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User avatar
By Wonder Boy
#405243
18-1-2. CLASS E SURFACE AREAS http://tfmlearning.faa.gov/Publications ... r1801.html

a.  A Class E surface area is designated to provide controlled airspace for terminal operations where a control tower is not in operation.
Class E surface areas extend upward from the surface to a designated altitude (That is the definition from the FAA, not me saying it)

Why do you think that was written, especially stated first? It is a designated altitude of class E, not sure why some dismiss that fact.
If the lateral boundaries extended up to 17,999 thats what would be written.

"or to the adjacent or overlaying controlled airspace. Class E airspace surface areas must meet the criteria in paragraph 17-1-3 of this order."
This applies to the extensions.


So here is a question,
Bremerton airport, half of it is under Seattle's class B airspace. So with the logic the lateral boundaries extend up to the "overlying" airspace, that means it would terminate at the class B and I could fly over it at say 12,000 feet.
Kind of wrecks that logic doesn't it....
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Last edited by Wonder Boy on Sat Oct 06, 2018 2:32 pm, edited 1 time in total.
User avatar
By aeroexperiments
#405244
Re my last post above (replying to magentabluesky), historical flying within control zones, etc--

Plus there's always the possibility of a given FAA official or group of officials simply not understanding the regs. We've seen evidence of that elsewhere on this thread! Sometimes it works in our favor-- great!
Last edited by aeroexperiments on Sat Oct 06, 2018 2:46 pm, edited 1 time in total.
User avatar
By aeroexperiments
#405245
Wonder Boy wrote:
Sat Oct 06, 2018 2:03 pm

So here is a question,
Bremerton airport, half of it is under Seattle's class B airspace. So with the logic the lateral boundaries extend up to the "overlying" airspace, that means it would terminate at the class B and I could fly over it at say 12,000 feet.
Kind of wrecks that logic doesn't it....

No general aviation pilot would dispute that there is more Class E above the ceiling of the Class C. It's there for other reasons, not because it happens to be above a Class-E-to-surface area. You're talking as if we have different colors of air and we are trying to figure out when one color of air ends and the other color begins. But it's ALL the same color air. It's ALL Class E. There's no sense in trying to figure out where the Class-E-to-surface air ends and the other Class E air begins. It's all Class E. It's just that different rules apply when we are within the lateral boundaries of a dashed magenta line-- and specifically, a dashed magenta line that actually surrounds the particular airport whose approaches it protects. And "within the lateral boundaries" means "ANYWHERE over the piece of ground that is enclosed by that dashed magenta line". Sure, when we get into the Class C, more stringent rules apply, but NOT because we are no longer "within the lateral boundaries" of the dashed magenta line. We still are. But now we're in Class C airspace rather than class E, so we have to play by the Class C rules, which are more strict, even though we're still "within the lateral boundaries" of the Class-E-to-surface-- i.e. still physically over the piece of ground that is enclosed by the dashed magenta line.

Look, whatever argument that you try to come up with to claim that this position is absurd-- nothing is more absurd than saying that the rules relating to being within the lateral boundaries of a Class-E-to-surface area, end a mere 700 feet above the ground. No one who understands how air traffic works is going to go along with that.

Steve
User avatar
By Wonder Boy
#405246
Keep in mind, https://www.faa.gov/regulations_policie ... k_ch15.pdf

Class E Airspace
Class E airspace is the controlled airspace not classified as Class A, B, C, or D airspace. A large amount of the airspace over the United States is designated as Class E airspace.
This provides sufficient airspace for the safe control and separation of aircraft during IFR operations. Chapter 3 of the Aeronautical Information Manual (AIM) explains the various types of Class E airspace.
Sectional and other charts depict all locations of Class E airspace with bases below 14,500 feet MSL.
In areas where charts do not depict a class E base, class E begins at 14,500 feet MSL.
In most areas, the Class E airspace base is 1,200 feet AGL. In many other areas, the Class E airspace base is either the surface or 700 feet AGL.
Some Class E airspace begins at an MSL altitude depicted on the charts, instead of an AGL altitude.
Class E airspace typically extends up to, but not including,
18,000 feet MSL (the lower limit of Class A airspace). All
airspace above FL 600 is Class E airspace.


