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Inspired by this question:

If a TFR requires discrete squawk and two-way ATC (Class C requirements) whenever within the airspace, and an untowered field exists within the TFR's boundary, does that untowered field essentially become a quasi-towered field?

If I'm to remain in two-way comms with ATC (presumably Approach), it will be difficult to coordinate with other traffic on CTAF. On the other hand, they all need to be on the same frequency to be in two-way with ATC. If we're all chatting away to coordinate on our own, that would seem to jam the frequency pretty badly... does Approach take over sequencing us? What's the procedure for landing at that field under these conditions (Obviously departures will need to be released by ATC.)?

I assume patternwork basically gets shut down? If not... do we get option clearances from Approach? (That seems... not ideal since they don't have eyes on the runway...)

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TL;DR: No. Class C airspace comes with a specific set of requirements for pilots and a specific set of requirements for ATC. TFRs have "squawk and talk" requirements for pilots, but that does not mean ATC has Class C requirements.


With all TFRs, it is imperative to read the actual text of the TFR itself and not make assumptions based on what similar TFRs may have required in the past. Let's examine this VIP (POTUS) TFR, which is FDC NOTAM 4/4691. Generally POTUS TFRs will always be the same, but just keep that in mind.

The overarching restriction is "No pilots may operate an aircraft in the areas covered by this NOTAM (except as described)." We knew that, but it's important to read this anyway; some TFRs only apply to certain types of aircraft. It makes you sound unprepared when you request permission to fly your Skyhawk into a "No UAS" TFR.

Then they list exceptions to, and more details about, the blanket restriction. Note that it is possible for ATC to authorize other exceptions "in consultation with the Air Traffic Security Coordinator via the Domestic Events Network." In your linked question the controller probably did not do this coordination and so it was probably an error on their part. But in theory ATC can authorize any deviation from the blanket restriction. In theory.

Paragraph A is for the "inner core" of the TFR and basically says you aren't flying your private Skyhawk into or out of there, no way no how.

Paragraph B is for the "outer ring" of the TFR and now things become relevant. Among other restrictions (no loitering, etc) it says:

ACFT MUST BE SQUAWKING THE DISCRETE CODE PRIOR TO DEP AND AT ALL TIMES WHILE IN THE TFR AND MUST REMAIN IN TWO-WAY RADIO COM WITH ATC.

This means exactly what it says: You must be on ATC's frequency as long as you're physically able to be (line-of-sight to ATC's radio antenna). If you feel that you need to be on CTAF, then in my mind you have two options: Make sure your aircraft has two operating radios, so you can transmit and listen on CTAF while still monitoring ATC... or wait for the TFR to end. I'm not a lawyer but that's how I would interpret it. Remember though that CTAF calls aren't mandatory—just highly highly encouraged.

In contrast, for Class C there is more to the airspace than just "squawk and talk." (In fact the "squawk" requirement is also different between TFRs and Class C airspace. The TFR requires a discrete code, while Class C only requires an "operable transponder" responding on the ATC-specified code, which may be the non-discrete 1200 code.)

Within Class C airspace ATC will separate IFR-to-VFR traffic, and this service is not part of the TFR. Within Class C airspace ATC will sequence VFR traffic to the primary airport, and this service is also not part of the TFR; note that even in actual Charlie airspace you can have non-towered satellite airports within the surface area, and ATC will not sequence to those non-towered airports.

For a TFR, you will contact ATC on the ground to get your discrete squawk code and your release from the airport. As always, ATC will never issue any runway clearances (takeoff, landing, option) for a non-towered airport.


As for pattern work: Again, read the TFR. Paragraph C lists the many types of operations which are specifically not authorized within the TFR:

FLT TRAINING, PRACTICE INSTRUMENT APCH, AEROBATIC FLT, GLIDER OPS, PARACHUTE OPS, ULTRALIGHT, HANG GLIDING, BALLOON OPS, AGRICULTURE/CROP DUSTING, ANIMAL POPULATION CTL FLT OPS, BANNER TOWING OPS, SIGHTSEEING OPS, MAINTENANCE TEST FLIGHTS, MODEL ACFT OPS, MODEL ROCKETRY, UNMANNED ACFT SYSTEMS (UAS), AND UTILITY AND PIPELINE SURVEY OPS.

To play devil's advocate, a very pedantic argument might be that non-"training" pattern work—a licensed pilot going up for currency, say—would still be authorized. Good luck making that argument, given the spirit of the rest of the prohibitions.

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I think you may be overthinking things by using terms of art like "de facto Class C" and "quasi-towered field." Really you just need to be talking and squawking. That's generally all the TFR will specify.

does Approach take over sequencing us?

They should provide whatever sequencing services they normally do depending on airspace and the flight rules in effect.

What's the procedure for landing at that field under these conditions?

Expect a normal full stop landing.

Personally I have only flow in and out of TFRs at a towered field where approach did hand us off to tower. However, as you noted in the other question the standard practice when landing at a non-towered airfield is for an approach controller to have you squawk 1200 and pass you to CTAF.

As answers to the other question indicated, that flight should have remained on an ATC frequency and kept their squawk until landing, so that would be the procedure to expect. Therefore, if the controller absentmindedly spouted the standard "squawk VFR, change to advisory approved" it would be prudent to reply "will remain with you until clear of the TFR / landing."

If you are concerned with not making normal CTAF calls, remember there shouldn't be anyone in the pattern, and everyone inbound or outbound should be talking to ATC. At some point it may be prudent to ask, and in non-standard situations just use plain language. For example: "approach, N123W, is there any arriving or departing traffic between me and the field?"

Obviously departures will need to be released by ATC...

Yes, departures will need to be released by ATC.

I assume patternwork basically gets shut down? If not... do we get option clearances from Approach?

That would be a good assumption. Since the "R" in TFR is intended to ground anyone not flying into or out of the TFR on a flight plan, it wouldn't make sense for pattern training to continue as if there were no TFR. And it would make less sense for a radar controller to play tower for the reason you mentioned.

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