HCF CTLR CONCERNED WITH LCL FAA DEFINITION OF 'ATC ASSIGNED AIRSPACE' (ATCAA) THAT ALLOWS FOR IDENTED AIRSPACE TO EXIST IN CLASS E AIRSPACE; THAT IS ALLEGED TO EXIST ONLY IN CLASS A AIRSPACE WITHIN UNITED STATES CONTIGUOUS AIRSPACE.

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THE ISSUE THAT I'M RAISING HAS TO DO WITH THE DEFINITION OF A SPECIFIC TYPE OF AIRSPACE -- ATC ASSIGNED AIRSPACE (ATCAA). ALTHOUGH THIS MAY NOT BE THE RIGHT FORUM TO ADDRESS THIS MATTER; I THINK IT'S A SAFETY ISSUE. THE DEFINITION OF ATCAA IS: AIRSPACE OF DEFINED VERT/LATERAL LIMITS; ASSIGNED BY ATC; FOR THE PURPOSE OF PROVIDING AIR TFC SEGREGATION BTWN THE SPECIFIED ACTIVITIES BEING CONDUCTED WITHIN ASSIGNED AIRSPACE AND OTHER IFR AIR TFC. IN THE CONTIGUOUS UNITED STATES; MIL OPS AREAS (MOA) ARE ESTABLISHED OUTSIDE POSITIVE CTL AIRSPACE TO SEPARATE CERTAIN NON HAZARDOUS MIL ACTIVITIES FROM IFR TFC AND TO IDENT FOR VFR TFC WHERE THESE ACTIVITIES ARE CONDUCTED. ATCAA'S NORMALLY SIT ABOVE THE MOA'S; FL180 AND ABOVE; WITH THE SAME LATERAL BOUNDARIES. BECAUSE THE ATCAA'S ARE IN CLASS A AIRSPACE; ATC IS ABLE TO KEEP ALL NON-PARTICIPANTS OUT OF THAT AIRSPACE. IN HAWAII; WE HAVE ATCAA'S LOCATED IN THE WARNING AREAS AND EVEN OVER THE ISLANDS OF OAHU AND HAWAII. A SIGNIFICANT DIFFERENCE BTWN HERE AND THE MAINLAND IS WE DON'T HAVE ANY CLASS A AIRSPACE. THIS MEANS THAT ALTHOUGH ATC MAY BE ABLE TO KEEP IFR ACFT OUT OF THE ATCAA'S; THERE'S NO WAY TO KEEP ALL THE VFR'S OUT. BY DEFINITION; THESE ATCAA'S ARE LEGAL. WHAT I WOULD LIKE TO SEE IS A CHANGE TO THE DEFINITION OF ATCAA TO SAY; 'POSITIVE CTL AIRSPACE OF DEFINED VERT/LATERAL LIMITS.' BY MAKING THIS CHANGE IT WOULD FORCE US TO CONSIDER THE CREATION OF MOA'S WHERE THE ATCAA'S NOW EXIST. I KNOW THAT IF I GO THROUGH REGULAR CHANNELS; THIS WILL TAKE A LONG TIME TO CHANGE; IF AT ALL. I'M CONCERNED THAT THE TIME IS OF THE ESSENCE.