. Our club field is within 2.0 miles of a city airport on the opposite side of the traffic pattern, has been for twenty years. The FBO and helicopter service know we are there,
That's nice for you. One club where I sometimes fly is within a couple of miles of a guy with a runway in his back yard. He flies there just a few times a year, The FAA's interpretation gives him the power to shut that club down. Another very small private airport is 4.8 miles from my club's field. The FAA wants to give them the power to shut us down. If you read the FAA's "interpretation" literally. it also gives a local private airport the power to shut down my club's indoor flying, because we do it at a gym a couple of miles from that field. Makes no sense, but neither did it make sense to shut down the children's dirt bike industry because dirt bikes contain an alloy containing lead, and it's a federal crime to sell a children's product with more than tiny amounts of lead in it. Bought a children's dirt bike lately? (Even selling or giving away a used one is now a felony.) The fact that your club is fine doesn't mean everybody else doing safe things will be fine, too.