GuyNoir
Well-Known Member
Attached below is the draft of the comments I intend to file with the
FAA on their NPRM.
Feedback is welcome.
Additionally, you may also wish to check out:
https://dms.dot.gov/search/searchResultsSimple.cfm?numberValue=27390&searchType=docket
which shows all comments filed in the docket to date.
I'll be out of town from Thursday through Saturday afternoon, and will
incorporate comments into the final response after I return.
From the feedback I've received thus far, it's clear that two critical
elements of the NPRM need our strong response. As written, the NPRM
could be interperted to prohibit launches within 5 miles of an airport,
and require detailed information be filed on EVERY rocket to be flown
under a waiver. Even if folks do nothing other than to suggest the FAA
needs to change these elements, letters would be appreciated.
Relative to the NAR's response, I'd like a "straw poll" here to let me
know how many of you would be affected by the 5 mile prohibition.
Background data like that would be useful to have in finalizing this
response.
= = = = = = = = = = == = = = == = = = == = = = == = = = == = = = == = = = =
DRAFT - NAR RESPONSE TO FAA NPRM
September 1, 2007
Docket Management Facility
U.S. Department of Transportation
1200 New Jersey Avenue, SE.
West Building Ground Floor, Room W12140
Washington, DC 20590
Charles P. Brinkman
Licensing and Safety Division (AST200)
Commercial Space Transportation
Federal Aviation Administration
800 Independence Avenue
Washington, DC 20591
Re: [Docket No. FAA200727390; Notice No. 0706]
Dear Mr. Brinkman:
I am please to present comments on behalf of the National Association of
Rocketry (NAR) on the FAAs Notice of Proposed Rulemaking (NPRM), Docket
No. FAA200727390, as published and amended in the Federal Register.
Background
The National Association of Rocketry (NAR) is a non-profit scientific
organization dedicated to safety, education, and the advancement of
technology in the sport rocket hobby in the United States. Founded in
1957, the NAR is the oldest and largest sport rocketry organization in
the world, with over 4,500 members and 110 affiliated clubs.
NAR publishes the bimonthly color magazine Sport Rocketry, which goes to
all NAR members and to libraries and newsstands around the nation. The
NAR also provides a wide range of other services to its members,
including national and local competitions, flight performance record
recognition, liability insurance, and technical literature publication.
NAR provides supports to teachers and students in the form of grants and
scholarships. NAR co-sponsors, with the Aerospace Industries Association
(AIA) the Team America Rocketry Challenge (TARC), an engineering
challenge contest for middle and high school students.
The NAR's primary orientation is consumer safety and youth education. It
is the recognized national testing authority for safety certification of
rocket motors in the U.S. and is the author of Safety Codes for the
hobby that are recognized and accepted by manufacturers and public
safety officials nationwide. It plays a strong role in the establishment
of national standards for public safety officials through its
participation in the National Fire Protection Association. It functions
as the consumer liaison and the voice of its members with hobby
manufacturers, national media, local public safety officials, and
Federal and state government regulatory agencies.
The foundation for defining the scope of sport rocketry and the rules by
which it is conducted without hazard to the public is a set of Codes
from the National
Fire Protection Organization (NFPA). The NFPA is an independent,
non-profit organization of public safety officials, industry, and safety
experts whose
mission is to develop consensus codes that reduce the worldwide burden
of fire and other hazards to quality of life and public safety. NFPA
Codes 1122 (Model
Rocketry) and 1127 (High Power Rocketry) provide detailed guidelines for
safe conduct of private sport rocket launch activities for both the
hobbyists and
educators that conduct such launches and for public safety officials who
may oversee them. It should also be noted that NASA fully accepts and
follows the NAR safety code for range operations in its Student Launch
Initiative, a program that uses sport rocketry to train young engineers.
These Codes were developed by safety experts and public safety officials
based on a 25 year program of thorough technical analysis, experimental
testing and
repeated NAR studies. A partial list of NAR safety studies includes:
1978 - Model Rocket Motor Shipping Safety
1985 - High Power Rocket Safety
1991 - Burn Tests of Reloadable Motors
1992 - Model Rocket Motor Burn Tests
1994 - Overall Safety of Reloadable Motors
1995 - Hybrid Motor Technology
1996 - Safety Analysis of Manufacturers' Maximum Recommended Liftoff Weight
1997 - Radio Controlled Glider Safety Code Development
1999 - Tests of Cleared Distance Required for High-Power Rocket Launches
1999 - Implementation of the NARs "Trained Safety Officer" program
2001 - Model Rocket Safety Code End-to-End Review
2005 - Special Study on Range Operations and Procedure
Most importantly, the NAR has historically worked with the FAA to insure
safe use of the nations airspace, consistent with reasonable access for
sport rocket flyers. It was the NAR who, in 1963, first approached the
FAA regarding potential rules for model rocket launches. As both the NAR
and the sport rocket hobby grew, NAR members have worked with local FAA
staff to secure airspace waivers as required for launches, and produced
a 44 year safety record unmatched in the rest of aviation.
Class 2 Large Model Rocket Definition
The FAA proposes to retain the current distinctions between model
rockets and large model rockets by categorizing such vehicles as Class
1 and Class 2 rockets. These classes differ solely by maximum liftoff
weight (16 ounces / 453 grams vs. 53 ounces / 1,500 grams). (Federal
Register / Vol. 72, No. 114, pgs 32820-32821).
