Authorization Class E surface vs. Class E 700 AGL

[Woodsong]

See attached screenshot of one of the sectional charts, specifically the one showing Florence Regional (FLO). I've never been there but it's a good one to discuss as it has multiple classes of air around FLO...Class D, Class E surface, and Class E 700 AGL.
I marked 3 different points on the chart, #1, #2, and #3.

#1 is within Class E going to the surface of the earth.
#2 is below Class E that has a floor of 700' AGL so flying at approved UAV level under 400', the UAV would technically be underneath the Class E of 700' AGL.
#3 is within the Class D airspace that goes to surface to 2,600 AGL.

Thus, to comply with Part 107 airspace authorization requirements, a Commercial UAV PIC would need to do the following:
Location #1: Authorization required to fly due to being in surface level Class E.
Location #2: Authorization REQUIRED due to being within LATERAL LIMITS of ANY Class E association with an airport.
Location #3: Authorization required due to being within surface level Class D.

So here is my question....is my comment related to Location #2 correct? Technically a UAV flying below 400' would be underneath the area of Class E space here since Class E does not start until 700' AGL so really if one is flying below 400' here they would be flying in Class G airspace. That would cause one to think authorization is NOT required b/c you are below the Class E @ 700' AGL.

But then if you read FAA Advisory Circular 107-2 we find the FAA says the following:
Operation Near Airports; in Certain Airspace; in Prohibited or Restricted Areas; or in the Proximity of Certain Areas Designated by a Notice to Airmen (NOTAM). Though many sUAS operations will occur in uncontrolled airspace, there are some that may need to operate in controlled airspace. Operations 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, are not allowed unless that person has prior authorization from air traffic control (ATC).

But then other FAA publications simply say that you must have authorization to enter class C, D, or E airspace with no mention of Class E lateral boundaries.

Soooo...how does one read this FAA language correctly? Common sense would indicate that one could fly underneath Class E that starts @ 700' and do so without authorization b/c they are technically not entering Class E airspace unless one defines it by lateral boundaries instead of elevation. But the FAA specifically calls out the lateral boundaries of the surface area of Class E designated for an airport. Only Class E airspace mentions lateral boundaries, yet we have many examples of Class B and C, etc. that do not extend to the surface yet no lateral boundaries are referenced for those air classes.....

This is one area distinction that has not really been addressed adequately in all the free materials or sites I have extensively reviewed, including the FAA's own materials. When I see the phrase "lateral boundaries" I think Ok, Location #2 at 400' is below the Class E but if you ignore elevation AGL, Location #2 is obviously within the lateral boundaries though elevationally below the 700' AGL if the UAV stays below 400'.

This question takes on further importance due to the high number of small airports that are not Class C or D and a are simple, untowered facility with the only controlled airspace being Class E airspace with a floor of 700' AGL such as at TZV located at Tompkinsville, KY as shown in the second attached screenshot for TZV.

I have no issue understanding what the sectional charts are telling me related to the airspace class but the FAA's use of the phrase lateral boundaries muddies the waters for me. To make it more fun the apps I use (such as Hover and Airmap) show these small untowered facilities with no surface Class E and only Class E with floor of 700' AGL as not requiring authorization.

Sorry for the book I just wrote but really, I feel like the FAA language is unclear to me.

 

[Pharm]

Bump. Sorry I can't help. I haven't learned to read these yet.

 

[Woodsong]

Lots of views and no replies so I may not be the only one not 110% sure on this one issue?
I was thinking about it this morning. With the FAA's main objective, as I understand it, being safety and traffic separation....wouldn't it be great if they produced a UAV specific sectional charts that really had 2 things on it...authorized part 107 air space where no ATC authorization is required and then depict all other airspace area where ATC authorization IS required. John Doe flying his drone may study for the 107 test and may retain that knowledge for a while but he may get fuzzy on remembering blue dotted lines vs solid magenta vs fuzzy magenta and what he is supposed to do around each of those. Developing a stupid simple UAV chart of allowed airspace and obstacles and areas of concern and areas of higher manned aircraft traffic, etc would probably go a long way towards making sure everyone is as safe as could be.
As UAV use increases it seems creating UAV use charts would make a ton of sense.