Class E extends down to 1200' & 700'.
The "surface area lateral boundaries" extend up to a designated altitude. (Not counting extensions) this would be 700'

"Surface area lateral boundaries" , that is a lateral boundary between class E and Class G at the surface.
Once above 700' there is no "lateral boundary", as it is all class E airspace.
You cant have a lateral boundary between class E and class E, there is no difference.
User avatar
By aeroexperiments
#405247
Wonder Boy wrote:
Sat Oct 06, 2018 2:50 pm

"Surface area lateral boundaries" , that is a lateral boundary between class E and Class G at the surface.
Once above 700' there is no "lateral boundary", as it is all class E airspace.
You cant have a lateral boundary between class E and class E, there is no difference.

I know what you are saying. To you, "within the lateral boundary" means as you are flying along, you could look out horizontally and see the boundary between E and G -- the innermost boundary, the one that goes all the way down to the surface. If you can't see that boundary, then you aren't "within the lateral boundary" of the airspace in question.

But that's not what is meant. It doesn't just say "within the lateral boundary of the airspace", it says "within the lateral boundary of the surface area of the airspace"-- or something close to that. The "lateral boundaries of the surface area of the airspace" are the dashed magenta lines on the surface, and being "within" those boundaries means being at ANY altitude whatsoever over the piece of ground around which those dashed lines are drawn, as long as they enclose the airport in question and are not mere "extensions".

The "surface area" doesn't mean the whole volume of airspace that goes from 700' down to the surface, it just means the surface footprint of that airspace. Being "within the lateral boundaries of the surface area" of the airspace just means you are somewhere over the surface footprint, at ANY altitude.

The above quotes are not necessarily all verbatim from the regs, I'm just trying to capture the general drift of it.

And yet, it IS true that in the FAA's "Airspace Designations And Reporting Points" (Order JO 7400.11C), we do find the very confusing phrase "Class E Airspace Areas Designated as a Surface Area" which honestly could be used to argue that the phrase "surface area" somehow does mean more than just a footprint. The simple truth is that we're looking at some utterly terrible writing here-- and a lot of inconsistency-- in the FAA's usage of language.

All this was an awful lot more clear back when the airspace was called a "control zone". When you go back and look at the original situation when FAR 103 was introduced, that's when your argument really falls apart.

Look, the language is NOT well written at all. I talk about this a lot (with plenty of verbatim quotes from the regs ad nauseum) in my stackexchange piece ( https://aviation.stackexchange.com/ques ... 5714#55714 ). And now I'm getting tired of arguing about a situation caused by someone else's (the FAA's) bureaucratic incompetence.

But there's no way you are going to get very far with this argument that the rules applying to Class-E-to-surface end a mere 700' above the ground. If someone in the FAA has told you that and you think you are fine to go with that in your particular area, fine, go with it. But the people in the FAA who would espouse that point of view are surely very far and few between.

Like I said before, try flying a drone at 701' over an airport surrounded by this sort of Class-E-to-Surface airspace, with no prior authorization, and just see what happens.

Steve
Last edited by aeroexperiments on Sat Oct 06, 2018 3:49 pm, edited 2 times in total.
User avatar
By Wonder Boy
#405249
Its not what it means to me, that's what it says. You keep saying what it means, Im saying what it says. (I just copy and past the definitions)
It does say it has an alt definition, lateral boundaries extend up to a designated alt, its all class E, the next designated alt from the surface for class E is 700, then 1200 and so on.

I found the old literature about control zones back from 1983.
Those did extended to 14,500, (not 17,999) it was explicitly written.

Many things have long since changed including the verbiage "control zone" and what is now surface area with its own definition and verbiage.
Perhaps if we all inquire with the FAA enough as the UAV guys did, they will come out with more guidance as they did about extensions.

