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Final Approach
Is there any reason for the requirement that wouldn't also apply to uncontrolled fields in transition zones? No one is going to be flying in the G without a clearance into or coming out of the E anyway, at least not legally, and there's been at least one enforcement action against someone who tried.I'm wondering to about the Radio communication requirement for establishment of a Surface Area. We'd probably have to go back to when the Control Zone was invented, long before the cell phone and all of our other present day means of communication were considered. With the exception of the very few Airport Traffic Areas that weren't within Control Zones, Class D was simply a new name for what already existed. The term Class E Surface Area had to be invented to cover the Non Towered Control Zones and the extensions and other odd shapes.
And I know of one surface E field that no longer meets the requirement. When it did, the only "radio" communication with ATC on the ground was via a GCO - the kind that's really a half-duplex phone connection. But that facility has been OTS for over 10 years.