The following is a joint response by the Tripoli Rocketry Association, the Association of Experimental Rocketry of the Pacific (AERO-PAC) and the Stratofox Aerospace Tracking Team which was submitted Tuesday, May 30 to the Federal Aviation Administration's Notice of Proposed Rulemaking (NPRM) on Experimental Space Launch Permits. (download 150K PDF)
The NPRM process allows the public to comment and make suggestions on proposed new regulations by the US federal government. These are the suggestions we made to the regulators. The context refers to the Experimental Permit NPRM document which can be downloaded above.
This is in reponse to the FAA Experimental Permit NPRM (Docket 24197)
issued March 31, 2006. This comment is submitted on behalf and with
approval of the following:
* the Tripoli Rocketry Association (TRA) http://www.tripoli.org/ ,
a national high-power rocketry organization
* the Association of Experimental Rocketry of the Pacific
(AERO-PAC) http://www.aeropac.org/ , the regional chapter of TRA for
northern California and northern Nevada, including Nevada's Black Rock
Desert
* the Stratofox Aerospace Tracking Team http://www.stratofox.org/ ,
a communications and rocketry club from California and Nevada which has
performed operating area containment and post-flight recovery of
suborbital rockets under FAA AST observation multiple times
* Ian Kluft, a resident of San Jose, California, a member of TRA
and AERO-PAC and a former Coordinator (equivalent of president) of
Stratofox
* Owen DeLong, a resident of San Jose, California, a member of TRA
and AERO-PAC and a former Coordinator (equivalent of president) of
Stratofox
* Mark C Whittington, a resident of Herndon, Virginia and current
Coordinator (equivalent of president) of Stratofox
* Ben Woodard, a resident of Pleasanton, California and a member of
Stratofox
* K Mark Caviezel, a resident of Norman, Oklahoma and a pending
member of Stratofox
* Steve Palmer, a resident of Cameron Park, California and a member
of Stratofox
* John Coker, a resident of Atherton, California, a member of TRA
and a former 1st Commissioner (equivalent of president) of AERO-PAC
* Tony Alcocer, a resident of Santa Rosa, California, a member of
TRA and current 2nd Commissioner (equivalent of vice president) of
AERO-PAC
* Robin Snelson, a resident of Sherman Oaks, California and a
pending member of Stratofox
* David Brock, a resident of Folsom, California, a member of TRA
and a pending member of Stratofox
This comment addresses issues from the point of view of members of the
High-Power Rocketry (HPR) community. HPR is defined by the National
Fire Protection Association (NFPA) 1127 "High Power Rocketry Code", a
document which was made by collaboration between national rocketry
organizations and the national fire marshals organization. The two
national organizations allowed to issue high-power rocketry
certifications and operate launch events under NFPA 1127 are the
Tripoli Rocketry Association (TRA) and the National Association of
Rocketry (NAR). The TRA Research Safety Code already has rules which
take HPR past the "O" motor limit of NFPA 1127 and covers experimental
launches with motors up to size "T" at 890,000 N-sec, which would be
capable of a suborbital space launch. For reference, the CSXT amateur
rocket launched on a suborbital flight on May 17,2004 used an "S"
motor. Several of the participants in the CSXT effort are or were on
the TRA board of directors and many more are TRA members. That
indicates some likelihood that the high end of HPR launches will
eventually and possibly soon grow to intersect the range of Part 437
Experimental Permits.
We first want to reconfirm the understanding that Part 400 does not
apply to "amateur rockets" below the following thresholds: 200,000
lb-seconds of impulse (as per 401.5), 12 lbs/square inch of ballistic
coefficient (as per 401.5), and 15 seconds of burn time (as per 401.5),
or to the Tripoli approved waiver for a burn time up to 60 seconds with
a reduction to 100,000lb-sec total impulse. In preparation for the
eventual day when an amateur rocketry project wishes to exceed any of
these thresholds, we would like Part 437 Experimental Permits to be an
option rather than requiring a launch license.
One of the activities which drives the high end of HPR is university
research. The Association of Experimental Rocketry of the Pacific
("AERO-PAC") and Stanford University have an ongoing program where
aerospace engineering students from many universities can fly research
projects on rockets built and operated by AERO-PAC volunteers. The
research projects are either the size of a soda can or a coffee can,
many performing a student's thesis project. Stanford sponsors the motor
reloads as a partner in the project. We wish to ensure that this
cooperation between university researchers and volunteers is not
considered "for hire", so that it can continue to grow toward
suborbital launches. We understand FAA AST's discussion text to
specifically allow goodwill payloads and for participants in the flight
to contribute to the costs, similar to the "for hire prohibition" on
Private Pilots. If there are any changes to that interpretation, please
ensure this university research arrangement remains allowed.
Since the purpose of the proposed Part 437 Experimental Permits is to
reduce the paperwork necessary for an experimental suborbital launch
below the burden of launch licenses intended for orbital launches, we
request that HPR launches should be explicitly included in Part 437. If
FAA AST does not include amateur/high power rocket launches at this
time, then please include the High-Power Rocketry community in a
follow-on round of rulemaking which accomodates HPR.
The remainder of this comment assumes suborbital HPR launches will be
explicitly included in Part 437 Experimental Permits. This is intended
to assist in that direction.
In 437.3 "Definitions", the lack of a definition of a "reusable
suborbital rocket" allows the interpretation that any rocket designed
for a suborbital flight and intended to be recovered and flown again is
applicable to Part 437. That interpretation is acceptable to us.
However, if a definition of "reusable suborbital rocket" is added,
please ensure that it remains compatible with non-profit research,
education, recreation and sporting competition projects.
In 437.5 "Eligibility for an experimental permit", paragraph (a)
ambiguously permits amateur/high power rocket launches if one
successfully argues for one of the categories of research and
development. To resolve the ambiguity, please add a paragraph (d) like
this, which describes amateur rocketry projects but avoids using the
term "amateur rocket" since that is already defined in 401.5.
(d) Non-Profit rocketry research, education, recreation, and
sporting competition projects.
In 437.21(b)(3) "Operation of a private launch site", it can be
interpreted to mean that an applicant proposing to launch from a
private launch site which has neither permanent facilities nor ongoing
operations is not required to obtain a launch site operator license.
That interpretation is acceptable to us. At the largest HPR launches,
the launch site equipment is portable and is taken away at then end of
the launch event. We wish to ensure that this can be included in the
experimental launch permit and does not require us to obtain a launch
site operator license for Nevada's Black Rock Desert, for example.