Computer flight simulation of Class 1 and Class 2 vehicles were made to
demonstrate the heavier models have far less velocity and altitude
potential. The simulation used a commercially available motor containing
the maximum amount of propellant under the proposed 125 gram limit.
Flight conditions were set to standard conditions (sea level, 59 degrees
Fahrenheit, 29.92 barometric pressure) with no wind.
Class 1 Vs. Class 2 Flight Simulation Results
Vehicle Characteristics Class 1 Model Class 2 Model Difference
Motor Propellant Weight 114.7 grams
(Aerotech H242T) 114.7 grams
(Aerotech H242T) -
Body Diameter 38 millimeters 38 millimeters -
Model Airframe Weight 174 grams 1,221 grams 1,047 grams
Total Liftoff Weight 453 grams 1,500 grams 1,047 grams
Estimated Drag Coefficient (Cd) 0.75 0.75 -
Maximum Altitude (meters) 1,257 810 (447)
Maximum Altitude (feet) 4,124 2,657 (1,467)
Maximum Velocity (m/sec.) 376 136 (239)
Maximum Velocity (f/sec.) 1,233 448 (785)
Maximum Acceleration (Gs) 57.5 16.4 (41)
The heavier model reaches only 64% of the altitude, 36% of the maximum
velocity and 29% of the acceleration of the lighter vehicle.
The simulation results demonstrate that heavier rocket attain less
altitude, and have lower velocity and acceleration than lighter rockets
which have been operating safely for more than 45 years.
The NARs own flight experience with rockets in the proposed Class 1
dates back to 1957, without any life threatening personal injury or
airspace incidents. The NARs experience with the proposed Class 2
rocket began in 1991 and has compiled and equally outstanding safety
record. Total ground property damage claims filed under the NARs
insurance program have totaled less than $10,000 over the 49 year
history of the Association.
This track record supports the NARs position that both the proposed
Class 1 and Class 2 rockets can be flown using operating limitations
proposed for Class 1.
FAA provides no historical or technical basis for why the increased
weight justifies a separate classification with different operating
limitations.
Thus, the NAR proposes the Class 1 and Class 2 be collapsed into a
single classification (Class 1) using the proposed Class 1 operating
limitations. The change in definition would simplify FAAs operations
without any adverse impacts on air or ground safety and bring FAA
operations in synch with existing rocketry Safety Codes.
101.25 Operating Limitations for Class 3High Power Rockets.
(a ) Technical Correction - The FAA states that Currently, rockets that
would be Class 3 operate under the provisions for Large Model Rockets.
This is technically incorrect since Large Model Rockets operating under
current FAA rules simply require notification to the appropriate ATC,
while larger rockets which would be Class 3 under proposed rules must
secure an airspace waiver for sections of FAR Part 101 in order to operate.
(b) Responsible Range Person - The NAR supports the FAAs proposed rule
that a person at least eighteen years old must be present and in charge
of ensuring the safety of the operation.. For Class 3 (high-power)
sport rocket ranges, the current NFPA Code 1127 requirement is that
there be a Range Safety Officer (RSO) in charge with overall
responsibility for the safety, setup, and launching of all high-power
rockets who is a certified user of such rockets. The NFPA Code further
requires that such certified users must be at least 18 and must possess
a level of knowledge and competence in using high-power rockets that is
acceptable to a recognized certifying organization such as the NAR.
(c) Fire Control - The NAR supports the FAAs proposed rule that
reasonable precautions to report and control a fire. The NARs most
recent safety study, available at:
https://www.nar.org/pdf/launchsafe.pdf, reads in part:
NFPA 1127 Code for High Power Rocketry (2002 Edition) contains a
Launcher Clear Distance table which specifies the radius this
clearance must be done, by motor power class. This table was tested at
the low end by actual field experiments (by both NAR and TRA), and if
these cleared distances are complied with the risk of grass fires at
liftoff is minimal. The hazards presented by grass fires caused by bad
flight trajectories after liftoff can be mitigated by having adequate
fire suppression equipment on the range, training range personnel in its
use, and having an emergency plan for suppression of fire by the Section
which includes a contact plan for professional assistance in the cases
it is required.
(d) Five (5) Mile Airport Boundary - The FAAs proposed operating
limitations for the proposed Class 3 rockets include the following
limitation: 101.25 (b) Within 8 kilometers (5 miles) of any airport
boundary (Federal Register / Vol. 72, No. 114, pg 32872 )
Historically, many rocket launches which include Class 3 sized models
have obtained airspace waivers from the FAA, and safely have taken place
within this five mile limit. Many such waivered rocket airspace
operations have take place directly on aviation airport property. NAR
launch organizers have worked closely and carefully with airport owners,
operators and users, and integrated rocket flight operations with the
appropriate air traffic control system authority (e.g., tower, ATC,
etc.). When properly integrated into the air traffic control operating
environment, with operation procedures documented in waivers, Class 3
operations can safely operated with other air traffic within 5 miles of
an airport.
