PSA - Loki Price Increase 2022/03/08

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I’m not interested in arguing with you either Steve. I would like to discuss several items with you and everyone else. However, in my experience TRA’s business practices are off limits for open public discussion, only my business practices are allowed to be discussed and openly criticized on this platform without so much as an open warning to its members or to Jim Scarpine in this thread for violating rules #2 & #15 with his posts towards myself and Loki Research. The only way I can overcome how Jim has lied about me and Loki is to stoop down to his level and throw others under the bus, and be in violation of the same rules myself, which I would surely be held to account for most swiftly indeed.

I’ll proceed with caution as I have been unfairly targeted for my open TRA discussions in the past, so I will try to focus more on NFPA instead. As with most big picture politics in the US, we seem to only be allowed to openly discuss in a public forum the minor issues and differences we all face. Major issues that fundamentaly affect us all, are not open to discussion in public forums. They must take place in private TRA forums that are largely ignored by the vast majority of people.

Perhaps some of the misunderstanding here is with the statement I made in bold above. It is hard for me to be precise in my speech, as precise and honest speech has got me banned from more than just a major launch site venue. I am afraid to be too specific about such things out of fear of more continued retribution from the leadership. I was vague, but since you brought up NFPA, maybe I can clarify my statements above. Also, I never mentioned any issues or complaints with the awesome TMT chairman and his excellent volunteer staff. I have never had a complaint with any of them or their performance.

Here are some excerpts from NFPA 1127. (bold/italics or underline is mine)
NFPA clearly states its purpose at the very beginning in section 1.2.2 by outlining what actions the code is intended to discourage.
In plain language, it states the following.

1.2.2 The purpose of this code shall be to discourage the following to minimize deaths and injuries:
1.2.2 (1) Experiments with explosive or highly energetic rocket propellants
1.2.2 (2) Construction of homemade rocket propulsion motors.
1.2.2 (3) Attempted launch or operation of homemade rocket devices.


It goes on to state what items and what entities this code and the discouragements above shall not apply to.

1.3.3 This code shall not apply to the design, construction, production, manufacture, fabrication, maintenance, launch, flight, test, operation, use, or other activity connected with a rocket or rocket motor where carried out or engaged in by the following entities:
(1) National, state, or local government
(2) 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

(3) College or university

In section 6.1 Prohibited Acts subpart (5) of the code is a passage which the TRA claims exempts any TRA Level 2 or 3 member from this section, section 6.1(8), as well as the opening statements and purpose of the entire code in section 1.2.2, and maybe even other sections too. This seems very contrary to the other entries in 1127.

Section 6, Prohibited Acts
6.1 (5) Making, operating, launching, flying, testing, activating, discharging, or otherwise experimenting with high power rocket motors, motor reloading kits, or pyrotechnic modules that have not been certified in accordance with NFPA1125, other than for the purpose of evaluation of new high power rocket motor technology by a recognized national user organization or an authority having jurisdiction, provided that all other requirements of this code are met and all activities are in accordance with applicable laws, regulations, and ordinances.

I would argue with you here Steve, that this portion of the code is meant to allow manufacturers such as myself to do such things, not club members. It is not written clearly enough, or else the NAR would also allow for research activities for the same reasons. Has the TRA ever asked the NFPA for clarification on this section? Why does the NAR interpret this section’s bold type face (mine) as referring to the manufacturers of “new high power rocket motor technology” and not a research motor enthusiast as the TRA interprets it? If you remove every word I put into bold type face, the sentence would make clear, perfect sense and it would read like so.

Prohibited Activities
“Making, operating, launching, flying, testing, activating, discharging, or otherwise experimenting with high power rocket motors, motor reloading kits, or pyrotechnic modules that have not been certified in accordance with NFPA1125 by a recognized national user organization or an authority having jurisdiction….....”



Read in context with other portions of section 6, if you add the bold face words back into the sentence, “other than for the purpose of evaluation of new high power rocket motor technology,” it does not indicate that the evaluation of new technology is to be performed by an amateur user with zero to good experience. It indicates to me that this passage is meant for those in the commercial motor making business of “evaluating new high power motor technology.” If it is in fact the TRA L2/L3 flier it refers too, then what and where is this new technology or the evaluation reports thereof?

