Narrative:

While flying in mry class C airspace, I descended below 2000 ft AGL to maintain VFR cloud clrncs. It has since come to my attention that I may have violated minimum altitude requirements over the marine sanctuaries in the area. The sectional charts identify a 'requested' minimum altitude of 2000 ft AGL. However, common practice and thought among local pilots is that this is only a request and not an far. I have not been able to find the FARS that establish 2000 ft AGL as a legal minimum. I have recently discovered crash fire rescue equipment's outside of the FARS that appears to restrict flight to 1000 ft AGL. I contacted pilot group's technical services for a consultation. Pilot group said they would have to refer it to their legal department for research because they were unsure themselves. I will continue to seek out an answer with pilot group, FAA and local controllers. Also during the flight, radar and radio contact were disrupted due to terrain obstruction. As a result, there was a miscom between the approach controller and me. I was transitioning through the class C to the south for a short trip and would be returning along the same route without leaving the vicinity of the airspace. I thought the controller requested I keep the initial squawk code and to contact him once again returning north (and I repeated this understanding back to him). I kept the same squawk code on my way north, but had difficulty re-establishing radio contact. When I finally did re-establish radio contact, it was apparent that the controller had requested another course of action just before losing contact. I have telephoned mry tower to ask about their preferred procedures and they confirmed that it is common for aircraft approaching from the south to be unable to establish or maintain radio contact at normal VFR altitudes, even while within the class C airspace. The controller I spoke with said that most of the controllers understand the problem and therefore do not report violations if pilots are trying to comply he said the only sure way to comply would be to climb to 5500 ft AGL or so, to establish radio communications in that area. There is a significant attraction to low level VFR flight in the area for sight-seeing purposes. It seems impractical to have class C airspace restrs over an area where ATC cannot adequately serve the dimensions of the airspace. I believe the class C designation is warranted due to the nature of mry's operations. However, improving radar and radio services within this airspace would dramatically increase safety and confidence in the operations therein.

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Original NASA ASRS Text

Title: A LOW TIME PVT PLT HAS A PROB IN MAINTAINING COM WITH MRY APCH CTLR WHILE ATTEMPTING ENTRY OF THE CLASS C AIRSPACE FROM THE S AND W OF ARPT AT MRY, CA.

Narrative: WHILE FLYING IN MRY CLASS C AIRSPACE, I DSNDED BELOW 2000 FT AGL TO MAINTAIN VFR CLOUD CLRNCS. IT HAS SINCE COME TO MY ATTN THAT I MAY HAVE VIOLATED MINIMUM ALT REQUIREMENTS OVER THE MARINE SANCTUARIES IN THE AREA. THE SECTIONAL CHARTS IDENT A 'REQUESTED' MINIMUM ALT OF 2000 FT AGL. HOWEVER, COMMON PRACTICE AND THOUGHT AMONG LCL PLTS IS THAT THIS IS ONLY A REQUEST AND NOT AN FAR. I HAVE NOT BEEN ABLE TO FIND THE FARS THAT ESTABLISH 2000 FT AGL AS A LEGAL MINIMUM. I HAVE RECENTLY DISCOVERED CFR'S OUTSIDE OF THE FARS THAT APPEARS TO RESTRICT FLT TO 1000 FT AGL. I CONTACTED PLT GROUP'S TECHNICAL SVCS FOR A CONSULTATION. PLT GROUP SAID THEY WOULD HAVE TO REFER IT TO THEIR LEGAL DEPT FOR RESEARCH BECAUSE THEY WERE UNSURE THEMSELVES. I WILL CONTINUE TO SEEK OUT AN ANSWER WITH PLT GROUP, FAA AND LCL CTLRS. ALSO DURING THE FLT, RADAR AND RADIO CONTACT WERE DISRUPTED DUE TO TERRAIN OBSTRUCTION. AS A RESULT, THERE WAS A MISCOM BTWN THE APCH CTLR AND ME. I WAS TRANSITIONING THROUGH THE CLASS C TO THE S FOR A SHORT TRIP AND WOULD BE RETURNING ALONG THE SAME RTE WITHOUT LEAVING THE VICINITY OF THE AIRSPACE. I THOUGHT THE CTLR REQUESTED I KEEP THE INITIAL SQUAWK CODE AND TO CONTACT HIM ONCE AGAIN RETURNING N (AND I REPEATED THIS UNDERSTANDING BACK TO HIM). I KEPT THE SAME SQUAWK CODE ON MY WAY N, BUT HAD DIFFICULTY RE-ESTABLISHING RADIO CONTACT. WHEN I FINALLY DID RE-ESTABLISH RADIO CONTACT, IT WAS APPARENT THAT THE CTLR HAD REQUESTED ANOTHER COURSE OF ACTION JUST BEFORE LOSING CONTACT. I HAVE TELEPHONED MRY TWR TO ASK ABOUT THEIR PREFERRED PROCS AND THEY CONFIRMED THAT IT IS COMMON FOR ACFT APCHING FROM THE S TO BE UNABLE TO ESTABLISH OR MAINTAIN RADIO CONTACT AT NORMAL VFR ALTS, EVEN WHILE WITHIN THE CLASS C AIRSPACE. THE CTLR I SPOKE WITH SAID THAT MOST OF THE CTLRS UNDERSTAND THE PROB AND THEREFORE DO NOT RPT VIOLATIONS IF PLTS ARE TRYING TO COMPLY HE SAID THE ONLY SURE WAY TO COMPLY WOULD BE TO CLB TO 5500 FT AGL OR SO, TO ESTABLISH RADIO COMS IN THAT AREA. THERE IS A SIGNIFICANT ATTRACTION TO LOW LEVEL VFR FLT IN THE AREA FOR SIGHT-SEEING PURPOSES. IT SEEMS IMPRACTICAL TO HAVE CLASS C AIRSPACE RESTRS OVER AN AREA WHERE ATC CANNOT ADEQUATELY SERVE THE DIMENSIONS OF THE AIRSPACE. I BELIEVE THE CLASS C DESIGNATION IS WARRANTED DUE TO THE NATURE OF MRY'S OPS. HOWEVER, IMPROVING RADAR AND RADIO SVCS WITHIN THIS AIRSPACE WOULD DRAMATICALLY INCREASE SAFETY AND CONFIDENCE IN THE OPS THEREIN.

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.