan on becoming a motor vendor, simply just needed a motor to two (h or I) for a static firing to have data to test avionics systems (my product). I am busy, I also have a full-time job and at first glance, it seemed like a lot of work to go through to get certified and a time-consuming endeavor, but who knows it may just be easier.

Noah
All you have to do is build and fly one rocket to get certified L1, which allows you to fly both H or I motors (NAR or Tripoli).
 

fyrwrxz

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Noah, where are you physically located? I might be able to help, but I'm at the bottom of Cali. While I no longer have load cells, etc. I may have hardware to be loaned/purchased. . Not being nosy or even volunteering to work on site. Maybe pm me?
 
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heada

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Umm . . . CTI, aka Cesaroni, is in Canada, not the US.

Dave F.
They manufacture in CA but I thought they opened an office in Florida. I know Anthony goes/went between on a regular basis.

Question is moot since the easiest solution is to get certified.
 

CoyoteNumber2

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just needed a motor to two (h or I) for a static firing to have data to test avionics systems (my product).

I don't know what you have planned, but I can't think of a scenario where you'd need to static-fire a motor to test avionics, aside from Research-type stuff like sampling chamber pressure or casing temperature. What conditions are you trying to simulate with said test?
 

StreuB1

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Few if any people in this hobby will buy from someone who isn't a flyer and is someone who we all don't know. This is a very very very tight knit hobby. Based on what you have already posted, you know little about us or our hobby. And for that, even if you are the cheapest guy on the block, few will buy from you. Especially considering what it is that we do and what we have gone through with the federal government.

No offense, but we don't trust people. Coming onto this forum with 6 posts and then making this thread, you've now got a target of question on you by nearly everyone.

Take my words literally for what they are. No insult or harm intended, it is literally fact of the matter.
 

CoyoteNumber2

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it is literally fact of the matter.

I think the words you're looking for are "my opinion."

No offense, but we don't trust people. Coming onto this forum with 6 posts and then making this thread, you've now got a target of question on you by nearly everyone.

I wouldn't be so sure. Every year, the day after Thanksgiving, people in this hobby throw their money at a vendor with a well-known history of not delivering paid-for orders. Sounds pretty trusting to me.

Especially considering what it is that we do and what we have gone through with the federal government.

I don't see what the Feds or the ATF lawsuit have to do with anything. Even if Noah is marketing the Super Lawbreaker 3000, you and I are the end-users. I.e., it's up to us (rocketeers) to not do anything dumb.

Caution is always warranted, but there's no need for fearmongering. Let's give Noah a chance to plead his case. We want him to feel welcome and get certified, right?
 

cerving

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As an avionics manufacturer I can tell you categorically that you 100% need to be involved in the hobby if you want your product to have any credibility in the market. You are going to get a LOT of questions about how to apply your products to different use cases... you should have experience with as many of those as possible in order to answer those questions intelligently. Having somebody else do all your testing for you is not going to cut it. You need first-hand experience.

You don't mention how much rocketry experience you have, or what kind of avionics you are planning to sell. I get the latter... you may not want to show your hand until you introduce your products. Personally, I like that strategy, vs. the "Here's what we're going to be selling real soon now" strategy, that can ruin your credibility if for some reason you don't deliver "real soon now". As far as the rocketry experience, hopefully you have some MPR experience but just not HPR. It's not a huge step from MPR to Level 1. Level 2 takes a bit more work, and Level 3 requires a lot more work/time plus you have to be able to show to your TAP/L3CC that you know what you're doing. Get your Level 1, fly some avionics with Level 1 motors until you feel comfortable, then get your Level 2 and repeat the process. If you have your Level 2 and enough experience to answer questions about your products, that will most likely be enough. The cost of the rockets, motors, and everything else you need to support a launch (which ends up being a lot, BTW) is part of the cost of doing business.

Of course, once you get the bug you'll just HAVE to get your Level 3...
 

StreuB1

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I think the words you're looking for are "my opinion."



I wouldn't be so sure. Every year, the day after Thanksgiving, people in this hobby throw their money at a vendor with a well-known history of not delivering paid-for orders. Sounds pretty trusting to me.



I don't see what the Feds or the ATF lawsuit have to do with anything. Even if Noah is marketing the Super Lawbreaker 3000, you and I are the end-users. I.e., it's up to us (rocketeers) to not do anything dumb.

Caution is always warranted, but there's no need for fearmongering. Let's give Noah a chance to plead his case. We want him to feel welcome and get certified, right?

You're right. I should have stated that it was my opinion.

