WASHINGTON, District of Columbia USA -- In preparation for Tuesday's status conference in United States District Court before Judge Reggie B. Walton, the Bureau of Alcohol, Tobacco, Firearms and Explosives (BATFE) have filed with the court the results of their tests relating to the explosive nature of ammonium perchlorate composite propellant (APCP).

Previously, the United States Court of Appeals had remanded the case back to the District of Columbia Circuit Court for reconsideration of whether or not APCP was truly an explosive.  APCP had been included on the original List of Explosives that Congress from 1971 mandated to the BATFE for oversight, and a cornerstone of the Tripoli Rocketry Association vs BATFE case in front of Judge Walton was that APCP wasn't an explosive by definition and should not be regulated.

The Court of Appeals found that there was no scientific basis in the determination that APCP was an explosive and earlier this year, the Judge Walton instructed the BATFE to conduct a series of tests to reconsider APCP's explosive classification.

The tests, conducted by the U.S. Air Force Research Laboratory at Tyndall Air Force Base, Florida, compared the burn rate of APCP to safety fuse, a product referenced in federal law as an 'explosive.' The definition of Explosives used for making this determination is contained in 18 U.S.C., Chapter 40, Section 841(d): "'explosives' means any chemical compound mixture, or device, the primary or common purpose of which is to function by explosion; the term includes, but is not limited to, dynamite and other high explosives, black powder, pellet powder, initiating explosives, detonators, safety fuses, squibs, detonating cord, igniter cord, and igniters."

BATFE developed the testing protocols for their comparison that would be "repeatable and consistent."  Safety fuse was classified as a "typical low explosive" where the reaction/burning rate for safety fuse was approximately 7.5 millimeters per second, claiming "though there are special use low explosives that react at rates slower than 7.5 millimeters per second."

Original ATF graphic submitted to U.S. District Court

According to these tests, ordinary bond paper burned more rapidly than safety fuse, and nearly as fast as APCP.  Safety fuse was obviously chosen for this laboratory comparison because it is referred to specifically by name in the federal law as an explosive but displayed burn rate characteristics that were less than APCP.  This result would seem to indicate that safety fuse is also mis-categorized as an 'explosive' or that perhaps 'bond paper' should be reconsidered in a future act of rulemaking as an 'explosive.'

ATF data reset with normal, non-logarithmic perspective applied to burn rate data points

If you look at the data reconfigured on a chart with normal, non-logarithmic perspective between the data points, you can see the burn rate difference of true explosives (black powder) and non-explosives (APCP, safety fuse and bond paper).  To the non-analytic observer, perhaps even to the judge, the original ATF graphic gives the impression that APCP is half as explosive as black powder.  But when viewed in this normal, non-logarithmic perspective, the burn rate of APCP becomes almost a "non-event."

While these results were completely expected under the circumstances, Tuesday's status conference is certain not to produce any immediate relief for hobby rocketry enthusiasts across the country.  With the latest BATFE rule change that took effect on October 10th, rocketry enthusiasts found the popular "Easy Access" exemption laid to rest, effectively ending the decade-long practice of motors and reload kits with APCP propellant grains containing less than 62.5 grams of propellant being exempt from federal oversight.  For years, hobbyists were able to fly up to "J" impulse class motors without a federal permit.  After the latest rule change that took effect on the 10th, this level was capped at the "G" impulse class.

The test results were filed in United States District Court Friday, October 13th, 2006.  With the filing of these documents, the BATFE's official position remains that APCP is properly classified as an explosive.  The court filings have been included here as Adobe PDFs.

DEFENDANT'S NOTICE OF AGENCY DECISION (PDF - 26K)
MEMORANDUM: AMMONIUM PERCHLORATE COMPOSITE PROPELLANT EXPLOSIVES CLASSIFICATION (PDF - 863K)

10-15-2006 08:10 PM  #1
crontab Certified Level Three   Joined: Aug 2006 Posts: 204	Only the ATF could come up with "fuzzy math" where half of 9615 is 143! Judging from the graph they submitted in their report, their intent to deceive is very clear. It is an insult to the presiding judge in this case that they think he is an idiot, evidenced by there attempt to pull this stunt in his court room.

