Gentlemen/Hoss,
I started this thread over two years ago to help other club secretaries with a mutual problem of airport notifications. The only thing that has really changed is the distance from three to five miles. I have carefully read the “Notice of Interpretation with Request for Comment” (Specifically footnotes page 13) and find nothing new here. Another thing we need to all remember is that this is an evolving document which after the comment period more than likely will be amended.
I worked in the air traffic control industry for many years and while I do not have anywhere near the flight time Hoss does I do hold a private ticket and one of the first things they teach in flight school is to know how to read FAA Regs. The FAA gives pilots a lot of latitude in decision making however no matter how “advisory” (Refer foot note 8) if you do not comply, you had better have a good reason (One that may have to stand up in court if you survive the incident).
I agree with Hoss, love them or hate them it is far easier to work with the FAA then it is to work against them. To me this is a shot across the bow that local clubs and the AMA need to be more cognizant of the NAS and its rules and regs that we all fly in.
Regards
Frank