Im not trying to convince anyone, you can think what you want.
Im just stating whats written.
User avatar
By aeroexperiments
#405250
Wonder Boy wrote:
Sat Oct 06, 2018 3:33 pm
Its not what it means to me, that's what it says. You keep saying what it means, Im saying what it says. (I just copy and past the definitions)

The truth is that what is written in the FAR's etc is a bunch of unclear and somewhat conflicting bureaucratic garbage. I edited my last post to say more since you've last seen it. But I don't believe your interpretation is the best one.

And now, once again, I'm signing off for the day.

Steve
User avatar
By magentabluesky
#405251
To get an understanding first ask: What is the purpose of Class E and Class E surface airspace?
This provides sufficient airspace for the safe control and separation of aircraft during IFR operations. (IFR - Instrument Flight Rules) Quote from Chapter 15 Airspace FAA Handbook. Pdf Link
The definition did not say Instrument Meteorological Conditions (IMC) but aircraft on operations under Instrument Flight Rules.

Next, what is the definition of Class E Surface Airspace?
1. Surface area designated for an airport: When designated as a surface area for an airport, the airspace will be configured to contain all instrument procedures. Aeronautical Information Manual 3- 2- 6 Class E Airspace. Link
Class E airspace extends upward from either the surface or a designated altitude to the overlying or adjacent controlled airspace. When designated as a surface area, the airspace will be configured to contain all instrument procedures. Pilot/Controller Glossary Pdf Link
Key here is the airspace will contain all instrument procedures.

Can we just digest those ideas for the moment?
User avatar
By aeroexperiments
#405252
(This was meant to be a supplement to my last post; was not a reply to magentabluesky)

Look at it this way, if I build a gigantic cubical frame a mile on each side, resting on the ground, and then I fly one mile over the very middle of the TOP of the cube, am I "within the lateral boundaries" of the cube? How would be being "within the lateral boundaries" be different from just being "within the boundaries" of the cube? I am I "within the lateral boundaries" of the "surface footprint" of the cube? Am I "within the lateral boundaries" of the "surface area" of the cube, if the context is such that it's clear that the "surface" we're talking about here is the ground surface? What if I write a regulation that declares the airspace above the bottom surface of the cube, continuing vertically upward with no definition up any upward limit, to be named a "surface area". Then if I fly one mile over the middle top of the cube, am I "within the lateral boundaries of the 'surface area'"?

The honest truth is that the language here is just about as confused as the language dealing with whether ultralights can fly through the "extensions", and I'm not saying there's absolutely no room for alternate interpretations in theory, but in actual practice it's just ludicrous to think that the rules pertaining to Class-E-to-surface airspace are meant to be no longer effect once an aircraft is 701' above the ground surface.

Now I really need to stop the dead-horse-beating--

*****************************************************************

Yes good post Michael (magentabluesky). I would only add the slight twist that as regards the IFR vs IMC thing, while it's good to recognize that IFR traffic might actually not be fully engaged in see-and-be-seen collision avoidance practices even when not in/near cloud (i.e. in IMC), they are legally obligated to be. And thus should not really need to be separated from VFR traffic. But I don't want to get off on another tangent right now--

Steve
User avatar
By aeroexperiments
#405253
Here's the real truth-- just as in the long run the FAA is never going to go along with the proposed interpretation that the meaning of "within the lateral boundaries of the surface area of Class E airspace designated for an airport" only extends up to 700 feet above the ground, so too the FAA is never going to go along with my argument (read full details here https://aviation.stackexchange.com/ques ... 5714#55714 ) that the meaning of "within the lateral boundaries of the surface area of Class E airspace designated for an airport" does not extend to "extension" areas that don't actually enclose the airport whose approaches they are designated to protect.

Why do I say that? Because Congress has recently passed a bill for the purposes of keeping drones and radio-controlled model airplanes out of the way of air traffic, motivated undoubtedly by the many sightings of drones being flown beyond line-of-sight by irresponsible hobbyists right in the middle of the approach paths for busy airports. Also clearly motivated by a desire to open up defined portions of the airspace for use by the expected explosion in growth of commercial drones. If I'm understanding it right, drones weighing under a certain weight limit (55 pounds), as well as conventional radio-controlled planes flown by hobbyists, are now called subjected to very onerous restrictions.

