Rocketry Planet

Note: The references and data in this article were furnished by several people, including Art Upton, Darrell Mobley, David Reese, and several others I am grateful to. Brent McNeeley, editor/publisher of Extreme Rocketry, as well as Neil McGilvray and Bob Utley, editor/publisher of ROCKETS Magazine, have both agreed to publish this article in each of their respective publications, transcending personal interest and embracing hobby concerns first. The article can also be found after the magazines are distributed on www.rocketryplanet.com and www.rocketryonline.com.

On June 14, 2007, the Federal Aviation Administration introduced a new NPRM (Notice of Proposed Rulemaking) Requirements for Amateur Rocket Activities [Docket No. FAA-2007-27390; Notice No. 07-06]. On December 2, 2008, they announced the final ruling of that NPRM found on page two of the above link. Should you desire to follow the link, all comments towards this NPRM are a matter of public record.

For most people, the recent FAA Final Ruling has reduced regulation, by eliminating bothersome notification for rockets below 3.3 pounds (Class 1). Class 2 activities will require a waiver, but that should not present much difficulty. This result can be safely attributed to the 50 year safety record of organized hobby rocketry and the organizations like NAR and TRA, working in concert with our partners, the FAA.

But for some people, it still hasn't sunk in that the new FAA Final Ruling has severely handicapped the individuals who routinely fly research motors or multiple commercial motors in the impulse ranges above O impulse. The new Class 3 rockets that have installed greater than O impulse must meet a plethora of criteria just to have the flight plan approved, regardless of whether it is a low altitude Pyramid or a minimum diameter high performance bird.

At first blush, many high power rocketeers will say, "Who cares? I don't fly above an O motor." Sure, but do you cluster? 4 M's?  A pair of N's? If the total impulse of the flight is greater than 40,960NS, then you will be bumped up to Class 3 where you no longer benefit from the umbrella waiver of the launch organizer and may be required to file your OWN waiver application at least 45 days in advance, or at least get your data to the waiver holder with the following requirements:

When a Class 3 - Advanced High-Power Rocket requires a certificate of waiver or authorization the person planning the operation must provide the information below for each type of rocket to the FAA at least 45 days before the proposed operation. The FAA may request additional information if necessary to ensure the proposed operations can be safely conducted. The information shall include for each type of Class 3 rocket expected to be flown:

1. The information requirements of paragraph (a) of this section*.
2. Maximum possible range,
3. The dynamic stability characteristics for the entire flight profile,
4. A description of all major rocket systems, including structural, pneumatic, propellant, propulsion, ignition, electrical, avionics, recovery, wind-weighting, flight control, and tracking,
5. A description of other support equipment necessary for a safe operation,
6. The planned flight profile and sequence of events,
7. All nominal impact areas, including those for any spent motors and other discarded hardware, within three standard deviations of the mean impact point,
8. Launch commit criteria,
9. Countdown procedures, and
10. Mishap procedures.

* Paragraph (a) requirements:

1. Estimated number of rockets,
2. Type of propulsion (liquid or solid), fuel(s) and oxidizer(s),
3. Description of the launcher(s) planned to be used, including any airborne platform(s),
4. Description of recovery system,
5. Highest altitude, above ground level, expected to be reached,
6. Launch site latitude, longitude, and elevation, and
7. Any additional safety procedures that will be followed.

This fundamental change makes the typical Level 3 documentation requirements look pale by comparison, as possibly EVERY launch of a Class 3 rocket may require even more documentation than an L3 flight would require.

This shifts the responsibility off of the launch organizers and puts it squarely on the backs of the flier and waiver holder. One of the more confounding requirements is filing all data 45 days in advance of each type of rocket, which would include data readings of winds aloft. Care to guess what the winds aloft will be 45 days in the future? One can suppose the NOAA historical winds aloft data or recent GOES wind data would be accurate enough to input to the model and return results which qualify for the FAA requirements. But the inputting of that data seems redundant 45 days prior. On site, perhaps the high altitude winds-aloft data for popular large launch sites (Black Rock, Delamar, Wayside, Argonia, etc.) could be tabulated in an easier-to-use format? For lower altitude Class 3 flights at other, smaller sites, the aviation weather service is able to give real-time and forecast winds-aloft data for nearby airports; tracking the trends over time and using those results may be suitable as well.

This begs the question. Is there any commercially available 6DOF splash pattern software which meets the FAA requirement? That seems to be the biggest hurdle in the rules. Aside from RS-Pro, I was not able to find one that I believe will satisfy the FAA. At $1000.00 a copy, that may be a little steep for most fliers.
 
Although the new requirements for Class 3 rockets add a degree of difficulty, and possibly expense, it doesn't seem impossible, either. I am ecstatic that they've lifted the burn duration and total impulse maximums for AST applications, both of which eliminate launch licenses previously required. But capping Class 2 @ 40960 N-s seems somewhat un necessary, especially since it is not coupled with altitude. And in a teleconference call with Mr. Phil Brinkman of the FAA in DC, I asked if the FAA still wanted TRA to internally review flights over 25K, and the answer was "No". However, it would be prudent for the flier to have documentation on his/her flight to supply to the waiver holder to answer any queries from the FAA on any individual flight.

The real question is why the impulse change was made. The FAA discussion claims:

Quote:
Several commenters recommended the upper limit for Class 3 be reduced from 163,840 Newton-seconds to 40,960 Newton-seconds. They stated this reduction would place the upper limit at the ''O'' class, as documented in the TRA safety code. Some commenters noted that a rocket carrying a motor above the ''O'' class, or 40,960 Newton seconds, could reach altitudes greater than 7,620 meters (25,000 feet). These commenters suggest any rocket with the ability to reach greater altitudes belongs in Class 4-Advanced High-Power Rockets.