Again, 3 sub sections later, taken in context with 1.2.2 (2) & (3) and 6.1(5), section 6.1(8) clearly states the following is prohibited, yet it is green-lighted by the TRA leadership and somehow allowed for only L2/L3 members, and only because of TRA’s interpretation of portion of section 6.1(5) above.

6.1 (8) Reloading or reusing of any expendable, disposable, solid- or hybrid-propellant high power rocket motor with any material once the motor has been operated, or reloading of any reloadable, solid- or hybrid-propellant high power rocket motor with any material or by any means not specifically certified

Now let me be crystal clear with readers. I personally and professionally have zero issue with anyone, who wants to do anything they want, with any kind of rocket motor, provided they are being safe and smart about it. I may not even be here typing this if I didn’t get into EX years ago. I’m also not trying to pick on Tony A. here for being an expert in doing the above and posting how-to threads on it. I love him and think he’s one of the very best guys we have to look up to in this hobby. Tony A. for TRA President.

What I’d like to know is this. After the TRA granted it’s L2 and L3 members exemption from the discouraged and prohibited activities stated in 1127 above, how many different entities did Tripoli leadership, thru official policy, recognize in its membership as being exempt from NFPA1127 provisions, entities that manufacturers like myself can sell non-certified motors to, which can also then be flown and insured at a TRA sanctioned launch, the same as any homemade motor can?

Answer that question for me, and perhaps my bold faced statements above will make more sense to everyone.
 
I called Scott and asked him about a couple of my favorite loads that he didn’t have in stock, and because they were the same kind of fuel, and because my order was large enough to justify making a single batch, I’ll be getting my order filled in time for the next launch.

@Loki Research
Scott, what is the minimum order for having a batch of out-of-stock motors cast?
 
@Loki Research
Scott, what is the minimum order for having a batch of out-of-stock motors cast?
There is no answer here because it's an exception to the rule. If I ever am able to do this, it would depend on what motors, why they are out of stock, how long you are willing to wait for them, etc. I'm easy to work with but I have very little time. Things worked out for Dan this time and I could help his shipping cost go further and he could wait for the time I needed. I don't want to take orders for things that are not produced yet because production of anything is not always simple and uneventful. I've been bit by pre-orders once and that was enough. I do try to help customers get the best value for their shipping dollar though.

I did the same here for a large dealer order the week before with a couple PITA moon burners which have yet to ship because he added more reloads on to the order this week. I bet he'd buy a blue N or O motor from me to fly if he could. I know Teddy at OneBadHawk would. He's been badgering me for a red 76/8000 N motor for years ever since I static tested the first one I made in Argonia.
They're not allowed to fly them unless certified or I give it to them.

Hello Aerotech / Gary :)
 
Snip…

What I’d like to know is this. After the TRA granted it’s L2 and L3 members exemption from the discouraged and prohibited activities stated in 1127 above, how many different entities did Tripoli leadership, thru official policy, recognize in its membership as being exempt from NFPA1127 provisions, entities that manufacturers like myself can sell non-certified motors to, which can also then be flown and insured at a TRA sanctioned launch, the same as any homemade motor can?

Answer that question for me, and perhaps my bold faced statements above will make more sense to everyone.
The answer is none. We have no authority to “recognize entities that manufacturers like yourself can sell non-certified motors to.” That is up to the manufacturers to determine based on their interpretation of laws based on those sections of NFPA that you highlighted.
Instead we have done what we can to make motor certification easy and inexpensive so that our members have wide access to certified motors. There’s simply no reason to allow such non-certified (but certifiable) commercial motors to be flown at TRA sanctioned launches.
Why do you want to sell single digit quantities of non-certified motors when we have made certification of motors by manufacturers so easy and inexpensive? It just doesn’t make sense, Scott. Why don’t you just submit those motors for certification? It would make it possible for you to enjoy economies of scale and would allow them to be used at both NAR and TRA launches as well as those competitions which require motor certification.
You make great motors. I fly them myself as well as AT and CTI.
 