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[GMack]

Excellent idea!

A lot on those sectionals now have meaningless stuff like frequencies to ATC, standard flight byways, radials from VORs, etc. They could be simplified a lot for sUAV fliers for downloading to your area. Maybe numbers to call for permissions, towns with anti-drone ordinances, etc. Maybe include where you can fly at as well.

Send it to the FAA and see if they respond.

 

[ExcObs1]

My interpretation (FWIW)

There is NO surfaces area of class e in the 2nd diagram. That's per FAA definition.

Therefore, what they seem to be saying is, there is a much better chance of authorization within the surface area of class e (1st diagram) than any other. Or, there would be more applicable UAS operation within a class e surface area than any other. (but I would question that philosophy)

It is interesting why they choose that description (within lat bounds of class e surface)

But again that does not apply to the second diagram. There is NO surface area.

5.8.1 authorizes operations there.

 

[Woodsong]

While there is no surface area Class E @ ground level at TZV (second diagram), there is Class E present if one increased their flight elevation to 700' so Class E is there and if one was using lateral boundaries as the defining criteria of authorization from ATC or no authorization from ATC, then yes, Class E is present if one continued that perimeter around the 700' AGL and carried it down to the ground.
Here is the link to the document referring to lateral boundaries (scroll to bottom of page 5.5 in the link):
http://www.faa.gov/uas/media/AC_107-2_AFS-1_Signed.pdf

And here is the FAA's "rule summary" document that simply states no operation in Class E allowed without authorization and no mention is made of any related to lateral boundaries.

And then here is the FAA's simple summary of the rules on their own website saying no authorization required if flying inside of Class G airspace: Fly for Work/Business

So doument #1 seems to indicate you can't fly under Class E 700 AGL and document #2 seems to say you can fly under Class E 700 AGL. And then the last link to their website says ok to fly in Class G space. So 2 of the 3 documents/sources from the FAA indicate that one CAN fly underneath Class E 700 AGL airspace but then the one document refers to lateral boundaries....

 

[N42742]

If it isn't surrounded by dashed magenta lines, it's not Class E surface area. No further interpretation is needed.

 

[Woodsong]

So then it seems my confusion is not in the term lateral boundaries but "surface area" of class E so they literally mean the lateral boundaries of only that class E airspace that goes directly to the ground, I.E. dashed magenta lines....
That certainly frees up a lot more airspace not requiring authorization from 0-400' AGL. I still think the FAA's wording is poorly constructed but maybe if I had my full private pilot's license I would not think that was the case....



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[stillentt]

So then it seems my confusion is not in the term lateral boundaries but "surface area" of class E so they literally mean the lateral boundaries of only that class E airspace that goes directly to the ground, I.E. dashed magenta lines....
That certainly frees up a lot more airspace not requiring authorization from 0-400' AGL. I still think the FAA's wording is poorly constructed but maybe if I had my full private pilot's license I would not think that was the case....



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Woodsong - Just curious where you ended up on this topic. I'm researching the exact same issue for my home town and looking for clarity.

 

[Mike-m1911a1]

1 is class E from the surface up. This is denoted by the magenta dashed line. The dashed magenta box is what is referred to as lateral boundary.

2 is class g from surface to 700 agl then it's class E.

3 is class D from surface to 2600 msl then is class E.

Hope this helps.


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[stillentt]

Not really.

While I agree that #2 is Class G from surface to 700AGL, the FAA defines the "requirement for authorization if within the lateral boundaries of Class E (in which #2, unfortunately, falls into that category)". Therefore, authorization will be required for #2 even though 'technically' it is inside Class G airspace.

 

[Mike-m1911a1]

I'm not sure I agree as 2 is under class e not laterally bound to class e.


