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If the official weather report for an airport for which Class D airspace is designated is showing IMC, is that controlling for a Class E surface extension (designated for that airport)?

For example, if I determine that I have 3 miles flight visibility and at least a 1000 ft. ceiling, can I fly through that Class E surface extension without receiving an SVFR clearance?

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The ATC Orders 7-5-1(a)(4) say:

a. SVFR operations in weather conditions less than basic VFR minima are authorized:

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  1. Only within the lateral boundaries of Class B, Class C, Class D, or Class E surface areas, below 10,000 feet MSL.
  2. Only when requested by the pilot.
  3. On the basis of weather conditions reported at the airport of intended landing/departure.

That means, ATC will issue SVFR clearances - or not - in the class E surface area according to the official airport weather.

The 'twist' here is that ATC can't issue an SVFR clearance anyway unless the pilot requests it. The AIM 4-4-6 simply says that an SVFR clearance is required "when the weather is less than that required for VFR flight". So as far as I can see, if you're in VMC in a class E surface area and you expect to remain in VMC then you aren't required to request SVFR, whatever the reported airport conditions are.

I'm actually not sure what your exact scenario is here (in contact with ATC or not, within 4NM or not, etc.) but in reality I suspect that ATC would say "N12345, the field is IFR, say intentions". If you tell them you're in VMC then they have no way to challenge that but they might hint strongly that you should request SVFR - "N12345, is there anything special you'd like to request?" - because it would clarify the situation for everyone and help keep you safe and legal.

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  • $\begingroup$ @pondlife- the question is whether or not 91.155 (c)- " Except as provided in §91.157, no person may operate an aircraft beneath the ceiling under VFR within the lateral boundaries of controlled airspace designated to the surface for an airport when the ceiling is less than 1,000 feet." applies to the Class E surface area, which has been established for (appended to) the Class D airspace, when the official wx report for that Class D's primary airport shows less than a 1000 ceiling. Operating in the Class D portion would require SVFR, but what about the Class E surface extension? $\endgroup$
    – user22445
    Commented Mar 2, 2018 at 0:13
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    $\begingroup$ @pondlife- in the early 1970's as a CFI I worked from a non-tower airport in the sfc extension of a control zone (predecessor of Class D). The extension was similarly established and appended to the control zone for the primary airport. When the official wx for the primary airport was less than 1000 ceiling and or 3 mi vis the entire control zone (including the extension) was declared IMC. I would be required to obtain a SVFR clearance to fly in and out of my non-towered airport. Principle is the same, but less procedural info on this is available since the change-over to airspace classes. $\endgroup$
    – user22445
    Commented Mar 2, 2018 at 0:28
  • $\begingroup$ @757toga According to the AIM 3-2-6: "Surface area arrival extensions become part of the surface area and are in effect during the same times as the surface area." I read that to mean that whatever applies in the surface area also applies to the extensions. This might be a case where a picture is worth a thousand words: is there a specific airport that you could use to illustrate the question? The mix of class D, class E, class E extensions and SVFR is making this question confusing, at least for me :-) $\endgroup$
    – Pondlife
    Commented Mar 4, 2018 at 19:15
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    $\begingroup$ @Pondlife- My first comment above applies to my question. Suppose I am in Class G at 600 feet just below the overcast. I'm approaching a class E sfc extension appended to a class D area. The weather being reported at the class D airport is 700 overcast, 5 mi vis. Do I have to obtain a SVFR clearance to fly underneath the overcast thru the appended class E sfc extension (remaining clear of the class D space)? In other words, does the wx report from the primary airport for which the class D is established apply to the Class E extension? If it does, then I would have to get the SVFR clearance. $\endgroup$
    – user22445
    Commented Mar 4, 2018 at 19:31
  • $\begingroup$ Re "a. SVFR operations in weather conditions less than basic VFR minima are authorized: ... On the basis of weather conditions reported at the airport of intended landing/departure."-- But if the visibility at the pilot's actual location at any given moment was such that he or she could stay legal without requesting SVFR, this passage would seem to have no bearing on the situation. The passage is just saying that if a SVFR clearance is requested, then the conditions at the airport kick in to determine whether the conditions are bad enough, but not too bad, to issue a SVR clearance. Right? $\endgroup$
    – quiet flyer
    Commented May 4, 2021 at 21:07
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FAR 91.155(c) uses the phrase “within the lateral boundaries of controlled airspace designated to the surface for an airport” to describe the airspace where a Special VFR clearance is required to operate under Visual Flight Rules below a 1000’ AGL ceiling. Nowhere is it specified that the ceiling must be determined at the airport, so it is only logical that the regulation would apply to the ceiling at the aircraft's actual location.

Note that some surface-level Class E "extensions" can be very extensive-- for example, at SIT/PASI at Sitka Alaska, all the airspace inside the dashed magenta line that is outside the basic circle around the airport (which is not shown in full on the sectional chart) is actually defined as a surface-level Class E "extension" (E4 airspace).

FAR 91.155(d) uses the phrase "within the lateral boundaries of the surface areas of Class B, Class C, Class D, or Class E airspace designated for an airport" to describe the airspace where a Special VFR clearance is required to operate under Visual Flight Rules when taking off, landing, or entering the traffic pattern of an airport, if ground visibility at that airport (if reported at that airport) is less than 3 statute miles, or if ground visibility is not reported at that airport, if flight visibility during those operations is less than 3 statute miles.

