Is there a mechanism to bring to the attention of the FAA a potentially inaccurate, ambiguous, or misleading statement in the AIM, such as section 3-2-6?
"Surface area arrival extensions become part of the surface area and are in effect during the same times as the surface area."
Steve
Last edited by quietflyer; 04-30-2019 at 09:21 AM.
The floor of the class E "extensions" should logically be higher than the surface. Perhaps 400agl or something for drones and ultralights to operate without prior permission.
Because IFR traffic is always higher in the extensions (just like the class B inverted wedding cakes)
The rules for class E airspace are so poorly defined in AIM or the chart or anywhere, it's appalling.
Though may not be obvious at first sight, the floor of the Class E "extensions" is definitely the surface. Look at any of the E3 and E4 airspace descriptions in FAA Order JO 7400 -- https://www.faa.gov/documentLibrary/...O_7400.11C.pdfOriginally Posted by Bill Berson
I know, it's a can of worms. If you want to read about another possible can of worms re model airplane flight, see a related discussion here. However, I need to emphasize, the apparent problem here is in the words of the authorizing congressional legislation-- not the FARs. The actual FARs have not yet been codified, or at least have not yet been released to the public. -- https://www.rcgroups.com/forums/show...er-E4-airspace
Steve
Yes, there is. There is a Comments/Corrections page in the front of the AIM right after the subscription information page. And you will absolutely receive a reply to your comment(s), no black holes there.
Of course, it would be prudent to ensure the AIM is indeed inaccurate, ambiguous or misleading before making such a suggestion......
Well, they have areas like that, called "Class E transition areas," except they don't use 400'. Where the floor of Class E touches the surface, the powers in charge decided they needed to vertically protect aircraft that are operating in that airspace and that protection extended to the surface.
Thanks for the note re the AIM- and what is the mechanism for acting the FAA Chief Counsel for an opinion or interpretation? Just write a letter?
I have heard FAA officials make incorrect statements (sometimes in writing) many times over my 40 yrs in aviation.
Sometimes people prefer to let sleeping dogs lie.Perhaps I ought to do that. Honestly I'm surprised that one of the national ultralight or hang gliding/ paragliding organizations hasn't done so already, but if so it's never been referenced in any of the on-line discussions I've had on the subject.
I think most sanctioned record attempts obtain the proper waivers, etc.One would think it would be of particular interest re soaring pilots setting FAI records-- I don't think the records are valid if you violate airspace limitations.
Write a clear and concise, make simple declarative sentences, avoid pedantic -- oh sheesh I sound like my old english teacher....
https://www.faa.gov/about/office_org...tion/contacts/
A quicker mechanism would be to write to your regional counsel and ask for an "interpretive ruling" it carries less weight than a chief counsel opinion but it might shine light on the overall subject. Getting a response from the Chief Counsels office may take months.
The historical description of the control zones is WRONG. By the way. Control zones were very much depicted prior to 1992 as either dashed blue lines or dashed T lines (when no SVFR was allowed).
The control zones had the "extensions" prior to 1992 as well and were depicted they just weren't called anything specific.
What was true before 1992 was that the Airport Traffic Area that was created by having an operating control tower wasn't either charted nor was it by default controlled airspace. If they wanted controlled airspace in the ATA they also created a control zone. When these ATAs were subsumed into the class D controlled airspace, now you had an issue. What to do with the stuff sticking out of the circular central area. This is where the idea of "extensions" came about. If the extensions were small, they just became part of the class D. If they were larger, they became class E extensions to the class D.
Frankly, I think this is much ado about nothing. The scope and size of a control zone is no different than the current class D or class E surface areas.
By the way, the FAA when they proposed all this change, promised the uncharted zombie airspace of the naked ATA would go away. They lied. Within a few months after the regs became effective, they restored the rules for operations in vicinity of control towers in class G or E airspace.
Me too. I know a hang glider pilot who was told by an official at the local FSDO that the class-E-to-surface areas could be ignored in relation to part 103 whenever the weather at the airport was above VFR minimums. Later he was told by a different FSDO official that the ceiling of an E4 "extension" was considered to be 700' AGL. Supposedly he was also later told in writing by the Office of Chief Counsel that the ceiling of an E4 extension was considered to be the height of the adjacent Class D cylinder. And that "This is written in the rules & definitions and no further written correspondence will be offered". All a bunch of garbage.
Partly because of the risk of simply getting a confused or inaccurate answer. Especially considering that the FAA's interpretation of the significance of the E4 extensions re SVFR and drone flight appears to also suggest a favorable interpretation re FAR 103-- so why rock the boat and risk getting a different interpretation in writing? Still, it would be nice to get it pinned down.
Steve
Last edited by quietflyer; 04-30-2019 at 11:53 AM.
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