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Thread: Let's discuss-- Part 103.17-- ultralight flight in Class-E-to-surface "extensions"

  1. #11
    FlyingRon's Avatar
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    Quote Originally Posted by Bill Berson View Post
    I think you can get some ATC guidance from Advisory Circular 103.6 (AC 103.6) https://www.faa.gov/regulations_poli...cumentID/22639

    Unfortunately, AC 103.6 appears so far out of date and was created before class E airspace was invented.
    You would need more current advice.
    Surface area of class E airspace designated for an airport existed, it just went by a much simpler name: "Control Zone"

    I agree with Marty. Surface Area of class E airspace designated for an airport includes the class E extensions to class D airspace.

  2. #12
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    Quote Originally Posted by Bill Berson View Post
    There are some well trained pilots with pilot certificates that fly ultralights. Of course Part 103 doesn't spell out the details of how a trained or untrained 103 pilot would get "prior authorization", but it does suggest that authorization may be granted. So the details of the particular "permit" that ATC might issue would take into account the training, Certificates, etc, of the permittee, I suppose.
    That's a lot of supposing....
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  3. #13

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    Feel free to provide pertinent facts, it's been six days since the question was posed here.
    I can also say the FAA does issue Notams as a form or "prior authorization". In the case of Airventure a Notam is issued for ultralight operations and requires pilots attend a morning class or review for procedures.
    I "suppose" ATC may have issued prior authorization in a continuous Notam for the ultralight runway that was at Port Angeles International airport. I don't know if the ultralight runway is still there, since ultralights hardly exist anywhere now.

    I just read in the AMA journal that FAA may require model aircraft pilots pass an aeronautical knowledge and safety test.
    Last edited by Bill Berson; 11-05-2018 at 09:45 AM.

  4. #14
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    Some years back a group of us were flying powered paragliders from a sod farm within a class D area, about 3 miles south of the airport. We got our "prior authorization" with a phone call to the tower before taking off; one call for all of us for the afternoon. The agreement was that we would stay 3 miles south of the airport and below 300' until clear of the class D.

    Unfortunately some moron in a powered parachute (not one of our group and without calling the tower) wrecked it by repeatedly buzzing the town about a mile and a half from the airport. After that, no more permission even though we told them it wasn't one of us. Pity, it was a great spot to fly.


    (cameras weren't as good back then)

  5. #15

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    I went on a long road trip shortly before the first reply to my original post came it seems, didn't realize anyone had replied. Sorry to get back to the topic so late (months later)-- more in a sec here. S
    Last edited by quietflyer; 04-29-2019 at 11:55 AM.

  6. #16

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    Quote Originally Posted by martymayes View Post
    Quote Originally Posted by quietflyer View Post
    The underlying thrust of this post is that the airspace in the Class-E-to-surface "extensions"-- the airspace within the bits of Class-E-to-surface airspace that do NOT enclose the airport whose approaches they protect-- does NOT fall within the definition of airspace "within the lateral boundaries of the surface area of Class E airspace designated for an airport".



    That is not correct.
    Actually I believe it is correct. More in a moment. S
    Last edited by quietflyer; 04-29-2019 at 11:55 AM.

  7. #17

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    Meaning of surface area designated for an airport

    Quote Originally Posted by martymayes View Post
    Those Class E surface area extensions you claim "do NOT enclose the airport whose approaches they protect--" do in fact depict lateral boundaries of the surface area of Class E airspace designated for an airport. This can be confirmed by looking at the airspace description for these airports in subpart E of FAA Order 7400.11C (incorporated by reference, see 71.1.
    No, in subpart E of FAA order 7400.11C, the extensions that do NOT enclose the airport whose approaches they protect are described as (E3) "6003. Class E Airspace Areas Designated as an Extension.The Class E airspace areas listed below consist of airspace extending upward from the surface designated as an extension to a Class C surface area." and (E4) a. The Class E airspace areas listed below consist of airspace extending upward from the surface and designated as an extension to a Class B surface area.

    In contrast to the dashed magenta lines that DO enclose the airports whose approaches they protect (E2): "6002. Class E Airspace Areas Designated as Surface Areas.The Class E airspace areas listed below are designated as a surface area for an airport."

    S
    Last edited by quietflyer; 04-29-2019 at 03:20 PM.

  8. #18

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    Yuma AZ

    See http://vfrmap.com/?type=vfrc&lat=32....14.606&zoom=10

    Quote Originally Posted by martymayes View Post
    At any rate, I'll bet a box of donuts the surface area extensions are included in the airspace designated for the airport.
    OK, I'll be waiting for that box of donuts.