The NAR believes the proposed rule as written, strictly interpreted,
could ban waivered rocket launches within 5 miles of ANY airport
regardless of size, operations frequency or location. A blanket, total
prohibition of rocket flight operations ignores long standing successful
operations that have been in place for many years, make no distinctions
regarding the size of airport involved the frequency of its flight
operations, nor its facilities for properly managing and directing safe
airspace usage, and arbitrarily denies airspace access to a user
community whose record of safe flight operations under existing FAA
procedures is unparalleled when compared to other airspace users who
would presumably not face similar blanket prohibition.
The NAR estimates that between 20% and 60% of currently waivered NAR
launches would be completely shut down if this rule were implemented.
This would have an adverse effect on membership, community outreach, and
flight safety.
The NAR recommends the FAA modify the operating limitations on Class 3
rockets such that waivered flight operations, as currently practiced,
could remain in operation within 5 miles of airports.
101.27 Notice Requirements
(a) Launch Site Location - In the proposed list of information required
of launch organizers, the FAA suggests (d) Location of the center of
the affected area in latitude and longitude coordinates (Federal
Register / Vol. 72, No. 114, pg 32827). While GPS technology permits
computation of these coordinates, many NAR waivered launch operations
have used other means of locating their launch site such as distance
along VOR radial. Such methods allow other airspace users to precisely
locate the launch activities without resorting solely to GPS units or
cumbersome manual procedures.
The FAA should modify the proposed notice requirement in 101.27 (d) to
permit other acceptable methods of launch site location.
(b) Other Information - In the proposed list of information required of
launch organizers, the FAA suggests (g) Any other pertinent information
requested by the ATC facility. (Federal Register / Vol. 72, No. 114, pg
32827). Additionally, the FAA noted A hazard area is any region where
there is a significant potential for harm from the rocket activity.
Access to a hazard area is controlled or monitored by the operator (or
by others through agreements) to protect the uninvolved public. To
calculate these hazard areas and operational limitations, technical
information about the rocket and its operations is needed. Currently,
the waiver application process requires repeated correspondence between
the applicant and the FAA to get the necessary information. This
iterative process reduces the time available to the FAA to do analyses,
and increases the chance of determining either an insufficient or
excessive hazard area. (Federal Register / Vol. 72, No. 114, pg
32817-32818)
The NAR shares the FAAs concerns regarding flight safety and
establishment of appropriate hazard area, but the language proposed
fails to reduce the iterative process the FAA seeks to eliminate. By
leaving the phrase Any other pertinent information, the FAA has
apparently failed to determine what information is required of launch
organizers to properly establish the hazard area and assess flight or
other risks. Open ended information requirements impose undue burdens on
both launch organizers and the FAA and do not permit standard practices
to develop regarding establishment of hazard areas. The NAR believes
that FAA can reduce iterations and help establish standard operating
practices that would benefit all rocket launch organizers by insuring
their list of desired information is complete and relates, in a
scientific way, to the goal of establishing the hazard area.
101.29 - Information Requirements for Class 3 Rockets
(a) Information on Individual Rockets - The FAAs proposed information
requirements begin with A person operating one or more Class 3High
Power Rockets in controlled airspace must provide the information below
on each rocket to the FAA at least 45 days before the proposed
operation. (Federal Register / Vol. 72, No. 114, pg 32827).
A variety of factors make it nearly impossible for launch organizers to
collect and provide information on every rocket. Rocket hobbyists pursue
rocket flight for a variety of reasons, but many of them are
recreational flyers who are not professional engineers or scientists.
They may plan to attend a launch, then find circumstances do not permit
attendance, or conversely, they can attend launches in which they hadnt
originally expected to participate. Hobbyists are also not operating on
fixed production schedules for their vehicles, with delays common due to
suppliers, learning new building techniques, or other factors. The
result is that amateur rocket launches are highly variable as to what
vehicles are flown at any given launch.
The NAR believes a requirement to provide information on every rocket to
be flown is unnecessary for flight safety, and overly burdensome to the
FAA offices processing waiver applications. The proposed rule, if
strictly interpreted by FAA offices, could require information listed
for every vehicle to be flown.
The NAR has analyzed flight data from 38 launches from 1999 to 2006. At
these events, 6,160 rockets were flown which would be classified Class 3
by the proposed FAA rule. This results in an average of 162 vehicles per
launch. NAR local chapters organize approximately 2,000 launches
annually, at least half of which are waivered. Under a strict reading of
the proposed information requirements, these launches would require the
FAA to process approximately 162,000 applications for flight.
Historically, NAR launch organizers have provided waiver application
information about the expected aggregate number of rocket launches to be
held on particular dates and times, and have not provided this data on
each individual rocket to be flown. To describe the estimated flight
activity and performance, many waiver applications are submitted in the
form:
The Main Street Rocket Club estimates that approximately 200 rockets
will be flown during the waiver period, none of which will exceed the
maximum waiver altitude of 8,000 feet MSL.
The resulting waivers issued for launches result in a Notice to Airmen
(NOTAM) with information about the operating radius, maximum altitudes,
dates, times and location of the launch. Airspace users planning other
airspace operations can then determine how to safely conduct their
operations.
The NAR recommends the FAA clearly modify the proposed rule to make
clear that aggregate information on the type and expected number of
rockets to be flown is an acceptable practice.