10-15-2006 10:41 PM  #2
Just Jerry Freeform rockets advocate   Joined: Aug 2006 Posts: 1257	Thank you for the updated chart. Keep in mind the "range" of APCP burn rates are INCONSISTENT with my 35 years of PROFESSIONAL experience. For 500 psi firings (intended use) burning rates range from 0.11 to 0.62 ips for both consumer and commercial propellants we (companies I interface with) use. The ambient burning rates are between 2 and 10 mm/s. SO, the ATF is a lying sack of s%it. The DOT was too, so no surprise. Manganise dioxide my ass. Just Jerry! P.S. "propellant fragments". Hmmm. Do they mean unignited/extinguished whole grains? They do. Liars extreme. Is that "extreme rocketry"?? P.P.S. The ONLY AP which is explosive (list) has a particle size of UNDER 15 micron. Adding rubber further DESENSITIZES APCP!!!!!!!!!!!

10-16-2006 09:33 AM  #3
Len_Lekx Certified Level Two   Joined: Aug 2006 Posts: 53	I really liked the way that the BATFE interpreted the order... Instead of going to the lab (Air Force or otherwise...) and saying "We need you to determine whether or not APCP is an explosive", to which the lab would set up their own protocols and experiments, they HANDED the lab the protocols and experiments to run. The term "Garbage In - Garbage Out" comes immediately to mind...

10-16-2006 03:24 PM  #4
kgholloway APCP-4E   Joined: Sep 2006 Posts: 14	Jerry, Did you notice that in one paragraph the BATF states that not all APCP formulations can be classifed as explosive under their protocols. But then they do not reveal the formulations that they tested. That makes the whole report unsound. They could have used APCP formulations with additives such as RDX which, as I understand, would greatly increase the burn rate. In order for the report to meet even half of the appelate court's order they would have had to limit testing to hobby formulations and reported what they were. Of course you can not expect the BATF to be either fair or truthful in their reporting. Ken Holloway

10-16-2006 05:18 PM  #5
daveyfire Certified Level One   Joined: Aug 2006 Posts: 23	For anybody who's taking LSATs to get into law school this semester while simultaneously complaining about having to learn logarithms and the meaning of "powers of 10"... I'll show them this graph. (My roommate is one of them...) For the data they gathered, the presentation is scientifically accurate but horribly misleading. If shown the plots on a linear scale, suddenly their data doesn't seem so conclusive...

10-16-2006 08:27 PM  #6
xman New Member   Joined: Oct 2006 Posts: 2	daveyfire hit it right on the mark. logarithmic scales are very misleading. I just hope that everyone who sees this graph realizes the significance.

10-16-2006 10:55 PM  #7
Just Jerry Freeform rockets advocate   Joined: Aug 2006 Posts: 1257	Quote: Jerry, Did you notice that in one paragraph the BATF states that not all APCP formulations can be classifed as explosive under their protocols. But then they do not reveal the formulations that they tested. That makes the whole report unsound. They could have used APCP formulations with additives such as RDX which, as I understand, would greatly increase the burn rate. In order for the report to meet even half of the appelate court's order they would have had to limit testing to hobby formulations and reported what they were. Of course you can not expect the BATF to be either fair or truthful in their reporting. Ken Holloway They also could have used APCP where the fuel is a POWDER such as PVC. Just Jerry

