Official word: Runway Incursion vs Surface Incident

Spoke with the Renton FSDO and they sent me the following link to the
2002 Runway Safety Order 7050-1. As promised, I'll share the word:

http://www.faa.gov/airports/runway_s...r%207050-1.pdf

Relevant part is Appendix 2, parts 1 and 2a:

1: "In April 1987, the FAA Administrator approved the following
definition of the term "runway incursion": Any occurrence at an
airport involving an aircraft, vehicle, person or object on the ground
that creates a collision hazard or results in loss of separation with
an aircraft taking off, intending to take off, landing or intending to
land.""

Well, that's obsolete, but, not substantially different. Further:

2a "Although the definition is broad, it was always intended that
runway incursions include problems on the runway, but not on the
taxiways or ramps (in this case, the runway is considered that part of
the area intended for landing and takeoff and includes the runway as
well as parts of taxiways located between the hold line and the
runway)."

2d. "Runway incursions should not include aircraft, vehicles,
pedestrians, or objects on the runway without permission when there is
no collision hazard or loss of separation... Although these and other
similar unauthorized or unapproved movements occur on the airport
surface, they are surface incidents, not runway incursions."

And, finally, an official definition of a Surface Incident:

3l: Surface Incident: "Any event, including runway incursions, other
than an accident, where unauthorized or unapproved movement occurs
within the airport surface movement area or an occurrence in the
airport surface area associate with the operation of an aircraft that
affects or could affect the safety of flight."

That's definitive enough for me, and support's McNicoll's position.
According to the FSDO, in a nutshell, if you cross the yellow single-
solid/single-dash without authorization it's considered a surface
incident. If you cross the yellow double-solid/double-dash it's likely
to be reported as a runway incursion. A runway incursion is also a
surface incident.

Fly safe.

-Chris
CFI, KTTD