    Quote Originally Posted by martymayes View Post
    The example I used, Yuma, AZ is on page E-129 and E-130 but it only describes the last modification to the airspace which appears to be a "carve out" over Somerton Airport from the surface up to 300 ft above the surface. That would allow those guys a means to access their airport without penetrating the Class E. (As written an ultralight could fly to/from the Somerton Private Airport without prior authorization from ATC by utilizing the carve out. Interesting).

    Anyway, that means have to go back to an earlier version of FAA Order 7400 (or Federal Register) and find the complete legal description of the Yuma AZ Class D/E airspace (or just go to the facility and ask for the same).
    No, you don't have to go back to an older version of FAA Order 7400. You just didn't look in the right part of the document. All the airspace is described in the latest version of the document. Actually you proved my point exactly-- you WON"T find the E4 "extensions" described in the same part of the document that describes "Class E Airspace Areas Designated as Surface Areas" or "designated as a surface area for an airport." Because that's not what the E4 extensions are considered to be.

    What do we find when we take a careful look at FAA Order JO_7400.11C ? ( https://www.faa.gov/documentLibrary/...O_7400.11C.pdf )

    Below page E-156-- heading "6004. Class E Airspace Areas Designated as an Extension to a Class D or Class E Surface Area.

    We find page on E-211--

    AWP AZ E4 Yuma, AZ Yuma MCAS-Yuma International Airport, AZ (lat. 3239'24"N., long. 11436'22"W.) Bard VORTAC (lat. 3246'05"N., long. 11436'10"W.) That airspace extending upward from the surface within 1.8 miles either side of the Bard VORTAC 181 radial extending from the Bard VORTAC to the 5.2 mile radius of the Yuma MCAS-Yuma International Airport and within that airspace bounded by a line beginning at lat. 3244'05"N, long. 11433'41"W; to lat. 3250'00"N, long. 11431'00"W; to lat. 3249'00"N, long. 11427'00"W; to lat. 3240'15"N, long. 11430'17"W, thence counterclockwise via the 5.2- mile radius of the Yuma MCAS-International Airport, to the point of beginning. AMENDMENTS 04/23/98 63 FR 7058 (Revised)

    Those are the E-4 extensions at Yuma. They are NOT listed as part of the class-E-to-surface airspace "Designated for an airport".

    What Class-E-to-surface IS "designated for an airport" at Yuma? Read on to find out.

    Below page D-1-- heading "Subpart D - Class D Airspace 5000. General. The Class D airspace areas listed below consist of specified airspace within which all aircraft operators are subject to operating rules and equipment requirements of Part 91 of the Federal Aviation Regulations (see 14 CFR 91.129). Each Class D airspace area designated for an airport in this subpart contains at least one primary airport around which the airspace is designated."

    We find on page D-141--
    "AWP AZ D Yuma, AZ Yuma MCAS-Yuma International Airport, AZ (lat. 3239'24''N., long. 11436'22''W.) Somerton, Somerton Airport, AZ (lat. 3236'03''N., long. 11439'57''W.) That airspace extending upward from the surface to and including 2,700 feet MSL within a 5.2- mile radius of Yuma MCAS-Yuma International Airport, excluding that airspace from the surface up to and including 300 feet above the surface from lat. 3236'52'' N., long. 11441'44'' W.; thence east to lat. 3236'52'' N., long. 11439'30'' W.; thence south to lat. 3234'55'' N., long. 11439'30'' W.; thence clockwise along the 5.2-mile radius to the point of beginning. This Class D airspace area is effective during the specific dates and times established in advance by a Notice to Airmen. The effective date and time will thereafter be continuously published in the Airport/Facility Directory. AMENDMENTS 09/23/10 75 FR 39146 (Modified)"

    That's the Class D airspace for Yuma.

    Since the Yuma tower is not open 24 hours, that Class D reverts to Class E at times. Therefore we also find the dashed inner circle described again here-- this is the Class-E-to-surface that is "Designated for an airport" at Yuma--

    Under page E-1, heading "6002. Class E Airspace Areas Designated as Surface Areas. The Class E airspace areas listed below are designated as a surface area for an airport."