10-17-2006 07:14 PM  #8
ddmobley Administrator   Joined: Jul 2006 Posts: 3552	Quote: For the data they gathered, the presentation is scientifically accurate but horribly misleading. If shown the plots on a linear scale, suddenly their data doesn't seem so conclusive... Actually, NO. The presentation is NOT accurate. Look at the ATF graph again. On the lower bound of APCP, they state the burn rate is 36mm/sec. On the graph, the APCP lower bound falls between the "10" and the "100" mm/sec placement. If you use logic to determine that halfway between 10 and 100 is arrived at by subtracting 100-10=90. 90/2=45. 45+10=55. Therefore halfway between 10 and 100 on the lower bound of APCP is 55. The lower bound of APCP the ATF has charted on the graph is charted as slightly more than halfway between 10 and 100, yet it labeled as 36. 36 <> 55. If I were to logarithmically chart 36mm/sec on the chart, it would be EVEN CLOSER to the "10" end of the scale. The data is inaccurate no matter how you look at it.

10-17-2006 07:40 PM  #9
UhClem Certified Level Three   Joined: Oct 2006 Posts: 184	The graph is accurate. Log10(36) = 1.56, log10(55.8) = 1.75, log10(143) = 2.16 If that isn't convincing, here is an electronic sample of log paper. http://polymer.bu.edu/ogaf/image/fig22.gif There is nothing wrong with the graph with the possible exception of the choice of a log scale.

10-18-2006 12:48 AM  #10
ddmobley Administrator   Joined: Jul 2006 Posts: 3552	Leave it to me to invert the process. But it's illogical.

11-11-2006 07:03 PM  #11
tooch New Member   Joined: Nov 2006 Posts: 8	AFRL APCP burn rates are calculated wrong! I just was looking over the just released Documents from the ATF filing. The one intitled "Reaction Rate Determinations of Hobby Rocket Motors, Time Fuse and Powdered Propellants," United States Air Force Research Laboratory (AFRL), AFRL-ML-TY-TP-2006, July 2006. calculates burn rates of propellants by firing rocket motors, measuring burn times and measuring the length of the fuel grain and dividing. (page12) Only problem is this method assumes a end burning propellent! All of the APCP tested motors are core burners! If you use this method of course the burn rate is high! Our govement dollars at work! tooch

11-12-2006 04:34 PM  #12
Len_Lekx Certified Level Two   Joined: Aug 2006 Posts: 53	Sloppiest piece of work I've ever seen. `Nuff said.

11-12-2006 10:19 PM  #13
tooch New Member   Joined: Nov 2006 Posts: 8	Yes, but the Program Mgr. David S. Shatzer certifed under penalty of perjury that the foregoing is true and correct. Makes a big difference. Tooch

11-12-2006 10:26 PM  #14
Len_Lekx Certified Level Two   Joined: Aug 2006 Posts: 53	Quote: Yes, but the Program Mgr. David S. Shatzer certifed under penalty of perjury that the foregoing is true and correct. Makes a big difference. Well... it IS "True and Correct" for the assumptions they performed the tests under. The fact that the assumptions THEMSELVES were flawed - that ain't HIS fault. (Or, at least, that's the way it can be argued in court...)

11-12-2006 11:16 PM  #15
tooch New Member   Joined: Nov 2006 Posts: 8	Actually no, The first document outline what they wanted to measure and the method to do it, but lacked any direction for measurment of the fuel grain. There were no assumptions. They told the AFRL to determine the burn rate of APCP using the model rocket motors themselves. It is his direct responsibility to make sure that any documents presented are in FACT "true and correct". I spent 15 minutes with the documents and found the errors. And even if there were assumptions, he has responsiblity to make sure they are also "true and correct". That's the way it should be argued in court! Of course he could have just been happy with the results and didn't want to look any deeper. tooch

11-13-2006 10:37 AM  #16
Len_Lekx Certified Level Two   Joined: Aug 2006 Posts: 53	Quote: Of course he could have just been happy with the results and didn't want to look any deeper. Quite likely that's the case. Errors that SUPPORT your assertions are overlooked, while facts that refute are examined VERY carefully... before being discarded as 'irrelevant'. I can't wait to see how this plays out...

