Airspace Queston TME (Houston)

The standard for the upper limit of a Class D surface area is 2500' AGL. Field elevation at KTME is 166' MSL, if they stick with the standard it will be charted at 2700' MSL. The base of the Class B shelf is 3000' MSL to the northeast and 4000' to the east and southeast. Doesn't seem inconvenient to me.

I'd like more than 300' to transition above. That's not much room for altimeter error or setting mismatch. Say I'm in the middle, that's only 150' error each direction. Too close to put my certificate on the line.
 
A surface area requires:

Check that one off. Every towered airport will have communications down to the runway surface. They will also have landline communications to the facility providing IFR services.

Check. KTME has an AWOS-3, if it wasn't Federally commissioned the feds wouldn't show it in the A/FD.

If those two criteria are met, then a surface area:

This one is flaky. The tower at KTME operates under the FAA Contract Tower Program. Is an FAA contract tower an FAA control tower? I could find no explicit definition. If it is then KTME should have a Class D surface area. If it isn't the following comes into play:

The tower at KTME is not part of the Contract Tower Program. It is a Non-Federal control tower.
 
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