(b) Additional Information Requirements - The FAAs proposed list of
information also includes (2) Type of propulsion, fuel(s), oxidizer(s),
manufacturer, and certification, if any, (3) Description of the
launcher(s) planned to be used, including any airborne platform(s), (4)
Description of recovery system, (5) Description of how applicant will
meet § 101.25 (Operating Limitations for Class 3High Power Rockets).
(6) Highest altitude, above ground level, expected to be reached, (7)
Launch site latitude, longitude, and elevation. (8) Any additional
safety procedures that will be followed..
The NAR believes many of these requirements do not enhance flight
safety, are redundant given operating limitations imposed on launch
organizers, and impose unnecessary burdens to both launch organizers and
the FAA.
(2) Type of propulsion, fuel(s), oxidizer(s), manufacturer, and
certification, if any,
The FAAs stated rationale for new rules includes preserving safety,
addressing inconsistencies and improving clarity. However, the only
commentary provided in the NPRM on propellants reads The amateur rocket
regulations were written when the amateur rocket community used mainly
solid rocket motors. Since then the amateur rocket community has
developed rocket engines that use liquid propellants. We propose to
redefine amateur rocket activity to reflect this advanced rocket
environment. (Federal Register / Vol. 72, No. 114, pg 32818).
The FAA has failed to outline in the NPRM the technical basis on which
propulsion information addresses safety or any other rationales on which
the proposed rules rest. Safety related discussion in the NPRM rested on
flight performance, not the composition of the propellants used to
achieve that performance. In fact, the same flight performances, and
hence, the potential hazard area that needs consideration, can be
achieved with different engine types and combinations.
Because the FAA has failed to connect collection of propellant, fuel,
oxidizer, manufacturer and certification information to its rationale of
preserving safety, addressing inconsistencies and improving clarity, the
NAR recommend item (2) be stricken entirely from the final rule.
In lieu of striking this rule, the NAR would note that the National Fire
Protection Association (NFPA) has established standards for the
certification and production of amateur rocket motors in NFPA Code 1125,
Code for the Manufacture of Model Rocket and High Power Rocket Motors,
2007 Edition. The NARs Standards and Testing Committee tests motors to
this standard, and NAR members can only use on our ranges engines which
have been tested and passed these standards.
The NAR would recommend that the final rule be modified to recognize
motors certified to this standard as acceptable without requiring
specific performance or propellants be listed as part of the
application. The NAR recommends language similar to the following:
The Main Street Rocket Club launch will use only motors currently
certified to the standards of the National Fire Protection Association
(NFPA) by the National Association of Rocketry or other recognized
certification authorities.
be indicated as acceptable when providing propellant, fuel, oxidizer,
manufacturer and certification information.
(3) Description of the launcher(s) planned to be used, including any
airborne platform(s)
The NPRM is completely silent on launchers except for the inclusion of
this information requirement in the proposed rule. The FAA has provided
no rationale for why this information would enhance flight safety, or
what limits, if any, FAA might impose on launch organizers if launcher
information provided was seen by FAA as inadequate.
In searching NAR flight records, we can find no record of launcher
related failures resulting in either an unsafe flight condition, life
threatening injury or property damage.
The NAR recommends the FAA strike item (3) from the final rule.
(4) Description of recovery system
The NPRM is completely silent on recovery systems except for the
inclusion of this information requirement in the proposed rule. The FAA
has provided no rationale for why having this information would enhance
flight safety, or what limits, if any, FAA might impose on launch
organizers if recovery system information provided was seen by FAA as
inadequate.
The FAA operating requirement for all rockets covered by the proposed
rule demand that rockets be operated in a manner that does not create a
hazard to persons, property, or other aircraft. Recovery systems are
designed and engineered to provide this level of safety. The NAR Safety
Codes include language that say recovery must be such that all parts of
my rocket return safely and undamaged and can be flown again . . .
This effectively includes provisions equal to the FAAs proposed
language for flight safety.
However, amateur rocket recovery failures are serious events, and in
fact, the NARs most recent safety study showed that approximately 75%
of all NAR rocket failures were recovery related.
Pre-flight knowledge of the recovery system would not have prevented
these failures.
The NARs recommendations to members regarding recovery failures were
aligned with FAA philosophy, i.e. establish a hazard zone, and insure
rockets didnt land outside of that zone, regardless of the nature or
operation of the recovery system.
Since the FAA cannot demonstrate why recovery system information in
advance of flight would preserve safety, address inconsistencies or
improve clarity given the operating limitations imposed on all rockets
regardless of class, the NAR recommends striking item (4) from the final
rule.
(7) Launch site latitude, longitude, and elevation.
For reasons outlined in discussion of the notice requirements in 101.27,
FAA should modify item (7) to permit other acceptable methods of launch
site location, such as distance along a VOR radial.
(8) Any additional safety procedures that will be followed.
Open ended information requirements impose undue burdens on both launch
organizers and the FAA and do not permit standard practices to develop
regarding launch reporting. The NAR believes this blanket permit to
require additional information will not enhance flight safety, increases
the administrative burden on the FAA, and does nothing to preserve
safety, address inconsistencies or improve clarity regarding rocket
operations.
The NAR recommends FAA modify the final rule such that FAA requirements
for information are bounded in some way or made more clear in advance to
launch organizers.
NAR appreciates this opportunity to comment on FAAs NPRM. If additional
discussion is warranted, please feel free contact me directly. We are
happy to work with the FAA.