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[stillentt]

I really hope you are correct, as that would make my life easier , but I'm not 100% confident in either direction. I'm posting this question into the 107 study group on FB to see if I can get some more feedback.

 

[ExcObs1]

Not really.

While I agree that #2 is Class G from surface to 700AGL, the FAA defines the "requirement for authorization if within the lateral boundaries of Class E (in which #2, unfortunately, falls into that category)". Therefore, authorization will be required for #2 even though 'technically' it is inside Class G airspace.

By definition, #2 only denotes a "transition area". Not a lateral boundary.

There is no requirement for authorization within class G airspace

 

[RO'Shea]

The below letter of interpretation from the FAA states that class E airspace starting at 700AGL or 1200 AGL is a "transition area" and not "surface areas". This specific interpretation targeted aerobatic flight underneath that transition area at an airport. The verbiage for the subject reg in the LOI--91.303--includes language similar to 107.41.

The similarity of the language and this LOI lead me to believe that 107.41 only applies to those airports with surface area class E, not airports with a transition area overhead (i.e. shaded magenta).

91.303
No person may operate an aircraft in aerobatic flight—
(c) Within the lateral boundaries of the surface areas of Class B, Class C, Class D, or Class E airspace designated for an airport;

107.41
No person may operate a small unmanned aircraft 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 unless that person has prior authorization from Air Traffic Control (ATC)

https://www.faa.gov/about/office_or...2006/hucker - (2006) legal interpretation.pdf

 

[Richard R]

By definition, airspace below class e (700 ft) is class g, the lateral boundaries start at 700 ft agl. B, c, d and e (sfc) lateral boundaries can go to the ground and authorizations are required (I currently have an authorization to fly within the e(sfc) of our local airport).

 

[Unmannedsky]

Not really.

While I agree that #2 is Class G from surface to 700AGL, the FAA defines the "requirement for authorization if within the lateral boundaries of Class E (in which #2, unfortunately, falls into that category)". Therefore, authorization will be required for #2 even though 'technically' it is inside Class G airspace.

Read 107.41 carefully (Class E part)

 

[daveisim]

While late to this discussion, I might as well chime in as an FAA certified private pilot and Part 107 pilot.

Area #2 as debated is Class G from the surface to 700'AGL.

I agree that the FAA wording of the " within the lateral boundaries of the surface area of Class E airspace designated for an airport " is a tough one.

Think of two words here that will describe all airspace boundaries. The words are: Lateral and Vertical. Vertical for this area is 700AGl up to the next airspace. Lateral is within that vertical area, spreading outward over to the next airspace. Does that make it easier?

 

[RO'Shea]

Also late to discussion. Certified Flight Instructor. Hoping to clear up the "lateral boundaries of Class E Airspace designated for an airport". The FAA's definition of Surface Area in the Pilot Controller Glossary is below:

SURFACE AREA− The airspace contained by the lateral boundary of the Class B, C, D, or E airspace designated for an airport that begins at the surface and extends upward.

Key words are BEGINS AT THE SURFACE. Airports with Class E that begins at 700AGL don't fall into this, nor do the outer shelves of Class B and C as they don't begin at surface.

This issue has been extensively discussed as regards aerobatics, including a legal interpretation from the FAA.

91.303
No person may operate an aircraft in aerobatic flight—
(c) Within the lateral boundaries of the surface areas of Class B, Class C, Class D, or Class E airspace designated for an airport;

Same key words and concepts. FAA has issued a legal interpretation that states that airspace that is not designated for SURFACE is ok for aerobatics, and thus for drones, regardless of what airspace is above. For more reading:

http://www.rapp.org/archives/2006/03/surface_area/

 

[SkySensei]

Area 2 is Class G up to 700' AGL. You may be within 5nm of an airport ("Chicken Coop") which would require notification by a non-rated pilot and no notification (but obviously awareness and caution) on the part of a rated pilot.

The Class E extension (Area 1) is down to the surface most likely to accommodate an instrument approach into KFLO. You need permission to enter so you don't present a threat to an aircraft operating IFR.