For good reason, I get itchy any time someone talks about how to bypass regulations that our hobby hinges upon.
 

sharkbait

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I don't know what you have planned, but I can't think of a scenario where you'd need to static-fire a motor to test avionics, aside from Research-type stuff like sampling chamber pressure or casing temperature. What conditions are you trying to simulate with said test?
I too have no idea what a static test fire is going to give you that you would need for avionics, the Pro38 website for Cesaroni gives you pretty much all the data for each motor except chamber pressure and temperature. Maybe you could expand on your definition of what kind of avionics product or products are you talking about, and folks could weigh in with their opinions and or advice that could potentially save you a lot of time, effort, and money
 

cbrarick

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I guess i'm a little skeptical about someone without rocketry experience trying to get in the market.
We don't want or need what the big guys use.
Our concerns tend to be a lot different then theirs.
We need avionics that do dual deploy
If we're doing staging or air starts, we need avionics that make smart decisions on the go-no go based on the facts we want to use, not based on some fiction the avionics produce (We had this discussion at METRA this weekend)
We would like (or maybe need) a way to find our rocket
All of which we need to do in our typical flight envelope (<20k on the east coast, higher for the lucky people in the central and west coast)
All of which it needs to to reliably, with easy mounting, setup and use
Oh, by the way, we want it inexpensively and for you to have LOTS of stock so I can order on monday for the weekend's launch

None of my flight avionics have been anywhere near a static burn, nor will they ever be. I've got a DAQ on a test stand with thrust and pressure, so I won't move off of that. I'm not certain why you'd be interested in the extremely small group of people who do static burns that are fully instrumented. Bet that number isn't north of 200 people total.

being in our little hobby and flying at your local club will build up some credibility. I don't know of any successful vendors who have broken into our hobby without some sort of history. I hope you get to fly and lean what the flyers you meet are really looking for. I used to fly a certain altimeter that was a PIA to wire up, hard to program and wasn't very user friendly. I've eliminated them all with better options since then. Making similar avionics may get you strong initial buying but no return customers. In my ebay fleet, I have a 8" ebay with 2 altimeters, a 6 inch with 2 altimeters, a 4 inch with 2 altimeters, four 3 inch ebays with i altimeter each and four ebays that are smaller then 3 inches. Probably similar to many other L3 flyers - with a total of 14 altimeters in my front line fleet of ebays. A better mouse trap may cause me to buy up to 15 altimeters if they were better then what I currently have.

Just my humble opinion
 

MariePerry

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I guess i'm a little skeptical about someone without rocketry experience trying to get in the market.
We don't want or need what the big guys use.
Our concerns tend to be a lot different then theirs.
We need avionics that do dual deploy
If we're doing staging or air starts, we need avionics that make smart decisions on the go-no go based on the facts we want to use, not based on some fiction the avionics produce (We had this discussion at METRA this weekend)
We would like (or maybe need) a way to find our rocket
All of which we need to do in our typical flight envelope (<20k on the east coast, higher for the lucky people in the central and west coast)
All of which it needs to to reliably, with easy mounting, setup and use
Oh, by the way, we want it inexpensively and for you to have LOTS of stock so I can order on monday for the weekend's launch

None of my flight avionics have been anywhere near a static burn, nor will they ever be. I've got a DAQ on a test stand with thrust and pressure, so I won't move off of that. I'm not certain why you'd be interested in the extremely small group of people who do static burns that are fully instrumented. Bet that number isn't north of 200 people total.

being in our little hobby and flying at your local club will build up some credibility. I don't know of any successful vendors who have broken into our hobby without some sort of history. I still believe that people have reached a level of development and should if they have their business use sources that will help them with the financial side, I for example use https://fitmymoney.com/tax-refund-loans/ because it is much easier and beneficial to use experts who know what they are doing and not burn out financially. By the way this company helps with tax refund loans, you can go in and see, there are many things there that could help you. Probably similar to many other L3 flyers - with a total of 14 altimeters in my front line fleet of ebays. A better mouse trap may cause me to buy up to 15 altimeters if they were better then what I currently have.

Just my humble opinion
Hey, Cbrarick, I'm also new and without rocketry experience, so do you also consider I have no chances on market?
 
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cbrarick

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Hey, Cbrarick, I'm also new and without rocketry experience, so do you also consider I have no chances on market?

You could be the first, or perhaps the second. Not sure.
The real question is, did you do your research, do your business planning and have a viable plan? What is your profit margin, and does your product differentiate from what's out there in a way that the rocketeer would find useful and worth their money? How will you accomplish market penetration given the unique nature of a small niche hobby? How many units can you produce and sell and what will that net you? Will it be worth your time?
I'd be more likely to be interested in a product from Joe Rocketeer, Level 3, member of WOOSH and flys regularily at Bong, and my friend from URRG knows him and vouches he's a good flyer with a solid track record. Or perhaps it's someone I see at Red Glare or URRF or NYPOWER and have some history with. If not, I'll look, listen and probably wait until someone I knew flew your product. Then I'd consider it. (but that's just what I do, I don't speak for anyone in the hobby but myself.)

I don't know you, but are you willing to bet your pile of money that you could do what most can't?
good luck if you do.
 
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