Sincerely,
Mark A. Bundick, President
National Association of Rocketry
FAA on their NPRM.
Feedback is welcome.
Additionally, you may also wish to check out:
https://dms.dot.gov/search/searchResultsSimple.cfm?numberValue=27390&searchType=docket
which shows all comments filed in the docket to date.
I'll be out of town from Thursday through Saturday afternoon, and will
incorporate comments into the final response after I return.
From the feedback I've received thus far, it's clear that two critical
elements of the NPRM need our strong response. As written, the NPRM
could be interperted to prohibit launches within 5 miles of an airport,
and require detailed information be filed on EVERY rocket to be flown
under a waiver. Even if folks do nothing other than to suggest the FAA
needs to change these elements, letters would be appreciated.
Relative to the NAR's response, I'd like a "straw poll" here to let me
know how many of you would be affected by the 5 mile prohibition.
Background data like that would be useful to have in finalizing this
response.
= = = = = = = = = = == = = = == = = = == = = = == = = = == = = = == = = = =
DRAFT - NAR RESPONSE TO FAA NPRM
September 1, 2007
Docket Management Facility
U.S. Department of Transportation
1200 New Jersey Avenue, SE.
West Building Ground Floor, Room W12140
Washington, DC 20590
Charles P. Brinkman
Licensing and Safety Division (AST200)
Commercial Space Transportation
Federal Aviation Administration
800 Independence Avenue
Washington, DC 20591
Re: [Docket No. FAA200727390; Notice No. 0706]
Dear Mr. Brinkman:
I am please to present comments on behalf of the National Association of
Rocketry (NAR) on the FAAs Notice of Proposed Rulemaking (NPRM), Docket
No. FAA200727390, as published and amended in the Federal Register.
Background
The National Association of Rocketry (NAR) is a non-profit scientific
organization dedicated to safety, education, and the advancement of
technology in the sport rocket hobby in the United States. Founded in
1957, the NAR is the oldest and largest sport rocketry organization in
the world, with over 4,500 members and 110 affiliated clubs.
NAR publishes the bimonthly color magazine Sport Rocketry, which goes to
all NAR members and to libraries and newsstands around the nation. The
NAR also provides a wide range of other services to its members,
including national and local competitions, flight performance record
recognition, liability insurance, and technical literature publication.
NAR provides supports to teachers and students in the form of grants and
scholarships. NAR co-sponsors, with the Aerospace Industries Association
(AIA) the Team America Rocketry Challenge (TARC), an engineering
challenge contest for middle and high school students.
The NAR's primary orientation is consumer safety and youth education. It
is the recognized national testing authority for safety certification of
rocket motors in the U.S. and is the author of Safety Codes for the
hobby that are recognized and accepted by manufacturers and public
safety officials nationwide. It plays a strong role in the establishment
of national standards for public safety officials through its
participation in the National Fire Protection Association. It functions
as the consumer liaison and the voice of its members with hobby
manufacturers, national media, local public safety officials, and
Federal and state government regulatory agencies.
The foundation for defining the scope of sport rocketry and the rules by
which it is conducted without hazard to the public is a set of Codes
from the National
Fire Protection Organization (NFPA). The NFPA is an independent,
non-profit organization of public safety officials, industry, and safety
experts whose
mission is to develop consensus codes that reduce the worldwide burden
of fire and other hazards to quality of life and public safety. NFPA
Codes 1122 (Model
Rocketry) and 1127 (High Power Rocketry) provide detailed guidelines for
safe conduct of private sport rocket launch activities for both the
hobbyists and
educators that conduct such launches and for public safety officials who
may oversee them. It should also be noted that NASA fully accepts and
follows the NAR safety code for range operations in its Student Launch
Initiative, a program that uses sport rocketry to train young engineers.
These Codes were developed by safety experts and public safety officials
based on a 25 year program of thorough technical analysis, experimental
testing and
repeated NAR studies. A partial list of NAR safety studies includes:
1978 - Model Rocket Motor Shipping Safety
1985 - High Power Rocket Safety
1991 - Burn Tests of Reloadable Motors
1992 - Model Rocket Motor Burn Tests
1994 - Overall Safety of Reloadable Motors
1995 - Hybrid Motor Technology
1996 - Safety Analysis of Manufacturers' Maximum Recommended Liftoff Weight
1997 - Radio Controlled Glider Safety Code Development
1999 - Tests of Cleared Distance Required for High-Power Rocket Launches
1999 - Implementation of the NARs "Trained Safety Officer" program
2001 - Model Rocket Safety Code End-to-End Review
2005 - Special Study on Range Operations and Procedure
Most importantly, the NAR has historically worked with the FAA to insure
safe use of the nations airspace, consistent with reasonable access for
sport rocket flyers. It was the NAR who, in 1963, first approached the
FAA regarding potential rules for model rocket launches. As both the NAR
and the sport rocket hobby grew, NAR members have worked with local FAA
staff to secure airspace waivers as required for launches, and produced
a 44 year safety record unmatched in the rest of aviation.
Class 2 Large Model Rocket Definition
The FAA proposes to retain the current distinctions between model
rockets and large model rockets by categorizing such vehicles as Class
1 and Class 2 rockets. These classes differ solely by maximum liftoff
weight (16 ounces / 453 grams vs. 53 ounces / 1,500 grams). (Federal
Register / Vol. 72, No. 114, pgs 32820-32821).
