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3. In keeping with item (2) immediately above, the FAA's LAANC system for authorizing flight of Small Unmanned Aircraft under FAR 107 (and also under the October 2018 44809 Recreational Exception for limited (hobby) recreational operations of unmanned aircraft, which uses the same phrasing as FAR 107.41)) does not include any E4 Class-E-to-surface "extension" airspace in the "gridded" airspace where authorization may be requested, thus implying that no authorization is required to operate a Small Unmanned Aircraft System (sUAS) or hobby model airplane, drone, etc in this airspace under the terms of FAR 107 or the October 2018 Recreational Exception.

4. In keeping with items (2) and (3) immediately above, this 2019 Power Point document entitled "Class E airspace", compiled by FAA Aviation Safety Inspector Kevin Morris for an FAA UAS (Unmanned Aircraft System) Symposium, contains graphics clearly indicating that no authorization is needed to operate an "unmanned aircraft" in E4 airspace-- i.e. in the "extensions" to Class D or E2 airspace-- despite the language of FAR 107.41. Note specifically the inclusion of KTVL (Lake Tahoe airport) as one of the illustrated examples.

5. If there were no operational difference between E2 airspace surrounding an airport and E4 "extensions", it is difficult to imagine why the FAA would ever designate an E4 "extension" to full-time E2 airspace, as has been done at Lake Tahoe Airport (KTVL) and Humboldt Country Airport (KACV) and , rather than simply making the entire area one unified piece of E2 airspace.

1. Actually, the plot is even more twisted than that-- the case may be made that after using the E4 airspace as an "elevator shaft" to ascend from ground level to the floor of the overlying sheet of Class E airspace (typically at 700' AGL or 1200' AGL), a model airplane or hobbyist drone pilot operating under the Recreational Exception may then freely roam around the Class E airspace at any altitude above the Class E floor, without being confined to stay within the footprint of the E4 extension. The key point being that unlike the situation with Part 107, the standard 400' altitude limit in the Recreational Exception only applies in uncontrolled airspace.

3. In keeping with item (2) immediately above, the FAA's LAANC system for authorizing flight of Small Unmanned Aircraft under FAR 107 (and also under the October 2018 44809 Recreational Exception for limited (hobby) recreational operations of unmanned aircraft, which uses the same phrasing as FAR 107.41)) does not include any E4 Class-E-to-surface "extension" airspace in the "gridded" airspace where authorization may be requested, thus implying that no authorization is required to operate a Small Unmanned Aircraft System (sUAS) or hobby model airplane, drone, etc in this airspace under the terms of FAR 107 or the October 2018 Recreational Exception.

4. In keeping with items (2) and (3) immediately above, this 2019 Power Point document entitled "Class E airspace", compiled by FAA Aviation Safety Inspector Kevin Morris for an FAA UAS (Unmanned Aircraft System) Symposium, contains graphics clearly indicating that no authorization is needed to operate an "unmanned aircraft" in E4 airspace-- i.e. in the "extensions" to Class D or E2 airspace-- despite the language of FAR 107.41. Note specifically the inclusion of KTVL (Lake Tahoe airport) as one of the illustrated examples.

5. If there were no operational difference between E2 airspace surrounding an airport and E4 "extensions", it is difficult to imagine why the FAA would ever designate an E4 "extension" to full-time E2 airspace, as has been done at Lake Tahoe Airport (KTVL) and Humboldt Country Airport (KACV), rather than simply making the entire area one unified piece of E2 airspace.

1. Actually, the plot is even more twisted than that-- the case may be made that after using the E4 airspace as an "elevator shaft" to ascend from ground level to the floor of the overlying sheet of Class E airspace (typically at 700' AGL or 1200' AGL), a model airplane or hobbyist drone pilot operating under the Recreational Exception may then freely roam around the Class E airspace at any altitude above the Class E floor, without being confined to stay within the footprint of the E4 extension. The key point being that unlike the situation with Part 107, the 400' altitude limit in the Recreational Exception only applies in uncontrolled airspace.