11-13-2006 03:16 PM  #17
Len_Lekx Certified Level Two   Joined: Aug 2006 Posts: 53	I did a test of my own, using a K445 I happened to have in storage. Using the manufacturers' data for burn-time, and measuring the thickness of the propellant from inside of the core to liner, I came up with a burn rate of 4.15mm/s. That's almost an order of magnitude lower than the slowest rate the ATF came up with for APCP... it's also almost half the rate that safety fuse burns at. Not to mention - it's marginally slower than bond paper!

11-13-2006 06:43 PM  #18
Just Jerry Freeform rockets advocate   Joined: Aug 2006 Posts: 1257	Quote: I did a test of my own, using a K445 I happened to have in storage. Using the manufacturers' data for burn-time, and measuring the thickness of the propellant from inside of the core to liner, I came up with a burn rate of 4.15mm/s. That's almost an order of magnitude lower than the slowest rate the ATF came up with for APCP... it's also almost half the rate that safety fuse burns at. Not to mention - it's marginally slower than bond paper! It is possible to come to this conclusion from PUBLISHED data (burn time, web thickness) on the Aerotech website (www.aerotech-rocketry.com) without ever lifting a finger or igniting any propellant. That said, and given the resources thrown at this problem, it can probably be proven they did or should have known this, and did these tests anyway, and when the results varied from KNOWN DATA, went with it anyway. Yes, gents, that IS perjury. Oops. Just Jerry EDIT: Changed Errortech to Aerotech. Jerry, violations of TOS are going to be your undoing.

11-13-2006 08:08 PM  #19
Len_Lekx Certified Level Two   Joined: Aug 2006 Posts: 53	Quote: It is possible to come to this conclusion from PUBLISHED data (burn time, web thickness) on the Errortech website without ever lifting a finger or igniting any propellant. Well... I used a CTI motor, and Anthony doesn't list the web thickness in the data. Also, since I attached everything in a note I EMailed to Mark Bundick, I figured it would be prudent to SHOW how I came to my results. Quote: That said, and given the resources thrown at this problem, Personally, I'm not sure if the resources went into ADDRESSING the problem, or SPINNING it. (From the standpoint of the BATFE, at least...

11-13-2006 08:14 PM  #20
Len_Lekx Certified Level Two   Joined: Aug 2006 Posts: 53	Quote: PUBLISHED data (burn time, web thickness) on the Errortech website Out of Curiosity, Jerry - I had a peek at the Aerotech website, and couldn't find where the web thickness was listed. On some of the certification letters, I saw dimensions for the nozzle throat, but nothing for core diameters, propellant diameters (as opposed to actual motor diameters...) or slot sizes. Maybe you could point out the page you saw them in...?

11-13-2006 10:47 PM  #21
Just Jerry Freeform rockets advocate   Joined: Aug 2006 Posts: 1257	Quote: Out of Curiosity, Jerry - I had a peek at the Aerotech website, and couldn't find where the web thickness was listed. On some of the certification letters, I saw dimensions for the nozzle throat, but nothing for core diameters, propellant diameters (as opposed to actual motor diameters...) or slot sizes. Maybe you could point out the page you saw them in...? Cheerfully. www.aerotech-rocketry.com CLICK Resources. CLICK RMS Assembly Drawings. CLICK RMS-38 High Power Assembly Drawings. CLICK 38-720-W-M. ZOOM to item 8 (grains) Cite: 03581-J350 GRAINS (1.308" O.D. X 1.815" X .500" CORE) Oops!! The exact load involved in the "Keystone Cops Incident" AND the "lying sack of sh|t" filing. How handy indeed JUST Jerry again EDIT: Strike 2.

