Meeting about Amateur Rocket NPRM\
with Mark Bundick, NAR\
date: 07/26/2007

**attendees:** Phil Brinkman, Chuck Larsen, Marcus Ward, Sue Lender,
Mark Bundick

**subject:** Receive comments on the Amateur Rocket NPRM

+----------------------+-----------------------------------------------+
| **Introduction**     | Mark Bundick of the National Association of   |
|                      | Rocketry (NAR) requested a meeting with the   |
|                      | Office of Commercial Space Transportation     |
|                      | (AST) to present his organization's comments  |
|                      | on the Amateur Rocket NPRM. AST agreed to the |
|                      | meeting, noting that its representatives      |
|                      | could listen to the comments, but could not   |
|                      | provide any substantive responses. The        |
|                      | meeting was taped. All participants agreed to |
|                      | the taping. These minutes summarize the       |
|                      | meeting.                                      |
+----------------------+-----------------------------------------------+
| **Background**       | Mr. Bundick gave us his "two-minute elevator  |
|                      | speech" to provide background on the NAR. The |
|                      | organization was founded in 1957 because a    |
|                      | lot of young men were interested in building  |
|                      | their own rockets because of the space race.  |
|                      | And they ended up blowing themselves up. An   |
|                      | aerospace engineer out at White Sands, Harry  |
|                      | Stein realized if he combined a pre-packaged  |
|                      | engine with a rocket made out of breakable    |
|                      | materials and put a safety coat around it     |
|                      | that he could stop these young men from       |
|                      | killing themselves and turn them into real    |
|                      | rocket engineers.                             |
|                      |                                               |
|                      | Mr. Bundick described the NAR's service       |
|                      | programs and education outreach to teachers.  |
|                      | He described their Team America Rocketry      |
|                      | Challenge event. With the Aerospace           |
|                      | Industries Association they partner and       |
|                      | distribute \$60,000 worth of scholarship      |
|                      | money to high school students who participate |
|                      | in the challenge to launch an egg to a        |
|                      | specified altitude and have it land exactly   |
|                      | 45 seconds later.                             |
+----------------------+-----------------------------------------------+
| **NAR safety         | Mr. Bundick noted that because of NAR's       |
| culture**            | origins in the aerospace industry and because |
|                      | Harry was the safety officer at White Sands,  |
|                      | there is a cultural imperative within the     |
|                      | organization to protect the safety of the     |
|                      | hobby. They have had a lot of input over the  |
|                      | years into FAA regulations for model rockets. |
|                      |                                               |
|                      | Over time the NAR has modified Harry's safety |
|                      | code. Every time that they've done so,        |
|                      | they've undertaken a major technical study    |
|                      | behind changing the regulations. The code is  |
|                      | sacrosanct to the NAR. They don't want to     |
|                      | change it unless they think we have a good    |
|                      | technical reason. He gave some examples of    |
|                      | studies they've conducted. The most recent    |
|                      | one resulted from observations of recovery    |
|                      | failures on some ranges. The study was        |
|                      | published in 2006. Mr. Bundick offered to     |
|                      | provide it as an addendum to the NAR's        |
|                      | comments. FAA staff asked if the NAR planned  |
|                      | to reference the document in their comments.  |
|                      | If so, they would want to submit the study    |
|                      | with their filing. Mr. Bundick noted that the |
|                      | study was prepared by Jay Apt, a long time    |
|                      | NAR member and former NASA astronaut, and Ted |
|                      | Cochran, from Johnson Space Center.           |
|                      |                                               |
|                      | Mr. Bundick stressed that the NAR emphasizes  |
|                      | its safety culture with the organization's    |
|                      | new members.                                  |
+----------------------+-----------------------------------------------+
| **NAR ranges**       | Mr. Bundick described the safety codes that   |
|                      | govern the use of their ranges: the Model     |
|                      | Rocket Safety Code and the High-Power Rocket  |
|                      | Safety Code. In order to fly the high-power   |
|                      | rockets (Class 3 rockets in the NPRM),        |
|                      | members must complete a qualification         |