Computer flight simulation of Class 1 and Class 2 vehicles were made to
demonstrate the heavier models have far less velocity and altitude
potential. The simulation used a commercially available motor containing
the maximum amount of propellant under the proposed 125 gram limit.
Flight conditions were set to standard conditions (sea level, 59 degrees
Fahrenheit, 29.92 barometric pressure) with no wind.
Class 1 Vs. Class 2 Flight Simulation Results
Vehicle Characteristics Class 1 Model Class 2 Model Difference
Motor Propellant Weight 114.7 grams
(Aerotech H242T) 114.7 grams
(Aerotech H242T) -
Body Diameter 38 millimeters 38 millimeters -
Model Airframe Weight 174 grams 1,221 grams 1,047 grams
Total Liftoff Weight 453 grams 1,500 grams 1,047 grams
Estimated Drag Coefficient (Cd) 0.75 0.75 -
Maximum Altitude (meters) 1,257 810 (447)
Maximum Altitude (feet) 4,124 2,657 (1,467)
Maximum Velocity (m/sec.) 376 136 (239)
Maximum Velocity (f/sec.) 1,233 448 (785)
Maximum Acceleration (Gs) 57.5 16.4 (41)
The heavier model reaches only 64% of the altitude, 36% of the maximum
velocity and 29% of the acceleration of the lighter vehicle.
The simulation results demonstrate that heavier rocket attain less
altitude, and have lower velocity and acceleration than lighter rockets
which have been operating safely for more than 45 years.
The NARs own flight experience with rockets in the proposed Class 1
dates back to 1957, without any life threatening personal injury or
airspace incidents. The NARs experience with the proposed Class 2
rocket began in 1991 and has compiled and equally outstanding safety
record. Total ground property damage claims filed under the NARs
insurance program have totaled less than $10,000 over the 49 year
history of the Association.
This track record supports the NARs position that both the proposed
Class 1 and Class 2 rockets can be flown using operating limitations
proposed for Class 1.
FAA provides no historical or technical basis for why the increased
weight justifies a separate classification with different operating
limitations.
Thus, the NAR proposes the Class 1 and Class 2 be collapsed into a
single classification (Class 1) using the proposed Class 1 operating
limitations. The change in definition would simplify FAAs operations
without any adverse impacts on air or ground safety and bring FAA
operations in synch with existing rocketry Safety Codes.
101.25 Operating Limitations for Class 3High Power Rockets.
(a ) Technical Correction - The FAA states that Currently, rockets that
would be Class 3 operate under the provisions for Large Model Rockets.
This is technically incorrect since Large Model Rockets operating under
current FAA rules simply require notification to the appropriate ATC,
while larger rockets which would be Class 3 under proposed rules must
secure an airspace waiver for sections of FAR Part 101 in order to operate.
(b) Responsible Range Person - The NAR supports the FAAs proposed rule
that a person at least eighteen years old must be present and in charge
of ensuring the safety of the operation.. For Class 3 (high-power)
sport rocket ranges, the current NFPA Code 1127 requirement is that
there be a Range Safety Officer (RSO) in charge with overall
responsibility for the safety, setup, and launching of all high-power
rockets who is a certified user of such rockets. The NFPA Code further
requires that such certified users must be at least 18 and must possess
a level of knowledge and competence in using high-power rockets that is
acceptable to a recognized certifying organization such as the NAR.
(c) Fire Control - The NAR supports the FAAs proposed rule that
reasonable precautions to report and control a fire. The NARs most
recent safety study, available at:
https://www.nar.org/pdf/launchsafe.pdf, reads in part:
NFPA 1127 Code for High Power Rocketry (2002 Edition) contains a
Launcher Clear Distance table which specifies the radius this
clearance must be done, by motor power class. This table was tested at
the low end by actual field experiments (by both NAR and TRA), and if
these cleared distances are complied with the risk of grass fires at
liftoff is minimal. The hazards presented by grass fires caused by bad
flight trajectories after liftoff can be mitigated by having adequate
fire suppression equipment on the range, training range personnel in its
use, and having an emergency plan for suppression of fire by the Section
which includes a contact plan for professional assistance in the cases
it is required.
(d) Five (5) Mile Airport Boundary - The FAAs proposed operating
limitations for the proposed Class 3 rockets include the following
limitation: 101.25 (b) Within 8 kilometers (5 miles) of any airport
boundary (Federal Register / Vol. 72, No. 114, pg 32872 )
Historically, many rocket launches which include Class 3 sized models
have obtained airspace waivers from the FAA, and safely have taken place
within this five mile limit. Many such waivered rocket airspace
operations have take place directly on aviation airport property. NAR
launch organizers have worked closely and carefully with airport owners,
operators and users, and integrated rocket flight operations with the
appropriate air traffic control system authority (e.g., tower, ATC,
etc.). When properly integrated into the air traffic control operating
environment, with operation procedures documented in waivers, Class 3
operations can safely operated with other air traffic within 5 miles of
an airport.