Is the crux of Scott's concern with Ex motors the following; Ex motors that are "free" are allowed but "sold" are not allowed? These posts are quite long and I could be mis interpreting.

Also a general comment about manufacturers and dealers. Back when I was 18 and started Pyramid Rocketry, I started selling to dealers. One of them wanted to have a word with me and said to be careful when selling direct. He stated I as a manufacturer could always out-compete the dealers on price. I thought about it for a moment, thought it was a reasonable concern, and thanked him for the advice. I made it my policy to always sell at list price when doing direct sales. That being said, none of this is absolute. What is important is to recognize this is a potential issue and work out a contract with the dealers. The rules can be decided based on whatever all the parties think is fair. That being said, once agreed upon, honoring those rules is critically important. I have no idea what folks are specifically concerned with in this thread, since they are leaving details out, but I wanted to share my experience.
 
Is the crux of Scott's concern with Ex motors the following; Ex motors that are "free" are allowed but "sold" are not allowed? These posts are quite long and I could be mis interpreting.

Also a general comment about manufacturers and dealers. Back when I was 18 and started Pyramid Rocketry, I started selling to dealers. One of them wanted to have a word with me and said to be careful when selling direct. He stated I as a manufacturer could always out-compete the dealers on price. I thought about it for a moment, thought it was a reasonable concern, and thanked him for the advice. I made it my policy to always sell at list price when doing direct sales. That being said, none of this is absolute. What is important is to recognize this is a potential issue and work out a contract with the dealers. The rules can be decided based on whatever all the parties think is fair. That being said, once agreed upon, honoring those rules is critically important. I have no idea what folks are specifically concerned with in this thread, since they are leaving details out, but I wanted to share my experience.
You might want to check TRA rules on the sale of research motors.
 
I thought Scott said that part of his problem was variability in raw materials making it expensive/difficult to match previously-certified motors. Recertifying the while line would be very expensive and time-consuming.
 
I might be going out on a limb here but given the size of our hobby, I would imagine that AT and CTI both are not interested in having a sole monopoly on motors. They are smart people and must realize that putting all the eggs in one basket in our hobby places the entire hobby at risk.

Perfect example is when both larger companies had accidents. The other ramped up production to support the hobby while the other sorted things out. They didn't "have to" do that, they knew they "needed" to do it. "Want" wasn't even in the vocabulary as the survival of the hobby was in the balance in a way.

With (3) motor manufacturers, the hobby has backup in case something catastrophic happens. With a sole monopoly, or even only (2) manufacturers, the hobby becomes precarious at this point. The hobby is big enough at this point (I think.....) to support (3) manufacturers. I think if Scott could ramp up more, upon sorting some of the challenges out that seem to be plaguing him. The hobby could still support (3) quite happily. I question even if one of the other (2) manufacturers wouldn't be willing to 'help' sort some of those challenges out. I feel its ultimately in their best interest in the long term as it would help add stability to the hobby by shoring up motor supplies.

Just my $0.13

No comments on EX stuff.....I agree with it 100%.
 
"Research motor cannot be sold for PROFIT at a TRL"
The specific language about profits is to acknowledge that people who make research motors as part of a project team may be reimbursed for materials. It’s not intended to allow someone to set up shop and sell non-certified or research motors, for profit or otherwise. Research motors are allowed by Tripoli so our members can learn more about that aspect of rocketry, nothing more.
 
“Brevity is the soul of wit.”
- William Shakespeare

Scott: You've come a long way from the time you were learning to make research motors. I suggest you keep making good products and set the price as needed. Venting here will not change anything, but it could have a negative impact on your reputation.
 
Changes in chemical sources and reformulation do not require recertification as long as the performance is within the limits required by NFPA 1125. It may require pre-processing of sub-optimal chemicals, and going through some iterations. It's a trade off of time and money. Plus, more technical knowledge will shorten the process.
 
