Wally Roberts

Attached is a two-page PDF, which shows the Class E 1,200' airspace proposed in this NPRM. Page 1 shows the boundaries of the proposed airspace in magenta and also shown is the exact holding pattern for the course reversal for the KBCE RNAV Runway 21 standard instrument approach procedure (SIAP). You will note that a substantial portion of the holding pattern's primary airspace is excluded by the NPRM (green tinted area). FAA policy and safety of flight mandates that the green tinted area be included within the proposed Class E 1200' boundaries. The second page of the attached PDF shows the coordinates of the airspace required to cause this holding pattern to be in compliance with FAA policy and for safe flight in the terminal environment during instrument meteorological conditions (IMC). The final rule in this matter must include as Class E 1200' airspace the entire primary area of the subject holding pattern. The NPRM also proposes to add Class E 700' airspace, and I quote: "That airspace extending upward from 700 feet above the surface within 8 miles each side of the 047° and 227° bearing from the airport, extending 18 miles northeast and 15.9 miles southwest of the airport." That exact airspace was enacted in the last final rule issued for Bryce Canyon; thus the current Class E 700' proposed airspace is duplicative.