11-13-2006 10:49 PM  #22
tooch New Member   Joined: Nov 2006 Posts: 8	One thing to note, some if not all of the current reloadable motors burn not only from the core to the wall but from the ends of the grains to center. So there is a lot on burn area that we are not counting in calculation. The rate is actually slower. Tooch

11-13-2006 10:49 PM  #23
Just Jerry Freeform rockets advocate   Joined: Aug 2006 Posts: 1257	Quote: Cheerfully. The exact load involved in the "Keystone Cops Incident" AND the "lying sack of sh|t" filing. How handy indeed JUST Jerry again BTW I actually ENJOY this stuff F the government. The constitution tells me so.

11-13-2006 11:01 PM  #24
Just Jerry Freeform rockets advocate   Joined: Aug 2006 Posts: 1257	Quote: One thing to note, some if not all of the current reloadable motors burn not only from the core to the wall but from the ends of the grains to center. So there is a lot on burn area that we are not counting in calculation. The rate is actually slower. Tooch A tiny amount if you do a regression calculation. Burnsim? Just Jerry

11-13-2006 11:22 PM  #25
Len_Lekx Certified Level Two   Joined: Aug 2006 Posts: 53	Quote: Cheerfully. I didn't look in the right place. Thanks. And you're right - with that info, they could have done the burn-rate calculations without having to do any test-firings. (Probably wanted to make it look "Independently-Verified"...)

11-13-2006 11:27 PM  #26
Just Jerry Freeform rockets advocate   Joined: Aug 2006 Posts: 1257	Quote: I didn't look in the right place. Thanks. And you're right - with that info, they could have done the burn-rate calculations without having to do any test-firings. (Probably wanted to make it look "Independently-Verified"...) I am always right I sometimes get punished for that Do I need to publish a surface vs time chart for that grain? Just Jerry 27 CFR 555.141-a-8 (ANY size grain is exempt. Got your AmEx for that 10x shuttle size motor?)

11-14-2006 12:41 AM  #27
Kapton Certified Level Two   Joined: Oct 2006 Posts: 34	J350W.. Web thickness (1.308 in - .500 in)/2 = .404 in. Burn rate: .404 in/1.94 sec = .208 in/sec .208 in/sec x 25.4 mm/in = 5.29 mm/sec Slower than safety fuse at 7.48 mm/sec or M700 fuse at 7.26 mm/sec.

11-14-2006 10:38 AM  #28
Just Jerry Freeform rockets advocate   Joined: Aug 2006 Posts: 1257	Quote: Do I need to publish a surface vs time chart for that grain? Chipmunk BASIC v3.5.0 >run "surfaceBATES.bas" Copyright 1998 Jerry Irvine - Surface.bas SINGLE GRAIN BATES SURFACE VS DISTANCE Grain OD inches = 1.25 Core Dia inches = .5 Total Grain Length = 1.815 INCREMENT WEB PT SURFACE ========= ====== ======== 1.00 0.02 4.91 2.00 0.04 5.00 3.00 0.06 5.08 4.00 0.07 5.14 5.00 0.09 5.19 6.00 0.11 5.23 7.00 0.13 5.25 8.00 0.15 5.26 9.00 0.17 5.26 10.00 0.19 5.24 11.00 0.21 5.21 12.00 0.22 5.17 13.00 0.24 5.11 14.00 0.26 5.04 15.00 0.28 4.96 16.00 0.30 4.86 17.00 0.32 4.75 18.00 0.34 4.63 19.00 0.36 4.49 20.00 0.37 4.34 Progresivity % = -11.6 > You can chart this in Excel and normalize burn time to the final 20 point. Just data Jerry

11-14-2006 11:26 AM  #29
Len_Lekx Certified Level Two   Joined: Aug 2006 Posts: 53	Quote: I am always right Not always... you're only human, after all... Quote: I sometimes get punished for that Actually... I think you get 'punished' because you seem to derive immense pleasure from being an 'In Your Face' kind of guy. Something else I'd like to point out about the ATF report... Did you notice that two of the motors they tested used the same propellant formulation, yet they came up with two VERY different burn-rates...? The J350W and the G40-10W both use the White Lightning propellant, yet the J350 is reported to burn almost four times faster than the G40. Another strike against their testing procedures...

