ZAN CTLR CONCERNED WITH PERCEIVED WEAK FAR REGS CONCERNING SIGHTSEEING AROUND MT MCKINLEY; AK. CTLR HAS FILED A FACILITY UCR.

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THIS IS NOT TO RPT A SPECIFIC OCCURRENCE; BUT RATHER A SIT THAT EXISTS THAT CAUSES A REPEATING UNSAFE SIT TO OCCUR. IN MY OPINION; IF THE SIT IS NOT CORRECTED; IT WILL PROBABLY ONE DAY LEAD TO AN ACCIDENT THAT COULD BE BLAMED ON FAA REGS. I WOULD LIKE TO PREVENT THIS BEFORE IT HAPPENS. I HAVE ALREADY SUBMITTED THE PROB AS AN EMPLOYEE SUGGESTION; FILED A UCR BUT HAVE NOT RECEIVED A SATISFACTORY RESPONSE. NOTE: CONFIDENTIALITY IS NOT REQUIRED. MT MCKINLEY IN ALASKA IS ABOUT 20300 FT HIGH. CLASS A PCA BEGINS AT 18000 FT SO THE MOUNTAIN IS ACTUALLY IN THE PCA; EXCEPT THAT THE PCA EXCLUDES ALL AIRSPACE WITHIN 1500 FT OF TERRAIN. IFR TERRAIN SEPARATION REQUIRES 5 MI OR 2000 FT FROM TERRAIN. ZAN HAS ESTABLISHED AN MIA OF 23000 FT OVER MT MCKINLEY. THIS LEAVES AN AREA THAT IS MORE THAN 1500 FT; BUT LESS THAN 2000 FT; WHICH IS NOT USABLE VFR OR IFR. THERE HAVE BEEN SEVERAL INSTANCES WHERE ACFT HAVE BEEN SIGHTSEEING AT MT MCKINLEY; AND ENCOUNTERED SEVERE TURB WITHIN 1500 FT OF THE MOUNTAIN. THEY REQUEST AN IFR CLRNC TO ENTER CLASS A AIRSPACE BUT ARE UNABLE TO REACH FL230; SO THE REQUEST IS DENIED. THIS LEAVES THE PLT TO CHOOSE BTWN VIOLATING CLASS A AIRSPACE; OR KEEP THE ACFT IN UNSAFE PROX TO THE MOUNTAIN. A SIMILAR SCENARIO THAT OFTEN OCCURS; THAT WHILE NOT AS DANGEROUS; IS STILL AN INEFFICIENT USE OF AIRSPACE; IS AN IFR ACFT OVERFLYING THE MOUNTAIN AT FL230 REQUESTS DSCNT TO VFR ON TOP. THE CLRNC CANNOT BE ISSUED BECAUSE THERE IS NO WAY TO GET BELOW CLASS A AIRSPACE WITHOUT FIRST VIOLATING IFR TERRAIN SEPARATION MINIMA. MY SUGGESTION FOR A SOLUTION WOULD BE TO REDEFINE CLASS A AIRSPACE TO EXCLUDE ANY AIRSPACE BELOW AN ESTABLISHED MINIMUM IFR ALT. TO ME IT IS A CONTRADICTION TO HAVE PCA BELOW THE MIA. THE RESPONSE I HAVE RECEIVED SO FAR IS THAT WE ARE NOT GOING TO REWRITE REGS TO ACCOMMODATE SIGHTSEEING. MY COUNTER IS: IT IS NOT THE FAA'S BUSINESS WHY SOMEONE IS FLYING. IT IS OUR BUSINESS TO ENSURE THAT THE FLYING THEY DO IS DONE SAFELY; AND WE CERTAINLY SHOULD NOT HAVE REGS THAT FORCE THEM TO DO UNSAFE THINGS; SUCH AS FLYING CLOSER THAN THEY WOULD LIKE TO; TO A MOUNTAIN THAT IS WELL KNOWN TO GENERATE ITS OWN WX; INCLUDING EXTREME TURB; AND VICIOUS WINDSHEARS AND UP AND DOWNDRAFTS.