Here's one of the restrictions-- " In Class G airspace, the aircraft is flown from the surface to not more than 400 feet above ground level and complies with all airspace restrictions and prohibitions. "

That really sucks for r.c. sailplane enthusiasts like me-- 400' above the ground is NOTHING. Note however that the 400' restriction is ONLY for class G airspace.

Here's another one of the restrictions--

" In 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, the operator obtains prior authorization from the Administrator or designee before operating and complies with all airspace restrictions and prohibitions. "

There's that same language that we have in and FAR 103.17 and FAR 107.13 -- "within the lateral boundaries of the surface area of Class E airspace designated for an airport". No drone or r.c. plane operation in there without prior permission, just as is currently the case for ultralights.

If the interpretation of the meaning of "within the lateral boundaries of the surface area of Class E airspace designated for an airport" given by the January 10 2018 FAA Memorandum on FAR 107.13 ( http://goldsealgroundschool.com/uav-lib ... ations.pdf ) is upheld, that means any drone hobbyist can go fly their drone in the Class-E-to-surface EXTENSIONS, with no need for prior authorization and NO prescribed altitude limit.

The FAA will NEVER go for this. That's exactly the problem they are trying to prevent.

What do you think they will do about this? Options would include--

1) Rewrite the 400' rule so that it is not limited to Class G airspace

2) Rewrite the proposed regulations to explicitly include the Class-E-to-surface "extensions" as well as the airspace "within the lateral boundaries of the surface area of Class E airspace designated for an airport"

3) Issue a ruling that the meaning of "within the lateral boundaries of the surface area of Class E airspace designated for an airport" DOES encompass the Class-E-to-surface "extensions" to Class D or higher airspace-- thus over-ruling the Jan 10 2018 Memorandum to the contrary.

I bet you anything they'll go for #3. It's the simplest option, and the language and terminology involved is just vague enough to let them get away with it. Plus I think similar opinions have already been issued in the past by various FAA offices, specifically in regard to FAR 103.17 (ultralights). I don't have current links to any of those handy. From what I remember they seemed based on a lot of confusion and a lack of careful consideration of the exact language and history of the regs. But now that they have a specific memorandum to the contrary to over-rule, they'll be much more deliberate about it. Like I've been saying, I think such a ruling would NOT be in line with the original intent and best logical interpretation of the regulations. But, there's enough slop in the language to let them get away with it. They didn't do a good job of in the first place (or rather I should say at the time of the 1993 airspace re-organization) of harmonizing the exact language of FAR 103.17 and the exact language of "Airspace Designations And Reporting Points" (Order JO 7400.11C or whatever was its past incarnation at that time.) (See https://www.faa.gov/documentLibrary/med ... 00.11C.pdf .) And so now we're going to pay the price of that sloppiness. They'll find a way to interpret the language to get what they want.

So-- the long and short of it is-- this is probably NOT a good time to go ask the FAA for an interpretation in favor of the idea that the meaning of "within the lateral boundaries of the surface area of Class E airspace designated for an airport" only extends up to 700'. They'll never say yes, and the odds are very good that they'll also say something-- either without realizing the complexity of the various issues involved, or because they do explicitly realize they are about to have an issue re keeping drones from flying to high altitudes in the "extensions"-- that over-rules the January 10 2018 Memorandum and explicitly extends the meaning of "within the lateral boundaries of the surface area of Class E airspace designated for an airport" to the extensions.

I'm not versed with legal issues well enough to know whether the January 10 2018 "Memorandum" carries any legal weight anyway. If you were "caught" flying a hang glider or other ultralight-- or even a drone-- in one of those Class-E-to-surface extensions, would it really help you to cite that "Memorandum"? Or is that more just something that pertains to internal FAA business and is not meant to be a legal ruling or guidance to the public?

Anyway, that's how I see it. The conflict between the January 10 2018 Memorandum and the desired intent of the new proposed regulations on UAS's (Unmanned Aircraft Systems) is going to force the FAA's hand to clarify the meaning of "within the lateral boundaries of the surface area of Class E airspace designated for an airport", and it's probably not going to come out in our favor.

