From: mckiou@cbnewse.cb.att.com (kevin.w.mckiou)
Newsgroups: rec.models.rockets
Subject: FAA Petition - News & Request
Date: 23 Nov 92 15:08:31 GMT
Distribution: usa
Organization: AT&T

I just received the following from Mark Bundick (VP NAR) with a request
to post it to RMR.  I strongly support the NAR's position in this matter
and will be sending the FAA a letter to that effect.

Kevin  McKiou

--------------------------------------------------------------
Many of you know that the NAR has petitioned the FAA to change Part  
101.  These are the Federal Air Regulations which govern the  
operation of model rocket flight in the United States.  After  
considerable work with Shaw Pittman, the NAR's legal counsel in  
Washington, DC, the NAR's 80 page legal response to the published  
NPRM is ready to delivery to the FAA.  Pat Miller, the NAR President,  
asked me to post the following letter, recently sent to all NAR  
Section presidents and senior advisors, in rec.models.rockets. 


His letter asks for YOUR help in changing Part 101, and to avoid  
further regulation on the hobby by the FAA.  In particular, the FAA  
wants to create a new class rockets, "large model rockets" that would  
still require notification to an FAA Air Traffic Control (ATC)  
facility before flight.  Additional notice would have to be given to  
airport managers if the flights were within 5 miles of any airport.

Counsel's opinion to  the NAR is that such rules are unnecessary, and  
have no basis in either the NAR's Barber Commission study of 1985 or  
the FAA's own study done in 1991.  The technical data does not  
demonstrate that the operation of 3.3 lb rockets poses any further  
hazard to air traffic than models currently allowed under Part 101  
operation.  Shaw Pittman prepared extensive documentation to support  
this assertion in the NAR's formal response to the NPRM, hence the 80  
page length.

Counsel also advised us that the most EFFECTIVE way NAR members could  
demonstrate their support for our petition would be to write a simple  
one page letter stating their support of the NAR's response to the  
NPRM.  Counsel believes NAR members should indicate they feel there  
is no need for a "large model rocket" category, that notification is  
not required, and that the NAR's original petition, which simply  
increased the weight limits to 3.3 lbs liftoff weight and 4.4 oz. of  
propellent,  should be adopted.

I STRONGLY encourage you to write your letter today, and send it IN  
DUPLICATE to the address shown in Pat's letter.  If you can  
demonstrate your support of the NAR's response, I'm confident that  
those letters, coupled with Shaw Pittman's outstanding legal work,  
will bring the Part 101 changes we seek.

You're also welcome to direct any further questions to Pat at  
72077.65@compuserve.com, to NAR Secretary C. D. Tavares at  
cdt@rocket.sw.stratus.com, or to me at mark@fnbc.com. We'd be happy  
to answer any questions you might have.
 

I know it's getting to be a buzy time of the year, but please take a  
half an hour today to write in support of this petition. You'll soon  
be the direct (and happy!) beneficiary of your work!

Cheers,  Bunny
(Mark B. Bundick, NAR Vice President)
========================================
November 24, 1992

Dear NAR Section Officer,

In May 1985 the National Association of Rocketry (NAR) and the Hobby  
Industries of America (HIA) proposed the following two changes to the  
Federal Air Regulations (FAR Part 101):

1.    Change the model rocket liftoff weight from 1 lb (453 gm) to
      3.3 lb(1500 gm).
2.    Change the model rocket propellant mass from 4 oz (113 gm) to
      4.4 oz(125 gm).

This proposal was made after an extensive technical study by the NAR.   
On September 10th after a seven year delay, the Federal Aviation  
Administration (FAA) published its Notice of Proposed Rulemaking  
(NPRM) in the Federal Register Vo. 57, No. 176, at p. 41628.

In summary the FAA's NPRM proposes the following:

a.	Introduction of a "large model rocket" category for models  
which weigh more than 1 lb at liftoff but not more than 3.3 lb, and  
have  between 4 oz and 4.4 oz of propellant.

b	"Large model rockets" flown outside five miles from an  
airport  require notification of the nearest FAA Air Traffic Control  
(ATC) facility.

c.	"Large model rockets" flown inside five miles of an airport  
require  notification of the nearest FAA ATC and the airport manager.

The NAR has prepared a response to the FAA's NPRM.  It is the  
position of the National Association of Rocketry that the May 1985  
proposal stands on its own merit.  Studies commissioned by both the  
FAA and NAR indicate that there is no increased hazard to aircraft  
with the heavier models.

Notification is not required for model rockets.  It is the NAR's  
position that notification should not be required for "large model  
rockets."  In fact, the NAR feels there is no reason to have a "large  
model rocket" category.

Public response to the FAA NPRM is due on or before December 9, 1992,  
in duplicate, and should be sent to the following address:

Federal Aviation Administration
Office of Chief Counsel
Attention:  Rules Docket AGC-10
Docket No. 26965
800 Independence Avenue S.W.
Washington, D.C.  20591

The NAR hopes you will carefully evaluate its official position on  
the FAA NPRM. The NAR hopes you will support and endorse this  
position in writing.  You are encouraged to provide a written  
response to the FAA at the above address.

Also, you are encouraged to share this letter with all of the members  
of your Section.  The NAR would appreciate their support and written  
responses to the FAA, as well.

To be the most effective it is important that all written responses  
arrive at the FAA on or about December 8, 1992.  The NAR will file  
its official position on that date, and the coincident support from  
you and the members of your Section will increase the effectiveness  
of this position.

Thanks!

J. Patrick Miller, President
Newsgroups: rec.models.rockets