The FAA agrees.

I searched the docket and found only one person who recommended the change to 40,960 N-s. In the TRA Research code, individuals can fly up to full P impulse (81920) without Board review. My suggestion when applying for waivers is to request the cap for Class 2 be increased to 81920 N-s, especially if your site has a safe history of previous flights at that impulse at your granted altitude.

Also, it is possible that the concern about the extra documentation for Class 3 flights is exaggerated. The new regulations do not require extra documentation for each flight or each rocket, but rather for each type of rocket (same exact wording as is used for Class 2 rockets), so a club may seek a blanket waiver for Class 3 flights that answers those questions once.

In my previously mentioned conversations with Mr. Brinkman, that was not hammered out. But, according to the published rules.

Quote:
When a Class 3 - Advanced High-Power Rocket requires a certificate of waiver or authorization the person planning the operation must provide the information below for each type of rocket to the FAA at least 45 days before the proposed operation. The FAA may request additional information if necessary to ensure the proposed operations can be safely conducted. The information shall include for each type of Class 3 rocket expected to be flown:

The other concern is the requirement of launch site size as per altitude requested. While it is prudent to want to protect uninvolved people, one quarter to altitude, say, for Wayside's past granted altitudes of 50000', equates to no highways or non launch site owner homes be closer than 2.37 miles.

Quote:
In consideration of the comments recommending the FAA adopt the NFPA 1127 separation distance requirements, we will require an additional separation distance from any person or property not associated with the operation. This decision is based on the minimum site dimensions provided in NFPA 1127. In the regulation, we instead specify this as an equivalent separation distance assuming the launch location is in the center of the site. This minimum separation distance is equal to one quarter of the expected maximum altitude or 457 meters (1,500 ft.), whichever is greater. Under normal conditions, this requirement will be adequate to protect public safety. When greater separation distances are required to protect spectators, the FAA will specify additional operating limitations in any certificate of waiver or authorization it may grant.

The FAA believes its principal responsibility is to protect those individuals and property not associated with the launch. This approach differs somewhat from that taken under 14 CFR Chapter III where the FAA counts spectators as part of the public in its risk analysis. The rationale for this different approach reflects the good job rocketry associations do in protecting spectators. Usually, spectators viewing amateur rocket launches are more closely associated with the operations than those viewing FAA-licensed launches and do not have as great a potential for a catastrophic accident, such as loss of life or serious injury.

As I said, there are many winners in these new regulations, but there will be a few hills to climb for some as well.

Finally, see below a sample form for Class Two Waiver applications. I hope it helps you in applying for your new 2009 waivers. If you have already been granted your 2009 waiver prior to the effective date of this ruling of February 2, 2009, the new regulations will not affect you, according to Mr. Brinkman.

(Attachment for FAR 101.29 information)
(put your club name here)

The following is the attachment mentioned on line 10 of form 1177-2 and provides the information requirements of FAR 101.29

101.29 (a)(1) The "put your club name here" will be launching approximately seventy (70) rockets each day of our weekend launch.

101.29 (a)(2) These rockets will be powered with commercial rocket motors utilizing Ammonium Perchlorate Composite Propellant (APCP) and hybrid rocket motors utilizing Nitrous Oxide as the oxidizer and a plastic or paper solid fuel grain.

101.29 (a)(3)  The rockets will be ground launched from solid launchers that will maintain a vertical trajectory for the rocket as it leaves the launcher per NFPA 1127  and NAR safety code.

101.29 (a)(4) The rockets will contain a parachute, streamer, aero-breaking, or gliding  recovery system that will return them safety to the ground per NFPA 1127 and NAR safety code.

101.29 (a)(5) The rockets will be operated below "put your waiver request here" AGL

101.29 (a)(6) The operations launch site is located at "put your GPS coordinates here"

101.29(a)(7) The flight operations will be conducted per all details of FAR 101.25, as well as following the NAR high power rocket safety code and NFPA 1127.***

We will be providing notification to the ATC per the requirements of FAR 101.27 and will be providing the following information:

(a) The name and address of the operator; except when there are multiple participants at a single event, the name and address of the person so designated as the event launch coordinator, whose duties include coordination of the required launch data estimates and coordinating the launch event;
(b) Date and time the activity will begin
(c) Radius of the affected area on the ground in statute miles
(d) Location of the center of the affected area in latitude and longitude coordinates
(e) Highest affected altitude
(f) Duration of the activity
(g) Any other pertinent information requested by the ATC facility.

*** if you are also waiving 101.25(b)(5) also state the following and adjust to your requirements:
However we are also asking for a waiver of 101.25(b)(5) to conduct operations within 5 miles of the uncontrolled grass paved airport located at "GPS" and have the FAA call sign of "XXX"

Finally, I believe that this ruling will be a learning process for both the HPR enthusiast and the FAA. I also believe that the FAA is one of the best Federal Agencies I have ever dealt with, one that reasonably makes efforts to serve any questions we may have, and have historically been very accommodating.

Happy Flying

Pat Gordzelik

Pat Gordzelik is long-term hobby rocketry enthusiast known for his passion for propellant and lives in the Texas Panhandle with his wife Retta.  Pat also serves as a board member on the Tripoli Rocketry Assocation Board of Directors.