    We find the following on p. E-129-130 --

    "AWP AZ E2 Yuma, AZ Yuma MCAS-Yuma International Airport, AZ (lat. 3239'24''N., long. 11436'22''W.) Somerton, Somerton Airport, AZ (lat. 3236'03''N., long. 11439'57''W.) That airspace, within a 5.2-mile radius of Yuma MCAS/Yuma International Airport, excluding that airspace from the surface up to and including 300 feet above the surface from lat. 9/15/18 JO 7400.11C E-130 3236'52''N., long. 11441'44''W.; thence east to lat. 3236'52''N., long. 11439'30''W.; thence south to lat. 3234'55''N., long. 11439'30''W.; thence clockwise along the 5.2-mile radius to the point of beginning. The Class E airspace area is effective during the specific dates and times established in advance by a Notice to Airmen. The effective date and time will thereafter be continuously published in the Airport/Facility Directory. AMENDMENTS 09/23/10 75 FR 39146 (Modified)"

    This is the same airspace that was described in the Class D section-- it is the dashed inner circle. It is shown as blue on the chart, but it effectively reverts to magenta when the tower is closed. The Class D airspace reverts to E2 airspace when the tower is closed. This is the only Class-E-to-surface airspace that is defined as "designated for an airport" at Yuma AZ. Not the E4 extensions.

    As an aside, note that when it is Class D it has an altitude ceiling, but when it is E2 no altitude ceiling is given. Class E airspace never has an altitude ceiling, other than the ceiling imposed by an overlying higher class of airspace (such as the overlying Class A in this case.)
    Last edited by quietflyer; 04-29-2019 at 06:39 PM.

  9. #19

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    Surface Area versus extension

    Quote Originally Posted by martymayes View Post
    The only reason to have a surface area would be in conjunction with an airport; it would make no sense to have a random block of Class E surface area out in the middle of nowhere.
    This statement is true in the general sense, but it is not true in the bureaucratic or legalistic sense. The fact is that in FAA Order JO 7400.11C ( https://www.faa.gov/documentLibrary/...O_7400.11C.pdf ), the E2 airspace is named or designated as being "Designated as a Surface Area" and "designated as a surface area for an airport", while the E3 and E4 airspace is not. The E3 and E4 airspace is named as "designated as an extension." That's the whole essence of my argument. S
    Last edited by quietflyer; 04-30-2019 at 06:09 AM.

  10. #20

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    about those control zones--

    Quote Originally Posted by FlyingRon View Post
    Quote Originally Posted by Bill Berson View Post
    I think you can get some ATC guidance from Advisory Circular 103.6 (AC 103.6)https://www.faa.gov/regulations_poli...cumentID/22639

    Unfortunately, AC 103.6 appears so far out of date and was created before class E airspace was invented.

    You would need more current advice
    Surface area of class E airspace designated for an airport existed, it just went by a much simpler name: "Control Zone"

    I agree with Marty. Surface Area of class E airspace designated for an airport includes the class E extensions to class D airspace.
    Well, I'm afraid I don't agree with Marty.

    But you are raising an interesting point here.

    What is the history of how "control zones" turned into Class E "surface areas"?

    "Control Zones" first appeared on charts in the mid-1940's (or at least by 1950) and often consisted of a thin dashed circle enclosing an airport-- originally red, later (by 1969) blue. Sometimes there were rectangular projections to enclose instrument approaches, giving a "keyhole" appearance, or other irregular shapes. By the time of this 1974 test-prep publication, control zones had been defined to go up to the overlying "Continental Control Area" at 14,500' MSL. At that time, most (but not all) towered airports had Control Zones around them, and some non-towered airports did too. By that time, special requirements in effect within a Control Zone included 3 miles visibility and a ceiling of at least 1000', unless a pilot was granted permission to fly under "special VFR" rules. Also by that time, an "Airport Traffic" area was a different thing from a "Control Zone", requiring radio communication with the tower for entry, with a standardized circular shape, a smaller standardized diameter and a much smaller, standardized vertical height. "Airport Traffic Areas" were not even depicted on sectional charts, because they were automatically present at all towered airports, and they were standardized in shape, diameter and height. Even though Airport Traffic Areas weren't depicted on sectional charts, they were referenced on the chart legend through at least mid 1983 in the language concerning towered airports, but by sometime in late 1988 that reference had been dropped.

    Now, on to ultralights-- FAR 103 was adopted July 30 1982.

    Originally, FAR 103.17 said that "No person may operate an ultralight vehicle within an airport traffic area, control zone, airport radar service area, terminal control area, or positive control area unless that person has prior authorization from the air traffic control facility having jurisdiction over that airspace".

