|
ALTOONA, Wisconsin USA — In the December 30, 1999 Federal Register, the Federal Aviation Administration announced its intention to seek informal public comments about potential changes in small rocket regulation via its website.
You can visit this portion of the FAA site by pointing your web browser to:
http://ast.faa.gov/publicforum/index.html
and registering to review comments made by the NAR and others.
At the recent NAR Board meeting in Seattle, the NAR Board reviewed and discussed the Federal Register announcement regarding small rocket licensing. Trip Barber graciously wrote an outstanding summary of the safety record of sport rocket flying in the US, outlining all critical safety provisions of our hobby, and summarising the NAR's position on sport rocket regulations the FAA imposes on rocket flying in the United States. The text of that writeup is attached below, and has been filed on behalf of the NAR with the FAA's website.
Based on this writeup, and my discussions with FAA officials prior to the online forum becoming active, I don't believe additional regulations from FAA are forthcoming for sport rockets flown under the limits of NFPA 1122
and 1127. At this time, I'm not recommending NAR members post comments to the FAA site, though you're certainly free to do so.
As we obtain more information and feedback, I'll keep members informed here and in other Association publications.
Mark B. Bundick, President
National Association of Rocketry
I am submitting this public comment on behalf of the approximately 5,350 members of the National Association of Rocketry (NAR), America's oldest and largest national non-profit organization for sport rocketry hobbyists.
The NAR has 43 years of experience in working with public safety officials, industry, and Federal and state agencies to establish the sport rocketry safety codes and certification standards that today ensure the safety of the public and of sport rocket hobbyists. As a result of this hobby's longstanding focus on safety and self-regulation, it has a truly outstanding record with extremely few injuries or incidents of hazard to public safety.
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. These Codes were developed by safety experts and public safety officials based on a 20-year program of thorough technical analysis and experimental testing by the NAR.
The most popular element of sport rocketry is "model rocketry". Based on the definitions of NFPA Code 1122, model rockets are non-metallic, reusable, safely-recovered rockets of 3.3 pounds or less in weight, propelled by one or more commercially-made, nationally-certified motors having no more than an aggregate total of 4.4 ounces of propellant and 72 pound-seconds of total impulse. Model rockets are currently exempt from FAA control under paragraph 101.4 of the Federal Aviation Regulations. Model rockets are available in hobby stores across the country and many millions of them are safely flown each year across the U.S., by both adults and children. Model rockets are today, and should remain, far below the scope of any regulation or attention in connection with the Commercial Space Launch Act (CSLA).
Over the last two decades, technology developments have permitted major growth in the "high power rocketry" area of the sport rocketry hobby. Safe, commercially-made hobby rocket motors using both solid propellants and hybrid propellants have become widely available at reasonable prices. Dozens of small companies have been established that offer flight vehicle kits using these motors. NFPA Code 1127 (High Power Rocketry) was developed and approved over the past 5 years to regulate this area of sport rocketry.
NFPA 1127 thoroughly controls trajectory safety by including minimum dimensions for launch sites (which increase rapidly with motor power) and by requiring near-vertical ground launch of rockets. It limits the size of "high power rockets" only by motor power; a maximum aggregate power of 40,960 newton-seconds (9208 pound-seconds) is allowed. This Code contains no limits on motor burn time or on rocket ballistic coefficient. The nature of high-power sport rocket design and construction (which uses non-metallic main structures and low internal packing densities) is such that virtually all high-power sport rockets have ballistic coefficients of 5-6 pounds per square inch or less, and none come close to 12 pounds per square inch.
The NAR believes that the current FAA regulation subjecting all rockets, regardless of size, with a total motor burn time of 15 or more seconds to CSLA licensing should be eliminated. Every rocket performance characteristic which has any bearing on public safety-size, energy, altitude, or velocity-depends largely on the power (total impulse) of the motor, not on its burn time. There are hobby rockets as small as one pound today that use motors exceeding 15 seconds of burn time. Mandating a short burn time such as 15 seconds actually reduces public safety by forcing the use of higher-thrust, shorter burn time motors which drive rockets to higher velocities. These higher velocities reduce rocket structural reliability and force the use of higher-strength structures with greater ballistic coefficients.
NFPA 1127 also stipulates that high-power rocket motors must use either solid or hybrid propellant (not liquid), must be commercially-made, must be tested and certified by a "recognized testing organization", and may only be sold to persons who are qualified with a "user certification" from a "recognized organization". The NAR is such an organization for both motor testing and user certification. As a result of these trajectory-control and motor regulations, high power rockets operated under NFPA 1127 offer minimal hazard to public safety on the ground today.
Both the NAR and other sport rocket user organizations have worked with the appropriate Federal agencies to establish procedures for safe and legal conduct of high-power rocketry. The FAA grants hundreds of airspace use waivers each year to permit organized launches of these rockets at specific locations and up to specific altitude limits. NFPA 1127 requires that such waivers be in effect at all high-power rocket launches. These waivers are blanket-type clearances for an indefinite number of flights within the specified time and altitude limits. Launch organizers have developed very effective procedures for ensuring that waiver altitude limits are carefully followed, and NFPA 1127 further requires that the Range Safety Officer at these launches ensure that the area is clear of aircraft before each rocket flight. As a result, high-power rockets operated under NFPA 1127 offer no hazard to public safety in the air today.
Sport rocketry has demonstrated an outstanding safety record and clearly falls within the intent of Congress as "small scale rocket launches from private sites conducted for recreational or educational purposes" and therefore outside the scope of the CSLA.
The National Association of Rocketry respectfully submits that sport rocketry activities conducted under National Fire Protection Association Codes 1122 and 1127 do not offer any significant risk to public health and safety and should be specifically excluded from any consideration for FAA licensing under the Commercial Space Launch Act.
Sincerely yours,
Mark B. Bundick, President
National Association of Rocketry
1311 Edgewood Drive
Altoona, WI 54720
800-262-4872 |