The NAR believes the proposed rule as written, strictly interpreted,
could ban waivered rocket launches within 5 miles of ANY airport
regardless of size, operations frequency or location. A blanket, total
prohibition of rocket flight operations ignores long standing successful
operations that have been in place for many years, make no distinctions
regarding the size of airport involved the frequency of its flight
operations, nor its facilities for properly managing and directing safe
airspace usage, and arbitrarily denies airspace access to a user
community whose record of safe flight operations under existing FAA
procedures is unparalleled when compared to other airspace users who
would presumably not face similar blanket prohibition.
The NAR estimates that between 20% and 60% of currently waivered NAR
launches would be completely shut down if this rule were implemented.
This would have an adverse effect on membership, community outreach, and
flight safety.
The NAR recommends the FAA modify the operating limitations on Class 3
rockets such that waivered flight operations, as currently practiced,
could remain in operation within 5 miles of airports.
101.27 Notice Requirements
(a) Launch Site Location - In the proposed list of information required
of launch organizers, the FAA suggests (d) Location of the center of
the affected area in latitude and longitude coordinates (Federal
Register / Vol. 72, No. 114, pg 32827). While GPS technology permits
computation of these coordinates, many NAR waivered launch operations
have used other means of locating their launch site such as distance
along VOR radial. Such methods allow other airspace users to precisely
locate the launch activities without resorting solely to GPS units or
cumbersome manual procedures.
The FAA should modify the proposed notice requirement in 101.27 (d) to
permit other acceptable methods of launch site location.
(b) Other Information - In the proposed list of information required of
launch organizers, the FAA suggests (g) Any other pertinent information
requested by the ATC facility. (Federal Register / Vol. 72, No. 114, pg
32827). Additionally, the FAA noted A hazard area is any region where
there is a significant potential for harm from the rocket activity.
Access to a hazard area is controlled or monitored by the operator (or
by others through agreements) to protect the uninvolved public. To
calculate these hazard areas and operational limitations, technical
information about the rocket and its operations is needed. Currently,
the waiver application process requires repeated correspondence between
the applicant and the FAA to get the necessary information. This
iterative process reduces the time available to the FAA to do analyses,
and increases the chance of determining either an insufficient or
excessive hazard area. (Federal Register / Vol. 72, No. 114, pg
32817-32818)
The NAR shares the FAAs concerns regarding flight safety and
establishment of appropriate hazard area, but the language proposed
fails to reduce the iterative process the FAA seeks to eliminate. By
leaving the phrase Any other pertinent information, the FAA has
apparently failed to determine what information is required of launch
organizers to properly establish the hazard area and assess flight or
other risks. Open ended information requirements impose undue burdens on
both launch organizers and the FAA and do not permit standard practices
to develop regarding establishment of hazard areas. The NAR believes
that FAA can reduce iterations and help establish standard operating
practices that would benefit all rocket launch organizers by insuring
their list of desired information is complete and relates, in a
scientific way, to the goal of establishing the hazard area.
101.29 - Information Requirements for Class 3 Rockets
(a) Information on Individual Rockets - The FAAs proposed information
requirements begin with A person operating one or more Class 3High
Power Rockets in controlled airspace must provide the information below
on each rocket to the FAA at least 45 days before the proposed
operation. (Federal Register / Vol. 72, No. 114, pg 32827).
A variety of factors make it nearly impossible for launch organizers to
collect and provide information on every rocket. Rocket hobbyists pursue
rocket flight for a variety of reasons, but many of them are
recreational flyers who are not professional engineers or scientists.
They may plan to attend a launch, then find circumstances do not permit
attendance, or conversely, they can attend launches in which they hadnt
originally expected to participate. Hobbyists are also not operating on
fixed production schedules for their vehicles, with delays common due to
suppliers, learning new building techniques, or other factors. The
result is that amateur rocket launches are highly variable as to what
vehicles are flown at any given launch.
The NAR believes a requirement to provide information on every rocket to
be flown is unnecessary for flight safety, and overly burdensome to the
FAA offices processing waiver applications. The proposed rule, if
strictly interpreted by FAA offices, could require information listed
for every vehicle to be flown.
The NAR has analyzed flight data from 38 launches from 1999 to 2006. At
these events, 6,160 rockets were flown which would be classified Class 3
by the proposed FAA rule. This results in an average of 162 vehicles per
launch. NAR local chapters organize approximately 2,000 launches
annually, at least half of which are waivered. Under a strict reading of
the proposed information requirements, these launches would require the
FAA to process approximately 162,000 applications for flight.
Historically, NAR launch organizers have provided waiver application
information about the expected aggregate number of rocket launches to be
held on particular dates and times, and have not provided this data on
each individual rocket to be flown. To describe the estimated flight
activity and performance, many waiver applications are submitted in the
form:
The Main Street Rocket Club estimates that approximately 200 rockets
will be flown during the waiver period, none of which will exceed the
maximum waiver altitude of 8,000 feet MSL.
The resulting waivers issued for launches result in a Notice to Airmen
(NOTAM) with information about the operating radius, maximum altitudes,
dates, times and location of the launch. Airspace users planning other
airspace operations can then determine how to safely conduct their
operations.
The NAR recommends the FAA clearly modify the proposed rule to make
clear that aggregate information on the type and expected number of
rockets to be flown is an acceptable practice.
(b) Additional Information Requirements - The FAAs proposed list of
information also includes (2) Type of propulsion, fuel(s), oxidizer(s),
manufacturer, and certification, if any, (3) Description of the
launcher(s) planned to be used, including any airborne platform(s), (4)
Description of recovery system, (5) Description of how applicant will
meet § 101.25 (Operating Limitations for Class 3High Power Rockets).
