I'd like to make a trip up to Marble Canyon next week. The airport lies within the Grand Canyon SFRA, and all else being equal, I'd kinda like to stay legal. 
FAR 93.309 says in relevant part,
Except in an emergency, no person may operate an aircraft in the Special Flight Rules Area unless the operation is conducted in accordance with the following procedures.
[...]
(f) Is conducted within 3 nautical miles of Grand Canyon Bar Ten Airstrip, Pearce Ferry Airstrip, Cliff Dwellers Airstrip, Marble Canyon Airstrip, or Tuweep Airstrip at an altitude less than 3,000 feet above airport elevation, for the purpose of landing at or taking off from that facility.
There is similar language on the chart itself. Now this is all well and good, and I've seen articles and YouTube videos by pilots who arrive at L41 by spiraling down, within 3 nm of the airport, from above the top of the SFRA.
The problem with that is that the top of that sector of the SFRA is 7,999' MSL, and the language of the FAR exempts only 3,000' above the 3,603' MSL field elevation. So is someone who spirals down from overhead (or climbs out within 3 nm on departure) in violation of the SFRA between 7,999' and 6,603' MSL?
The airport is slightly less than three nm from the boundaries of the SFRA to the northwest and southeast, but right at the boundaries are sheer canyon walls that go right up to the top of that 3,000'-above-field-elevation limit. I don't think buzzing the canyon rims is what they had in mind when the SFRA rules were drawn up.
The yellow circle on the attached chart screenshot is a 3nm radius from L41.
I read lots of goofy statutes in 40+ years as a lawyer, but this one appears to make it impossible to safely comply. Am I reading it wrong? Why does it only exempt 3,000' above the airport?
FAR 93.309 says in relevant part,
Except in an emergency, no person may operate an aircraft in the Special Flight Rules Area unless the operation is conducted in accordance with the following procedures.
[...]
(f) Is conducted within 3 nautical miles of Grand Canyon Bar Ten Airstrip, Pearce Ferry Airstrip, Cliff Dwellers Airstrip, Marble Canyon Airstrip, or Tuweep Airstrip at an altitude less than 3,000 feet above airport elevation, for the purpose of landing at or taking off from that facility.
There is similar language on the chart itself. Now this is all well and good, and I've seen articles and YouTube videos by pilots who arrive at L41 by spiraling down, within 3 nm of the airport, from above the top of the SFRA.
The problem with that is that the top of that sector of the SFRA is 7,999' MSL, and the language of the FAR exempts only 3,000' above the 3,603' MSL field elevation. So is someone who spirals down from overhead (or climbs out within 3 nm on departure) in violation of the SFRA between 7,999' and 6,603' MSL?
The airport is slightly less than three nm from the boundaries of the SFRA to the northwest and southeast, but right at the boundaries are sheer canyon walls that go right up to the top of that 3,000'-above-field-elevation limit. I don't think buzzing the canyon rims is what they had in mind when the SFRA rules were drawn up.
The yellow circle on the attached chart screenshot is a 3nm radius from L41.
I read lots of goofy statutes in 40+ years as a lawyer, but this one appears to make it impossible to safely comply. Am I reading it wrong? Why does it only exempt 3,000' above the airport?