|                      | program. He described the levels of           |
|                      | certification the NAR has for its ranges.     |
+----------------------+-----------------------------------------------+
| **Affiliation with   | The safety codes are also attached as an      |
| the NFPA**           | addendum to the National Fire Protection      |
|                      | codes. That's the National Fire Protection    |
|                      | organization. The NAR is affiliated with      |
|                      | them, again because of Harry. They joined a   |
|                      | technical committee on pyrotechnics in the    |
|                      | NFPA and engaged in an ongoing cycle of       |
|                      | reviewing their codes in the context of NAR   |
|                      | safety codes. The NFPA has a safety code for  |
|                      | model rockets, one for high power rockets,    |
|                      | and one for the manufacturer of the motors.   |
|                      | The NAR provides input and sits on the        |
|                      | technical committee that reviews and          |
|                      | recommends changes to the codes. They're on   |
|                      | about a 3-year cycle of standing revision.    |
+----------------------+-----------------------------------------------+
| **Waivers**          | FAA staff asked how many waiver requests for  |
|                      | flying large model rockets and high-power     |
|                      | rockets NAR members make on an annual basis.  |
|                      |                                               |
|                      | Mr. Bundick stated that the number probably   |
|                      | runs somewhere between 1500 and 2000 launches |
|                      | a year, as an organization. Somewhere between |
|                      | a third and a half of those would be waivered |
|                      | rocket launches.                              |
|                      |                                               |
|                      | Each of these launches is actually an event   |
|                      | where anywhere from 40 to several hundred     |
|                      | rockets could be launched. Mr. Bundick gave   |
|                      | the example of their national sport launch in |
|                      | Muncie, IN. They had a waiver there to 8,000  |
|                      | feet and probably flew 750 rockets in two and |
|                      | a half days of flying.                        |
+----------------------+-----------------------------------------------+
| **Comment on         | Mr. Bundick noted an item in the NPRM about   |
| defining the launch  | the notice requirements. They ask for a       |
| site.**              | definition of the launch site as latitude and |
|                      | longitude. Mr. Bundick stated that many       |
|                      | people file waivers and locate their launch   |
|                      | site by other means. They say, I'm x miles on |
|                      | a VOR radial. Historically, they've filed     |
|                      | waivers like that and they seem to work for   |
|                      | the FAA. So there are other ways to identify  |
|                      | the launch site.                              |
+----------------------+-----------------------------------------------+
| **Comment on         | Mr. Bundick noted a couple of things that are |
| confusing            | confusing the community. One of them is on    |
| information          | the high power rockets, on the Class 3        |
| requirements**       | rockets. The NPRM talks about how total       |
|                      | impulse and altitude are the things that the  |
|                      | FAA is interested in controlling. However,    |
|                      | the information requirements for those        |
|                      | rockets ask for a whole bunch of other        |
|                      | information that's unrelated to total impulse |
|                      | or altitude capability, for example,          |
|                      | propellants and launchers and recovery        |
|                      | systems. The rockets are designed to recover  |
|                      | safely and the safety codes demand that level |
|                      | of performance. The propellants that the NAR  |
|                      | uses are virtually all solids because it's    |
|                      | not economical or practical to use anything   |
|                      | else.                                         |
|                      |                                               |
|                      | FAA staff noted that if the NAR finds         |
|                      | something confusing, these are things they    |
|                      | should comment on and to file in the docket.  |
|                      | If the NAR finds a portion of the NPRM        |
|                      | confusing, chances are that other people do   |
|                      | also. It's also helpful for an organization   |
|                      | to tell the FAA why they think a regulation   |
|                      | is confusing. Give specific examples.         |
|                      |                                               |
|                      | FAA staff also reminded Mr. Bundick that the  |
|                      | NAR is not the only organization with an      |
|                      | interest in this NPRM. Others may have other  |
|                      | viewpoints and the FAA must consider all      |