    Not until mid-to-late 1992 do we see dashed magenta lines (as opposed to magenta shading) appear on sectional charts. Originally, the chart legend for the dashed magenta line read as follows: "Control Zone at airport without control tower and Control Zone extension without communications requirement". The charts now contained dashed magenta lines that encircled the airports whose instrument approaches they protected-- this would be a "Control Zone at airport without control tower"-- as well as dashed magenta extensions abutting dashed blue lines encircling airports, or abutting higher classes of airspace such as TRSA's-- these would be "control zone extensions" and not actually "control zones". Presumably the "without communications requirement" applied in both cases. So now for the first time we have two different kinds of airspace enclosed by dashed magenta lines. We also still have control zones depicted by dashed blue lines-- by this time, those control zones did have a communications requirement, since one of their functions was to fill the role of the old "Airport Traffic Area". At the same time that the control zones (and control zone extensions) depicted by dashed magenta lines appeared on the chart, the charts started showing a designated, individualized ceiling for each control zone depicted by a dashed blue line, typically around 2500 AGL. This was a step toward the evolution of the current "Class D" airspace. No specific ceiling was shown on the chart for the control zones depicted by a dashed magenta line or for the control zone extensions depicted by a dashed magenta line-- these airspaces had no upper limit other than floor of a higher class of airspace somewhere above.

    KEY POINT ----> Even after "control zone extensions" appeared on the sectional charts by mid-to-late 1992, FAR 103.17 never was modified to prohibit ultralights from entering "control zone extensions" without prior authorization from ATC.

    In late 1993 the nation's airspace went through a substantial change in nomenclature, along with some changes in structure-- this when the current system of Classes A, B, C, D, and E came into use. By November 1993, all reference to "control zones" and "control zone extensions" vanished from the sectional charts. Now the chart legend simply said "Class D airspace" for the dashed blue lines and "Class E airspace" for the dashed magenta lines. The latter isn't terribly descriptive, given the abundance of Class E airspace-- the pilot was simply expected to understand that this was specifically a reference to the nature of the airspace right at the very surface of the earth.

    This was also when the FAA's "Airspace Designations And Reporting Points" document, was revised to delete all references to control zones. According to the January 1 1993 CFR 14 17.1, the November 2 1992 version of this document (FAA Order 7400.7A) references "jet airways, area high routes, Federal airways, control areas, control area extensions, area low routes, control zones, transition areas, terminal control areas, airport radar service areas, positive control areas, reporting points, and other controlled airspace". According to the January 1 1994 CFR 14 17.1, the June 17 1993 version of this document (FAA Order 7400.9A) simply references "Class A, Class B, Class C, Class D, and Class E airspace areas and ..all reporting points".

    This is when we get the awkward terminology in the headings of the Airspace Designations And Reporting Points document. The heading of the section describing the type of Class-E-to-surface airspaces that surround the airports they protect (i.e. E2 airspaces) is "Class E Airspace Areas Designated as a Surface Area". Wouldn't they have done better to title this section something like "Class-E-to-surface airspace areas designated for an airport"? The term "Surface Area" is inherently somewhat confusing, since the Class-E-to-surface "extensions" also go all the way down to the surface. As we've already noted though, the descriptive text following the titles clears things up-- the heading "Class E Airspace Areas Designated as a Surface Area" is followed by the descriptive sentence _"The Class E airspace areas listed below are designated as a surface area for an airport". We don't find this language attached to the headings for the Class-E-to-surface "extensions" (i.e. the E3 and E4 airspaces) For example,the E4 Class-E-to-surface "extensions" are described as "Class E Airspace Areas Designated as an Extension to a Class D or Class E Surface Area" ".

    Around the same time-- specifically on September 16, 1993-- the text of FAR 103.17 was changed to include the current "No person may operate an ultralight vehicle within Class A, Class B, Class C, or Class D airspace or within the lateral boundaries of the surface area of Class E airspace designated for an airport unless that person has prior authorization from the ATC facility having jurisdiction over that airspace."

    Given the context of all of the above, there's no reason to think the phrase "within the lateral boundaries of the surface area of Class E airspace designated for an airport" was intended to included the Class-E-to-surface "extensions" -- i.e. the E3 and E4 airspaces. Nowhere in the "Airspace Designations And Reporting Points" document do we see the E3 or E4 extensions referred to as a "Surface Area", or as "designated for an airport", or as "surface area of Class E airspace designated for an airport".

    See the next post for more on this.

    S
    Last edited by quietflyer; 04-30-2019 at 05:58 PM.

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