On Jan 26, 2:10*pm, Tom wrote:
As stated in the original message, I am still resolving issues with
FAA legal.
Caustic remarks aside, this is an issue with many pilots, and the
issue is more than the words used in the current regulation.

Tom Knauff

What issue is there to resolve?
Unless they contradicted 91.121(a)(1)(III)

In the west, you cannot roll the altimeter down to zero, the knob does
not adjust that far.
And if you depart from an airfield at 1200MSL, and roll the altimeter
to zero, you have to remember that you are reading 1200ft low, and
when you climb through 16,800 as read on the altimeter, you just
busted Class A !

We are under a Class B shelf, roll the altimeter down to zero, how do
you know where your citing is as you climb under the shelf? BUSTED!

T