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

[martymayes]

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

Stalemate-

The AIM says: "Surface area arrival extensions become part of the surface area and are in effect during the same times as the surface area" (AIM 3-2-6)

My position is the same as before, extensions are part of the surface area designated for an airport.

Thereby, the ultralight vehicle operating within the lateral boundaries of the extension is by definition operating within the lateral boundaries of the surface area designated for the airport and needs to have prior authorization to go there. (103.17)