11-14-2006 01:13 PM  #30
Kapton Certified Level Two   Joined: Oct 2006 Posts: 34	Quote: Did you notice that two of the motors they tested used the same propellant formulation, yet they came up with two VERY different burn-rates...? The J350W and the G40-10W both use the White Lightning propellant, yet the J350 is reported to burn almost four times faster than the G40. Another strike against their testing procedures... That's an artifact of using the grain length instead of web thickness to determine burn rate. The length to web thickness ratio of the J350 is much greater than that of the G40, yielding a higher incorrect number for the J350 than the incorrect number they got for the G40.

11-14-2006 04:56 PM  #31
Len_Lekx Certified Level Two   Joined: Aug 2006 Posts: 53	Quote: That's an artifact of using the grain length instead of web thickness to determine burn rate. I *know* that - and that's why it needs to be pointed out in court. It's yet another flaw in their testing procedures, and illustrates how poorly they were put together in the first place.

11-14-2006 08:46 PM  #32
tooch New Member   Joined: Nov 2006 Posts: 8	They *knew* that too. You honestly think that testing lab is that stupid? If I were the judge I would throw the whole thing out just for insulting my intelligence. tooch

11-14-2006 09:40 PM  #33
Len_Lekx Certified Level Two   Joined: Aug 2006 Posts: 53	Quote: They *knew* that too. You honestly think that testing lab is that stupid? Possibly. But I'm trying to give them the benefit of the doubt... by not attributing to malice what can be attributed to foolishness.

11-15-2006 05:09 PM  #34
tooch New Member   Joined: Nov 2006 Posts: 8	I can appreciate that, but unless I am mistaken you are in Canada and don't directly pay for these people to protect and serve you. If a minister in your goverment came out with this garbage I believe you would feel differently. If they are foolish they should be fired, If there is malice they should be fired either way someone needs to be accountable. tooch

11-15-2006 07:04 PM  #35
Len_Lekx Certified Level Two   Joined: Aug 2006 Posts: 53	Quote: I can appreciate that, but unless I am mistaken you are in Canada and don't directly pay for these people to protect and serve you. If a minister in your goverment came out with this garbage I believe you would feel differently. Look - I'm on your side. I ENJOY travelling to the US to attend launches. I'm even trying to make myself 'Legal' by getting special permission for a LEUP. (And if you think YOU have it bad... try getting one as a non-citizen!) I just don't believe that the best way to solve the problem is to run at them screaming "You're LYING, and you KNOW it!"... Conspiracy Theories are great for movies, but don't do anything to support our position. On the other hand - well-thought-out and rational arguments, backed up with experimental evidence, DO. Quote: If they are foolish they should be fired, If there is malice they should be fired either way someone needs to be accountable. True enough. But let's just prove that they're wrong, and let the foolishness or malice come out later.

11-16-2006 01:07 PM  #36
tooch New Member   Joined: Nov 2006 Posts: 8	No offense ment or implied. I also love going to Canada whenever I can! And I know you are on our side. No conspiracy theories either. They are not lying. They are just presenting scientific data with a spin or in ignorance. There are just not a lot of options here for a conspiracy. Exploring motivations is sometimes key in court cases and scientific data sometimes gets lost to legal system so we should explore motives with just as rational and well thought out arguments as the data. tooch

11-16-2006 08:58 PM  #37
Len_Lekx Certified Level Two   Joined: Aug 2006 Posts: 53	Apologies. I'm in a rather stressful period right now, and I seem to be taking offense quicker than I should. No matter what we do, everyone tries to 'spin' scientific data to their own ends. They do it, we do it... all we can do is hope that the facts come out between the spin cycles.

11-17-2006 10:00 AM  #38
tooch New Member   Joined: Nov 2006 Posts: 8	Well said! I just wish we all had less ego in it. Truth should be truth in science. I wish you all the best. tooch