The specific language about profits is to acknowledge that people who make research motors as part of a project team may be reimbursed for materials. It’s not intended to allow someone to set up shop and sell non-certified or research motors, for profit or otherwise. Research motors are allowed by Tripoli so our members can learn more about that aspect of rocketry, nothing more.


Steve I agree but this is a very , very slippery slope. Who is to say one of the major universities approaches Scott for motors to launch one of their rockets on a test flight at MDRA before say a major event . Would Scott K. be eligible to receive the monetary value of his chemicals and time if he made the motor or is it different if Scott S. from MDRA makes the motor and sells it to recoup his costs ?

Eric
 
Research motors are allowed by Tripoli so our members can learn more about that aspect of rocketry, nothing more.
[/QUOTE


Very well said. So as long as someone is certified , they can legally go buy 20 pounds of AP , binder and cast a motor for a group project ( it does not matter if they know what they are doing ) all the while gaining every cent if not more back .

Why is it that a manufacture cannot demo up coming non certified motors ? Is it because they did not pass go and collect their $200?

For everyone reading , this is a peaceful discussion , for everybody sake let's keep it that way. Let's all learn together.
 
Steve I agree but this is a very , very slippery slope. Who is to say one of the major universities approaches Scott for motors to launch one of their rockets on a test flight at MDRA before say a major event . Would Scott K. be eligible to receive the monetary value of his chemicals and time if he made the motor or is it different if Scott S. from MDRA makes the motor and sells it to recoup his costs ?

Eric
MDRA is an independent, 501C non-profit corp with their own insurance. Tripoli safety codes don't necessarily apply. But, Maryland has adopted NFPA 1/IFC which reference NFPA 1122/1125/1127. It's up to those involved to decide if the words "research" and "university" offer a loophole.

If the same motor were brought to the Spaceport America Cup, Tripoli insurance is in place for all solid motors. The motor would need to be certified if made by a commercial vendor. If it were made by someone outside of the student team as a research motor, it wouldn't be allowed by the contest rules (if the team were honest about it).

If a university team or other amateur group wants to buy a non-certified motor from a company or individual (at a profit), they can launch it independently with their own insurance or personal liability waiver at independent sites such as FAR, or Spaceport America on their own fee and schedule. The motor maker has to decide what their personality liability and regulatory compliance might be.

[So much for brevity! ;-) ]
 
[snip]
Instead we have done what we can to make motor certification easy and inexpensive so that our members have wide access to certified motors. There’s simply no reason to allow such non-certified (but certifiable) commercial motors to be flown at TRA sanctioned launches.
Why do you want to sell single digit quantities of non-certified motors when we have made certification of motors by manufacturers so easy and inexpensive?
[/snip]

This thread has a fairly negative vibe, so this may not be the place to ask, but is it possible for the TMT volunteers to make a video about motor certification? I'm thinking something better than people videoing a kid's birthday party, but not quite up to the 'Smarter Everyday' guy on Youtube. Maybe something closer to his, but not a 'fully produced' product.

I think it would be interesting to learn more about the process as an interested hobbyist, not someone trying to start a business, as I can guarantee I should never even think about that! Just a documentary-like thing covering the process, preferable start to finish with general information (nothing that is restricted like formulas, methods of manufacture etc.). Just the stuff that happens once a manufacturer decides to try to market a product and applies (I assume it is apply) for certification. What is the paperwork, how many samples, how is the process done, how long does it take. What happens with success. What happens with failure.

I had always assumed (based more on forum posts from the 2000's, not current) that it cost a ton of money and took a lot of time and was a huge burden on a manufacturer, unless it was going to be a guaranteed commercial success. Maybe it was that way back then and is different today or maybe I had a completely incorrect vision of the process. That might be a good subject to cover as well - the history of TMT abridged to show how we got from the early days to the current state.