Sooner or later we are all going to need to fly with transponders anyway.

Steve
User avatar
By Wonder Boy
#405254
Lets move past the Surface area extensions and UAV /RC now. Its not helping the discussion. The point of brining it up was what the FAA defined as "for an airport"

The reason permission is not required for surface extensions: they are far away from the airport. You only have extensions to B, C and D airspace. (why would you be so slow that far out?)
You "should" be flying a UAV at 400' or less and an airplane should be at 500' or more.

91.119 Minimum safe altitudes; general An aircraft must maintain an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

Anyway, that's why that is.


UAV rules
https://www.ecfr.gov/cgi-bin/text-idx?S ... .2.107_123
https://www.faa.gov/uas/media/RIN_2120- ... Signed.pdf
User avatar
By aeroexperiments
#405255
Wonder Boy wrote:
Sun Oct 07, 2018 12:41 pm

The reason permission is not required for surface extensions: they are far away from the airport. You only have extensions to B, C and D airspace. (why would you be so slow that far out?)
You "should" be flying a UAV at 400' or less and an airplane should be at 500' or more.

Ok, so you are saying that in a typical "extension", an airplane should be at 500' or more.

Yet the FAA defines the upper altitude limits of those "extensions" with EXACTLY the same language as they define the upper altitude limits of the type of Class-E-to-Surface airspace that is "designated as Surface Area" and completely surrounds the airport whose approaches it protects. Such as Newport Oregon (http://vfrmap.com/?type=vfrc&lat=44.580 ... 58&zoom=10), or such as what happens over the middle of the Salem Oregon airport when the tower closes for the evening and the Class D reverts to Class-E-to-surface ( http://vfrmap.com/?type=vfrc&lat=44.910 ... 02&zoom=10 ).

So if the upper limits of those Class-E-to-surface areas around airports is 700', then so is the upper limit in the "extensions". Where you are saying aircraft should be above 500' at a minimum. Yet you are also saying if they get above 700', the regulations applying to Class-E-to-surface (for example the ability to request permission to operate under "Special VFR") suddenly no longer exist.

How does that make sense?

Steve
User avatar
By aeroexperiments
#405256
NEVER MIND, disregard the above post. (I'm no longer allowed to edit or delete it.) The "extensions" are a weird breed of cat. It appears to me that if we go by the letter of the law, they really have no effect on anything once we get above the level of the floor of the surrounding Class E airspace. Here's why I say that--

I don't know how to link directly to a given answer. How did you do that Magentabluesky? (This might work https://aviation.stackexchange.com/ques ... ve#tab-top ). Anyway look for the answer that starts with the phrase "Class-E-to-surface 'extensions' are not 'within the lateral boundaries of controlled airspace designated to the surface for an airport' "

or just try https://aviation.stackexchange.com/ques ... extensions

Professional pilots may chime in here to tell me I'm all wrong but that's how I see it. According the "comments" under the other answer, at least one flight instructor did as well.


Steve
Last edited by aeroexperiments on Sun Oct 07, 2018 2:58 pm, edited 4 times in total.
User avatar
By Wonder Boy
#405257
No. I pointed out the UAV rules requires you to fly no higher than 400', and a GA plane "should" be higher than 500' (just in general regardless of where you are) regarding http://www.uavexpertnews.com/wp-content ... ardner.png
I was commenting to your post about viewtopic.php?p=405253#p405253
I said the reason the FAA had no issue with UAV being with the lateral boundaries of an extension was viewtopic.php?p=405254#p405254

Nothing to do with 700'.
User avatar
By magentabluesky
#405258
Steve,

I think you have a good handle on the subject of Class E Surface Airspace.
aeroexperiments wrote:
Sun Oct 07, 2018 10:50 am
Sooner or later we are all going to need to fly with transponders anyway.
. . . .
Agreed, we should be working on integrated transponders with our flight instruments which are affordable. Keep it simple.

