Why would nitro-cellulose not be considered a substitute? Why do you think that a black powder substitute should be based on volume?
How about if we added a smoke addative to it like T7 and put the "Black Powder Substitute for Savage Muzzleloaders ONLY" on the label?(Savage really should do this)
I understand that most of the wording came out before the new smokless powder muzzleoaders. The reason it was worded that way is so people would not put nitro-cellulose based smokeless powder(i.e. normal shotgun or rifle reloading powder) into a muzzleloader because it could be very dangerous, especially is loaded on par with the same volume as common BP loads.
I'm sure the wording was in there for the "safety" factor, but now we can certainly say that a nitro-cellulose smokelss powder can be considered a safe black powder substitute for the Savage ML10.
The thing is. No one is certain. And it seems no body thus far can site any specific langauge or govenrmental document(I have been looking) reffering to the definition of a black powder susbstitute. The wording in the Michigan muzzleoading regulation can most certainly mean that a nitro-cellulose based smokelss powder is legal to use in the Savage ML10 simply because it is a reccomended black powder susbtitute for that specific gun.
Another good reference.
black powder substitute - wiki with some good resource links.