AIRSPACE RECLASSIFICATION DOES NOT ESTABLISH CLASS D AIRSPACE BY FAR WHEN TEMPORARY TWR IS ESTABLISHED.

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I'M PRESENTING YOU WITH SOME OF THE QUESTIONS WE HAVE HERE AT SAV TWR CONCERNING THE OP OF A TEMPORARY TWR AT 49J. AT 49J THERE IS NO CLASS D AIRSPACE. THERE CURRENTLY IS ONLY CLASS G AND CLASS E AIRSPACE. CLASS G AIRSPACE IS UNCTLED AIRSPACE UP TO 700 FT WITH CLASS E AIRSPACE OVERHEAD. THERE APPEARS TO BE NO PROVISION IN THE FARS TO IMPLEMENT A TEMPORARY CLASS D AIRSPACE FOR TEMPORARY TWR OPS. WITH THE CURRENT AIRSPACE; THE TWR WILL BE ISSUING CTL INSTRUCTION IN UNCTLED AIRSPACE AND POSSIBLY TO ACFT ON THE GND WITH NO REGULATORY AUTHORITY (FARS 91.126). IN PREVIOUS YRS WHEN A TEMPORARY TWR WAS OPENED; WE HAD AN ATA WHICH MANDATED PLTS TO TALK TO THE TWR (FAR 91.129); BOTH IN THE AIR AND ON MOVEMENT AREAS. THE NEW AIRSPACE CLASSIFICATION (FAR 91.129) REVISED THE AIRSPACE TO CLASS D AIRSPACE. CLASS D AIRSPACE WAS AN ATA AND A CTL ZONE. WE NEVER HAD A CTL ZONE AT 49J; SO CLASS D AIRSPACE IS NOT APPLICABLE. MEMO DATED SEP/XX/93; FROM FAA INDICATES THE PROB IS KNOWN AT THE NATIONAL LEVEL. THE FIRST PARAGRAPH IDENTS THE PROB THAT ACFT ARE NOT REQUIRED TO CONTACT THE TWR. THE SECOND AND THIRD PARAGRAPHS IDENT THAT TERMS USED SHOULD NOT BE REGULATORY IN NATURE TO MANDATE A PLT TO CONTACT THE TWR. HOWEVER; THE FOURTH PARAGRAPH IS CONTRADICTORY IN THAT; IN THE INTEREST OF FLT SAFETY; ACFT SHOULD CONTACT THE TWR. AGAIN; TO CONTRADICT THAT; THE LAST PARAGRAPH STATES THE LACK OF COM POSES NO THREAT TO AIR SAFETY. SINCE THERE IS UNCTLED AIRSPACE AT THE ARPT THERE IS NO WX REQUIREMENT (91.155;B) FOR 1000/3 TO BE VFR. ACFT CAN PROCEED INTO THE ARPT AT 500 FT WITH 1 MI VISIBILITY ON UNICOM AND LAND WHILE AN IFR ACFT IS EXECUTING AN APCH AND RECEIVING A CLRNC TO LAND. ACFT CAN BE CLRED FOR TKOF WITH 1 MI VISIBILITY WITH 2 OR LESS ENGS AND 1/2 MI VISIBILITY FOR HELIS AND ACFT WITH MORE THAN 2 ENGS (91.173).