All,
Just wanted give everyone a little update as to my view of the out come of the meeting. First off if they did not know that we are here they do now, they actually said that in the last week they were made aware of us and some other issues that might be affected by this by the ATFE and others. They also said that they even question if they should even regulate us at all, saying that they thought we might fall under the Division of Fire Safety but not for sure. Did say they would have to check in to it.
Now to help clear things up a little, the state regulations have not changed, the last revision was in 2005. To meet with state regulations anyone that is using and flying rocket motors should have a type I permit. Anyone buying, transporting or selling motor should have a type I and type II permit. If you also need to store motors then you will need a type III as well. This meeting was only to discuss the fee structure.
This is a link to the state regulations:
http://oil.cdle.state.co.us/Public%20Safety/Explosives/EXPLOSIVES%20REGULATIONS2005.doc
This is the only thing that I can find in the state regulations:
1.1 Scope
These rules and regulations shall apply to the use, manufacture, purchase, possession, sale, storage, transportation, and disposal of explosive materials in the State of Colorado by any individual, corporation, company, firm, partnership, association, or state or local government agency.
These rules and regulations shall not apply to:
(H) The use and storage of model rocket motors containing a propellant weight of 62.5 grams or less and which produce less than 17.92 pound seconds of total impulse.
This is their description of the 3 permits they currently have:
Type I Permit: A permit issued by the Division of Oil and Public Safety to individuals who possess and control explosive materials during the use, manufacture, acquisition, purchase, sale, distribution, storage, transportation, or disposal of explosive materials.
Type II Permit: A permit issued by the Division of Oil and Public Safety to corporations, companies, partnerships, firms, individuals operating a business, associations, or state or local government agencies involved in the use, purchase, sale, manufacture, transportation, acquisition, distribution or disposal of explosives materials.
Type III Permit: A permit issued by the Division of Oil and Public Safety to corporations, companies, partnerships, firms, individuals operating a business, associations, or state or local government agencies for the storage of explosives in approved magazines.
There were several scenarios but the one that seemed to be the most popular with the larger businesses is:
Type I $75.00 for 3 years
Type II 1200.00 for 3 years
Type III 75.00 for 3 years
They also were looking at a fee per inspection but will have to see what they come up with. They also were trying to get information on inspections from the ATFE to possibly cut back on some of the field time, cutting back expenses and also possible lowering these fees but may take a couple of years.
Right now we are going to have to wait and see what they draft as
their proposed fee structure. They will send it to everyone that is
a current permit holder and to the people that have given their info to them today at the meeting. Once everyone has had a chance to review it, they can respond in writing. Once this is done there will be a formal hearing and even then changes will be able to be made if they deem necessary.
I really think that our course of action should be seeing if they will write in an exemption to rocketry, add a forth permit dealing with low explosives or transfer regulation to Division of Fire Safety.
I think that I am going to try to sit down with Scott Narreau and or his boss and see what if anything they can do or what they think we should do. Scott is an inspector but does feel that we should not be regulated by the state as well as the ATFE. His boss is retiring in a few days but the interim guy seemed to be interested in rocketry at one time in his life so my be very understanding and willing to discuss possible options.
Over all I do not think things went bad but I still think that we need to be vigilant and work with them to try to work things out. I am not sure that we all should rush out and get these permits but I also am not sure that we will have any relief form them any time soon. I also do not believe we are the highest on their list of priorities and people to go after. I think I will try to talk to them again this week and make my decision to get their permits or not. I would rather pay the 225.00 then the 1350.00 possible. It will also put me in a better position to help out as well if things do not change before we win the lawsuit with the ATFE or the state give us some relief with some kind of exemption.
Sorry to say we are in the same position as we were in before the meeting, still waiting to hear what they are wanting to do with the fees but at lest we now know were we are and know in what direction to start.
I hope that this clears thing up a little for some of the information that may have be going around.
JamesR
I'm still a little confused....
Type II Permit: A permit issued by the Division of Oil and Public Safety to corporations, companies, partnerships, firms, individuals operating a business, associations, or state or local government agencies involved in the use, purchase, sale, manufacture, transportation, acquisition, distribution or disposal of explosives materials.
What about individuals NOT operating a business? In fact, this section doesn't make much sense at all. it only specifies what entities the permit is issued to and under what circumstances. It doesn't say what the permit is for. I have heard many times that this is the transportation permit, but that is not at all clear from the above text.
it actually lets you use, buy, sell, manufacture and transport. The type one is user only, an employee if you will. They do not need to buy just use, the company will need to buy, sell and transport. The type 3 lets the company store.
they do not expect individuals to engage in the use of explosives only businesses. even the ATFE refers to businesses.
That "business" term looks like a loop hole to me. But, until they take us into consideration, we have to be careful how we present ourselves.
They made it clear that they are understaffed and are really just interested in the companies using the explosives. I got the impression that they would really rather not have to deal with us at all and would prefer the Division of Fire Safety do it.
the only one that refers to an individual is the type I the other 2 refer to businesses only. not sure that would be a good arguing point or not.
I will discuss that with Scott when I am able to talk to him.
JamesR
You know, that may be a way out for them, one could only hope.
Now, imagine Maxwell Smart saying this and I won't look so dumb - Ahhh yes, the old "Oh well, the law doesn't extend to you guys, have fun..." line. Would you believe that two men and a row boat came up with that one... 😛
I'm soooo bored at work today, putting in deposits gets old.
I am trying to get back into the hobby after being out for a while. I know that APCP has been de-listed from the BATFE orange book, but what net effect has this had on getting CO permits?
Also, what are the new rules for the CO permits based on 051-08? Is the loophole of "for individuals running a business" the way to proceed, or are we still subject to all three permits?
Any help is appreciated.
Sean