As I have been saying: appreciate the freedom we now have with Part 103. Be safe and stay clear of conflicts with other airspace users. Work within the community on safe practices.

Save Part 103.
#405273
Doesn't this reg kind of imply that meaning of "within the lateral boundaries of the surface areas of Class E airspace designated for an airport" extends above 700' AGL? If this phrase only refers to airspace below 700' AGL, it would be perfectly legal for an unmanned balloon to be at 701' in this area with no prior authorization, despite the reg, and there would be no reason to include any reference to Class E airspace of any kind in the reg.

https://www.ecfr.gov/cgi-bin/text-idx?S ... 3&rgn=div8

§101.33 Operating limitations.
No person may operate an unmanned free balloon—

(a) Unless otherwise authorized by ATC, below 2,000 feet above the surface within the lateral boundaries of the surface areas of Class B, Class C, Class D, or Class E airspace designated for an airport

I still say it's really pretty clear what is intended in regards to altitude limits even if the language is kind of sloppy. Again see https://aviation.stackexchange.com/ques ... 5714#55714

Scroll down to the heading "Is there an altitude limit to the concept of "within the lateral boundaries of the surface area of Class E airspace designated for an airport"?
Last edited by aeroexperiments on Tue Oct 09, 2018 6:19 pm, edited 2 times in total.
User avatar
By Wonder Boy
#405274
Sure if this wasnt he case

18-1-2. CLASS E SURFACE AREAS http://tfmlearning.faa.gov/Publications ... r1801.html

a.  A Class E surface area is designated to provide controlled airspace for terminal operations where a control tower is not in operation.
Class E surface areas extend upward from the surface to a designated altitude

If you dont consider the shaded magenta area of class E in the area that is designated class E 700' as a designated altitude of class E then there you go.
No need to respond. I know your answer.
User avatar
By magentabluesky
#405278
Sure if this wasn’t the case:
1. Surface area designated for an airport: When designated as a surface area for an airport, the airspace will be configured to contain all instrument procedures. Aeronautical Information Manual 3- 2- 6 Class E Airspace.

. . . .
The same definition is under the Pilot/Controller Glossary.

I have never seen an approach where the Initial Approach Fix was at or below 700ft. or for that matter even at or below 1200ft.

How does that fit with your definition, Mike?

Unless there is some other airspace above the Class E Surface, the Class E Surface goes up to the Class A airspace – 17,999ft. We (ultralights) need permission to cross the lateral boundaries into the Class E Surface Airspace.

It really is not that big of a deal to ask ATC for permission. Skydivers do it all the time. Jump schools are based at airports with Class E Surface Airspace. They notify ATC that they will be jumping and give progress reports when the jump plane is in the air, when the jumpers are away, and when the jumpers are on the ground. The airspace users are on notice. Everyone gets along.

Winslow (KINW) is a great example. According to AirNav there are eight aircraft based at the airport. There is on average sixty-six aircraft operations per day. If you figure there are not as many aircraft operations at night, there is maybe six aircraft using the airport per hour, one every ten to fifteen minutes. If you ask Albuquerque Center for clearance to fly through the Class E Surface Airspace associated with Winslow Airport, they will approve your request unless there is some major operation going on.

It is the same for Bishop Airport (KBIH). Bishop has a few more aircraft based there at thirty-four with an average of seventy-one aircraft operations per day. If your hang gliding group is going to land at laws, have the driver call Oakland Center and request clearance into the Class E Surface Airspace with a landing two miles Northeast of the airport. If you have an aviation band radio, talk to Oakland Center directly.

It is a much better to let everyone know you are there and following the rules than to be sneaking around and then have something bad happen. It really is not that hard to be legal and safe.

Be on the up and up.
User avatar
By Wonder Boy
#405279
No one said they weren't asking for permission.
---

How that fits in, it says that the lateral boundaries cease to exist past 700 feet.
Yes it's all Class E airspace.
The surface area lateral boundaries we cannot be within.
The same way 700 to 1200 lateral boundaries only exist to 1200 feet, the surface lateral boundaries only exist up to 700 feet.
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