The whole reason I post this request is that I saw 'easy and inexpensive' above in your post twice and was surprised. I know it is a volunteer organization, but I thought it was expensive and difficult. In this case, I'd love to see a video of how the sausage is made!!! Part of the hobby is learning and this is something I would like to learn more about. Heck, maybe even an interview with Gary, Scott and Anthony (or delegated parties that work with TMT) about their perspective. Not wanting to go 'reality show' on the idea (i.e. Scott vs. Gary vs. Anthony - we've only got 5 DAYS TO MAKE THIS MOTOR!!!), but a somewhat well done 'how its made' documentary-style piece (20-30 min, maybe) that represented the process and the people would be a hugely cool thing to see, IMO.

Sandy.
 
This thread has a fairly negative vibe, so this may not be the place to ask, but is it possible for the TMT volunteers to make a video about motor certification? I'm thinking something better than people videoing a kid's birthday party, but not quite up to the 'Smarter Everyday' guy on Youtube. Maybe something closer to his, but not a 'fully produced' product.

I think it would be interesting to learn more about the process as an interested hobbyist, not someone trying to start a business, as I can guarantee I should never even think about that! Just a documentary-like thing covering the process, preferable start to finish with general information (nothing that is restricted like formulas, methods of manufacture etc.). Just the stuff that happens once a manufacturer decides to try to market a product and applies (I assume it is apply) for certification. What is the paperwork, how many samples, how is the process done, how long does it take. What happens with success. What happens with failure.

I had always assumed (based more on forum posts from the 2000's, not current) that it cost a ton of money and took a lot of time and was a huge burden on a manufacturer, unless it was going to be a guaranteed commercial success. Maybe it was that way back then and is different today or maybe I had a completely incorrect vision of the process. That might be a good subject to cover as well - the history of TMT abridged to show how we got from the early days to the current state.

The whole reason I post this request is that I saw 'easy and inexpensive' above in your post twice and was surprised. I know it is a volunteer organization, but I thought it was expensive and difficult. In this case, I'd love to see a video of how the sausage is made!!! Part of the hobby is learning and this is something I would like to learn more about. Heck, maybe even an interview with Gary, Scott and Anthony (or delegated parties that work with TMT) about their perspective. Not wanting to go 'reality show' on the idea (i.e. Scott vs. Gary vs. Anthony - we've only got 5 DAYS TO MAKE THIS MOTOR!!!), but a somewhat well done 'how its made' documentary-style piece (20-30 min, maybe) that represented the process and the people would be a hugely cool thing to see, IMO.

Sandy.
It might be interesting, but I wouldn’t ask the committee to do that, simply because of the huge amount of additional time it might take and because they need to be fully focused on safety while testing motors. It might also be interesting to see how a manufacturer develops a motor in the first place, before it’s ready to be submitted for certification. That’s the sausage making. But this screenshot might help you understand why I believe we’ve made it easy and inexpensive. The table in this screenshot shows how many samples the manufacturer must provide for each motor to be certified and the price for the certification procedure:
C7612135-940E-4673-B1B8-87AF7854C309.png

The procedure is well documented in the Policies and Procedures manual which is available on our website. Look over on the right of this page for links to the agreement and policies and procedures manual.
https://www.tripoli.org/content.aspx?page_id=22&club_id=795696&module_id=494535
 
since "we"....including org officers.....are still here discussing scotts private affairs....a much more productive post would be for.....some self appointed authority to attempt to....relate why any intelligent person should believe any rocket motor actually needs certification...whatever that supposedly is.

without all the red tape krap...all motors are research

safety....lol....pisshaw...these days aint verns days

only to restrict competition....to and of..... "the club" ?
 
Last edited:
" but is it possible for the TMT volunteers to make a video about motor certification? "

No, as the information is propriatory to the manufacturer. We cant divulge testing information until the manufacturer sees the data and releases it publicly. If a motor catos on the test ,we tell no one. We do video all tests, but that is passed on to the manufacturer.
 