Here is one of the more astounding results of the ongoing confusion and ambiguity around this issue. It seems obvious that when the October 2018 44809 Exception for limited recreational operations of unmanned aircraft ("Recreational Exception") was created-- undoubtedly with substantial FAA input-- the authors assumed that by including the phrase "within the lateral boundaries of the surface area of Class E airspace designated for an airport" within the list of places where prior authorization was required, E4 airspace would become off-limits for recreational model aircraft, or accessible only under strict conditions, including an altitude limit prescribed at the time the authorization was issued. The legislation contains no other provision for limiting the altitude to which model airplanes, hobbyist drones, etc may be flown in E4 airspace. Therefore the FAA's assertion that E4 airspace does not fall within the meaning of "within the lateral boundaries of the surface area of Class E airspace designated for an airport" has the bizarre consequence of setting aside E4 airspace-- the airspace protecting instrument approach and departure paths-- as the only airspace in which model airplanes, hobbyist drones, etc may be flown with no altitude restriction whatsoever.¹ This is not the case for part 107 operations, because part 107 contains a blanket 400' height limit, with certain well-prescribed exceptions.

Footnotes--

1. Actually, the plot is even more twisted than that-- the case may be made that after using the E4 airspace as an "elevator shaft" to ascend from ground level to the floor of the overlying sheet of Class E airspace (typically at 700' AGL or 1200' AGL), a model airplane or hobbyist drone pilot operating under the Recreational Exception may then freely roam around the Class E airspace at any altitude above the Class E floor, without being confined to stay within the footprint of the E4 extension. The key point being that unlike the situation with Part 107, the standard 400' altitude limit in the Recreational Exception only applies in uncontrolled airspace.

3. In keeping with item (2) immediately above, the FAA's LAANC system for authorizing flight of Small Unmanned Aircraft under FAR 107 (and also under the October 2018 44809 Recreational Exception for limited (hobby) recreational operations of unmanned aircraft, which uses the same phrasing as FAR 107.41)) does not include any E4 Class-E-to-surface "extension" airspace in the "gridded" airspace where authorization may be requested, thus implying that no authorization is required to operate a Small Unmanned Aircraft System (sUAS) or hobby model airplane, drone, etc in this airspace under the terms of FAR 107 or the October 2018 Recreational Exception.

4. In keeping with items (2) and (3) immediately above, this 2019 Power Point document entitled "Class E airspace", compiled by FAA Aviation Safety Inspector Kevin Morris for an FAA UAS (Unmanned Aircraft System) Symposium, contains graphics clearly indicating that no authorization is needed to operate an "unmanned aircraft" in E4 airspace-- i.e. in the "extensions" to Class D or E2 airspace-- despite the language of FAR 107.41. Note specifically the inclusion of KTVL (Lake Tahoe airport) as one of the illustrated examples.

5. If there were no operational difference between E2 airspace surrounding an airport and E4 "extensions", it is difficult to imagine why the FAA would ever designate an E4 "extension" to E2 airspace, as has been done at Lake Tahoe Airport (KTVL) and Humboldt Country Airport (KACV) and , rather than simply making the entire area one unified piece of E2 airspace.

3. In keeping with item (2) immediately above, the FAA's LAANC system for authorizing flight of Small Unmanned Aircraft under FAR 107 (and also under the October 2018 44809 Recreational Exception for limited (hobby) recreational operations of unmanned aircraft, which uses the same phrasing as FAR 107.41)) does not include any E4 Class-E-to-surface "extension" airspace in the "gridded" airspace where authorization may be requested, thus implying that no authorization is required to operate a Small Unmanned Aircraft System (sUAS) or hobby model airplane, drone, etc in this airspace under the terms of FAR 107 or the October 2018 Recreational Exception.

4. In keeping with items (2) and (3) immediately above, this 2019 Power Point document entitled "Class E airspace", compiled by FAA Aviation Safety Inspector Kevin Morris for an FAA UAS (Unmanned Aircraft System) Symposium, contains graphics clearly indicating that no authorization is needed to operate an "unmanned aircraft" in E4 airspace-- i.e. in the "extensions" to Class D or E2 airspace-- despite the language of FAR 107.41. Note specifically the inclusion of KTVL (Lake Tahoe airport) as one of the illustrated examples.

5. If there were no operational difference between E2 airspace surrounding an airport and E4 "extensions", it is difficult to imagine why the FAA would ever designate an E4 "extension" to full-time E2 airspace, as has been done at Lake Tahoe Airport (KTVL) and Humboldt Country Airport (KACV) and , rather than simply making the entire area one unified piece of E2 airspace.