Does an SVFR clearance extend to Echo surface extensions?
This is an answer to the question provided by my checkride examiner Barry Lloyd   

On 01-26-2010, a query asking whether SVFR is available in Class E extensions was routed to FAA ATC Headquarters. Below is a response to that query from the FAA ATO Western Service Center:

"Our opinion is:

FAR 91.157 (a) ..."special VFR operations may be conducted"..."within the airspace contained by the upward extension of the lateral boundaries of the controlled airspace designated to the surface for an airport." This permits SVFR clearances within the vertical extension, not the lateral/horizontal extension of an airport designated surface area.

FAAO 7400.9T par 6002. Definition of Class E2 airspace: "The Class E airspace areas listed below are designated as a surface area for an airport."

FAAO 7400.9T par 6004. Definition of Class E4 airspace: "...airspace extending upward from the surface designated as an extension to a Class D or Class E surface area."

The language in FAR 91.157 exactly matches the language in FAAO 7400.9T par 6002. Par. 6004 does not match and the FAR does not permit SVFR operations in the lateral extension of a surface area designated for an airport; only within the vertical extension.

Presumably this could be corrected if we indeed want to provide for SVFR within lateral extensions, but it is currently not permitted.

There are other operational issues involved: eg. an extension to a Class D surface area where the tower provides SVFR services within the Class D airspace as is permitted via LOA. They cannot issue a SVFR clearance in the E4 extension. If permitted, the controlling agency, presumably the ARTCC would have to do this.

Our opinion is that E4 airspace is not part of the airspace designated as the surface area for an airport. The surface area for an airport is D, C, or E2. Extensions are treated differently from surface areas designated for an airport, ie there is no communication requirement. In addition extensions, by definition in 7400.9, are not airspace designated as the "surface area for an airport"."