FAR 91.155(d) wouldn't pertain to operations in an "extension", since you wouldn't be taking off, landing, or entering a traffic pattern. However, in an "extension", simply by virtue of being in Class E airspace, you'd be required to have 3 statute miles visibility. There's no regulation that says that this has to be based on the visibility reported at the airport, which may be some distance away.

Section 7-5-1 in FAA Order 7110.65Y, entitled "Air Traffic Control", does have a passage stating that SVFR will be authorized "On the basis of weather conditions reported at the airport of intended landing/departure." But if the visibility at the pilot's actual location at any given moment was such that he or she could stay legal without requesting SVFR, this passage would have no bearing on the situation.

For example, if I determine that I have 3 miles flight visibility and at least a 1000 ft. ceiling, can I fly through that Class E surface extension without receiving an SVFR clearance?

The answer to the question should clearly be "yes". (And at least one air traffic controller has now communicated to me that he shares this view.)

However, at a recent airspace charting meeting, while discussion a tangentially-related issue, an FAA staffer made the comment "If it's a control zone extension, if it's surface level Class E, you are not relying on the pilot's visibility, it's reported visibility at the airport."1

I would argue that this is not correct, but I'm not sure I'd want to push the point in actual practice!

More unclear is whether or not the 1000' ceiling requirement even applies at all in surface-level Class E "extensions"-- and also whether Special VFR should be authorized at all in surface-level Class E "extensions". For more on this, see the related ASE answers linked below.

Footnotes:

  1. Source-- comment made by high-level FAA staffer during April 2021 airspace charting meeting.

Related ASE answers:

Does FAR 91.155c apply to class E surface extensions?

Does an SVFR clearance extend to Echo surface extensions?

Does an SVFR clearance extend to Echo surface extensions?

In the US, in actual practice, workload permitting, will ARTC facilities grant SVFR clearance for surface-level Class E “extensions” (E4 airspace)?

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  • $\begingroup$ some of the content has now been shifted to other answers where it is a better fit-- see links-- $\endgroup$
    – quiet flyer
    Commented May 5, 2021 at 15:36
  • $\begingroup$ There are several non-towered airports with surface-level Class E "extensions" to core Class E "surface areas". A good example is PASI in Alaska -- see airnav.com/airport/PASI . On the one hand the very existence configuration seems to suggest that the FAA continues the "extensions" to be regulatory different in some way than the core "surface areas". Otherwise, why not just make the entire airspace part of a single core E2 "surface area"? $\endgroup$
    – quiet flyer
    Commented Mar 20, 2022 at 15:25
  • $\begingroup$ (ctd) But on the other hand, the fact that the charting division seems to recently have standardized on the choice not to show boundary between the "extensions" and the core "surface areas" seems to be a rather strong indication that the FAA does not consider there to be any regulatory difference between the "extensions" and the core "surface areas". $\endgroup$
    – quiet flyer
    Commented Mar 20, 2022 at 15:25
  • $\begingroup$ " so it is only logical that the regulation would apply to the ceiling at the aircraft's actual location."-- that's just my opinion. I don't know if that's how the FAA sees it. $\endgroup$
    – quiet flyer
    Commented Feb 22, 2023 at 15:54
  • $\begingroup$ An important point is that 91.155(a) references flight visibility, not ground visibility. So if you aren't entering the pattern, how is the ground visibility reported at the aircraft relevant? You should even be able to enter the Class D without SVFR, so long as you have 3 miles flight visibility. $\endgroup$
    – quiet flyer
    Commented Feb 22, 2023 at 17:24
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No, the IMC designation is for the airport itself, not for the surrounding Class E airspace.

You are going to be flying at 500' AGL, assuming no buildings or people around, in a possibly active instrument approach corridor?

A 1000' ceiling = you must maintain yourself 500' below it in Class E airspace. The Class E extension is there for approach/departure protection for IFR operations.

If you must do it, call the tower please.

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    $\begingroup$ the question is whether or not the Class E surface extension is officially IMC since the Class D airspace, for which the Class E surface extension was created, is officially IMC. $\endgroup$
    – user22445
    Commented Mar 1, 2018 at 14:09
  • $\begingroup$ "officially IMC" is quite a label! "Officially", declared IMC is at an airport (and area) with on station weather reporting. The Class E extensions are not included in this area. That still puts you at 500' AGL to be legally clear of clouds as a VFR flight. $\endgroup$
    – Mike Brass
    Commented Mar 1, 2018 at 18:51
  • $\begingroup$ Officially IMC means, in the context of my question, that the "official" weather report (nws, twr, awos, etc.) for the airport for which the Class D was established is showing vis below 3 miles and/or the ceiling below 1000 ft. Pretty straight forward. $\endgroup$
    – user22445
    Commented Mar 1, 2018 at 19:55
  • $\begingroup$ edited my answer, I was OK on explanation but I didn't answer your question before the edit. $\endgroup$
    – Mike Brass
    Commented Mar 1, 2018 at 20:11

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