|                      | comments received.                            |
+----------------------+-----------------------------------------------+
| **Comment on         | Mr. Bundick commented on the section on the   |
| Prohibiting the      | operating limitations for Class 3 rockets     |
| launch of Class 3    | that prohibits launching within 5 miles of an |
| rockets within 5     | airport. He cited examples of people who are  |
| miles of an          | launching within 5 miles of an airport under  |
| airport**            | a waiver. They integrate into the air traffic |
|                      | control system more directly than if they     |
|                      | were 45 miles away from an airport. The       |
|                      | waiver conditions sometimes specify they must |
|                      | be in contact with the appropriate ATC        |
|                      | person. They have conducted launches directly |
|                      | on airport property. The NAR interprets the   |
|                      | NPRM as prohibiting this.                     |
|                      |                                               |
|                      | FAA staff advised Mr. Bundick to make sure    |
|                      | that he spells out his concerns in his        |
|                      | comments along with the examples he gave. The |
|                      | FAA can then give careful consideration to    |
|                      | his organization's position.                  |
+----------------------+-----------------------------------------------+
| **Comment on Class 2 | Mr. Bundick's final concern was the Class 2   |
| model rocket         | model rocket definition. It has its origins   |
| definition**         | in the rule that promulgated back in 1994.    |
|                      | That definition differs from a Class 1 model  |
|                      | rocket only by the weight that's associated   |
|                      | with them. The NAR safety code incorporates   |
|                      | both classes of those rockets into a single   |
|                      | class. They make no distinction in flying     |
|                      | these rockets on their ranges or in how they  |
|                      | operate them.                                 |
|                      |                                               |
|                      | Mr. Bundick stated that he didn't understand  |
|                      | the basis for a weight-based distinction and  |
|                      | definition. The FAA indicates multiple times  |
|                      | in the NPRM that total impulse and the power  |
|                      | is the principle ingredient upon which to     |
|                      | make distinctions between these classes. He   |
|                      | stated that the NAR did not believe the       |
|                      | distinction was necessary.                    |
|                      |                                               |
|                      | FAA staff asked if the suggestion was that    |
|                      | Class 1 and Class 2 be combined into one      |
|                      | class.                                        |
|                      |                                               |
|                      | Mr. Bundick responded that that was the case. |
|                      |                                               |
|                      | FAA staff asked Mr. Bundick to state that     |
|                      | explicitly in the comments he submits to the  |
|                      | docket. If he thinks that three               |
|                      | classifications are more sensible than the    |
|                      | four classifications in the NPRM, he needs to |
|                      | spell that out. When the FAA receives         |
|                      | comments of this nature, it looks at the      |
|                      | comment and says, OK, this organization notes |
|                      | that it doesn't see the reason for the        |
|                      | difference. In the FAA's disposition it will  |
|                      | state the reason for the differentiation.     |
|                      | Sometimes the FAA may say it agrees with the  |
|                      | comment and makes a change in the final rule. |
|                      | Sometimes, it will say, No there was a very   |
|                      | good reason for the rule as stated in the     |
|                      | NPRM and this is what the very good reason    |
|                      | is.                                           |
+----------------------+-----------------------------------------------+
| **Overall positive   | Mr. Bundick stated that the initial reaction  |
| response to the      | to the NPRM was quite positive. He noted      |
| NPRM**               | there is a very active rocketry community on  |
|                      | the internet that exchanges information about |
|                      | stuff. The reaction there was that a lot of   |
|                      | the proposed rule looks pretty reasonable and |
|                      | not unduly burdensome.                        |
+----------------------+-----------------------------------------------+
| **Conclusion**       | FAA staff thanked Mr. Bundick for taking the  |
|                      | time to share his comments with them. They    |
|                      | look forward to seeing NAR's submission to    |
|                      | the docket.                                   |
+----------------------+-----------------------------------------------+