(6) Highest altitude, above ground level, expected to be reached, (7)
Launch site latitude, longitude, and elevation. (8) Any additional
safety procedures that will be followed..
The NAR believes many of these requirements do not enhance flight
safety, are redundant given operating limitations imposed on launch
organizers, and impose unnecessary burdens to both launch organizers and
the FAA.
(2) Type of propulsion, fuel(s), oxidizer(s), manufacturer, and
certification, if any,
The FAAs stated rationale for new rules includes preserving safety,
addressing inconsistencies and improving clarity. However, the only
commentary provided in the NPRM on propellants reads The amateur rocket
regulations were written when the amateur rocket community used mainly
solid rocket motors. Since then the amateur rocket community has
developed rocket engines that use liquid propellants. We propose to
redefine amateur rocket activity to reflect this advanced rocket
environment. (Federal Register / Vol. 72, No. 114, pg 32818).
The FAA has failed to outline in the NPRM the technical basis on which
propulsion information addresses safety or any other rationales on which
the proposed rules rest. Safety related discussion in the NPRM rested on
flight performance, not the composition of the propellants used to
achieve that performance. In fact, the same flight performances, and
hence, the potential hazard area that needs consideration, can be
achieved with different engine types and combinations.
Because the FAA has failed to connect collection of propellant, fuel,
oxidizer, manufacturer and certification information to its rationale of
preserving safety, addressing inconsistencies and improving clarity, the
NAR recommend item (2) be stricken entirely from the final rule.
In lieu of striking this rule, the NAR would note that the National Fire
Protection Association (NFPA) has established standards for the
certification and production of amateur rocket motors in NFPA Code 1125,
Code for the Manufacture of Model Rocket and High Power Rocket Motors,
2007 Edition. The NARs Standards and Testing Committee tests motors to
this standard, and NAR members can only use on our ranges engines which
have been tested and passed these standards.
The NAR would recommend that the final rule be modified to recognize
motors certified to this standard as acceptable without requiring
specific performance or propellants be listed as part of the
application. The NAR recommends language similar to the following:
The Main Street Rocket Club launch will use only motors currently
certified to the standards of the National Fire Protection Association
(NFPA) by the National Association of Rocketry or other recognized
certification authorities.
be indicated as acceptable when providing propellant, fuel, oxidizer,
manufacturer and certification information.
(3) Description of the launcher(s) planned to be used, including any
airborne platform(s)
The NPRM is completely silent on launchers except for the inclusion of
this information requirement in the proposed rule. The FAA has provided
no rationale for why this information would enhance flight safety, or
what limits, if any, FAA might impose on launch organizers if launcher
information provided was seen by FAA as inadequate.
In searching NAR flight records, we can find no record of launcher
related failures resulting in either an unsafe flight condition, life
threatening injury or property damage.
The NAR recommends the FAA strike item (3) from the final rule.
(4) Description of recovery system
The NPRM is completely silent on recovery systems except for the
inclusion of this information requirement in the proposed rule. The FAA
has provided no rationale for why having this information would enhance
flight safety, or what limits, if any, FAA might impose on launch
organizers if recovery system information provided was seen by FAA as
inadequate.
The FAA operating requirement for all rockets covered by the proposed
rule demand that rockets be operated in a manner that does not create a
hazard to persons, property, or other aircraft. Recovery systems are
designed and engineered to provide this level of safety. The NAR Safety
Codes include language that say recovery must be such that all parts of
my rocket return safely and undamaged and can be flown again . . .
This effectively includes provisions equal to the FAAs proposed
language for flight safety.
However, amateur rocket recovery failures are serious events, and in
fact, the NARs most recent safety study showed that approximately 75%
of all NAR rocket failures were recovery related.
Pre-flight knowledge of the recovery system would not have prevented
these failures.
The NARs recommendations to members regarding recovery failures were
aligned with FAA philosophy, i.e. establish a hazard zone, and insure
rockets didnt land outside of that zone, regardless of the nature or
operation of the recovery system.
Since the FAA cannot demonstrate why recovery system information in
advance of flight would preserve safety, address inconsistencies or
improve clarity given the operating limitations imposed on all rockets
regardless of class, the NAR recommends striking item (4) from the final
rule.
(7) Launch site latitude, longitude, and elevation.
For reasons outlined in discussion of the notice requirements in 101.27,
FAA should modify item (7) to permit other acceptable methods of launch
site location, such as distance along a VOR radial.
(8) Any additional safety procedures that will be followed.
Open ended information requirements impose undue burdens on both launch
organizers and the FAA and do not permit standard practices to develop
regarding launch reporting. The NAR believes this blanket permit to
require additional information will not enhance flight safety, increases
the administrative burden on the FAA, and does nothing to preserve
safety, address inconsistencies or improve clarity regarding rocket
operations.
The NAR recommends FAA modify the final rule such that FAA requirements
for information are bounded in some way or made more clear in advance to
launch organizers.
NAR appreciates this opportunity to comment on FAAs NPRM. If additional
discussion is warranted, please feel free contact me directly. We are
happy to work with the FAA.
Sincerely,
Mark A. Bundick, President
National Association of Rocketry
