I'm trying to analyze the parts, to see what they are. In the same way that strokes 1-5, and 6-9 (even those together), and the the final six (bottom) form common elements of kanji.
So (a) do strokes 10-11 (12) form an element,
or (b) do strokes (12) 13-16 form an element?
Are there any other kanji that use (a) or (b)? --or 10-16 as a whole?
I don't think I've seen (a) before, but I think I've seen (b) in some form, but I'm not good enough to spin thru my mind looking, and searching has been futile.
Also, while these may not be traditionally accepted parts/elements of kanji, I'd wonder if Heisig would have named/separated this part of the kanji in that system (as two parts, or one).
edit: Got one that just leaves off the bottom--龍.