It might be interesting, but I wouldn’t ask the committee to do that, simply because of the huge amount of additional time it might take and because they need to be fully focused on safety while testing motors. It might also be interesting to see how a manufacturer develops a motor in the first place, before it’s ready to be submitted for certification. That’s the sausage making. But this screenshot might help you understand why I believe we’ve made it easy and inexpensive. The table in this screenshot shows how many samples the manufacturer must provide for each motor to be certified and the price for the certification procedure:
View attachment 514635

The procedure is well documented in the Policies and Procedures manual which is available on our website. Look over on the right of this page for links to the agreement and policies and procedures manual.
https://www.tripoli.org/content.aspx?page_id=22&club_id=795696&module_id=494535

Thanks for the table. That gives a good idea as to the magnitude of costs - less than $1000 for smaller motors, but still probably $2000-2500-ish for bigger motors due to the cost of the materials. Obviously that could be more if the hardware has to be supplied or there are different combinations. It does seem like the fees are reasonable and the quantity of motors is also reasonable. Nothing is free for sure, but its not $10k+ to attempt to certify a motor, it seems.

" but is it possible for the TMT volunteers to make a video about motor certification? "

No, as the information is propriatory to the manufacturer. We cant divulge testing information until the manufacturer sees the data and releases it publicly. If a motor catos on the test ,we tell no one. We do video all tests, but that is passed on to the manufacturer.

I guess that is where I was saying I didn't want a 'reality show' vibe, but more of a documentary. More of the 'this is how we measure force, this is where pressure is measured and we do it at X times per second which shows this on the graph etc.' All about education, not things going good or bad. I imagine the best way to execute the process would be to just use a commercial motor that has been certified for years and years to demonstrate a good test and if the desire was to show something going wrong, just ignore that desire and talk about the challenges that happen.

I think Steve basically said it won't work due to safety of the team and that's good enough for me. If there is any desire to try and figure out a production in the future, please PM me. A lot of the costs could have been covered. Maybe similar costs could be covered in the future if the need for a video can be justified by the TMT team.

Sandy.
 
Steve, I read Scott's post somewhat differently.

I believe that he does understand the existing certification requirements, but feels that those in the hobby now in power, or those who will gain it, should attempt to change those requirements in order to improve, from a business perspective for motor manufactures, and for we hobbyists as motor purchasers, the future for both.
We will never win a contest with Mother Nature. That is a given. Perhaps however that may be different with the current motor regulatory situation, but my take is that we may be able to do that with the current motor regulatory situation, and I think that is what Scott is getting at.
We fought the Government regarding the regulation of the APCP issue, and we won. He may well be remembering that and wondering if we can do something that will help in the motor certification area as well..
I've not spoken with Scott. I am not speaking for him, simply offering my view of his post. These are my thoughts only. They may be wrong. If so, he'll tell us...
 
Steve, I read Scott's post somewhat differently.

I believe that he does understand the existing certification requirements, but feels that those in the hobby now in power, or those who will gain it, should attempt to change those requirements in order to improve, from a business perspective for motor manufactures, and for we hobbyists as motor purchasers, the future for both.
We will never win a contest with Mother Nature. That is a given. Perhaps however that may be different with the current motor regulatory situation, but my take is that we may be able to do that with the current motor regulatory situation, and I think that is what Scott is getting at.
We fought the Government regarding the regulation of the APCP issue, and we won. He may well be remembering that and wondering if we can do something that will help in the motor certification area as well..
I've not spoken with Scott. I am not speaking for him, simply offering my view of his post. These are my thoughts only. They may be wrong. If so, he'll tell us...
Thanks for suggesting a different interpretation of Scott’s comments. I’ll reread them with your interpretation in mind.
 
since "we"....including org officers.....are still here discussing scotts private affairs....a much more productive post would be for.....some self appointed authority to attempt to....relate why any intelligent person should believe any rocket motor actually needs certification...whatever that supposedly is.

without all the red tape krap...all motors are research

safety....lol....pisshaw...these days aint verns days

only to restrict competition....to and of..... "the club" ?
All motors are research? ... especially considering the early days of TMT lol!!
 
All motors are research? ... especially considering the early days of TMT lol!!
In my opinion the most testing of a new motor is us flyers. Over my 30 years of HPR flying there has been a number of times after a new motor has been released and out at launches failures show up and we are told to stop flying the motor. My own L3 cert flight was held up for 7 months before motor problem was solved. Back than there was very few choices for a L3 motor so we just waited.
 

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