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47 Aerial advertising is the name given to operations such as banner towing, airborne signs, skywriting, and public address systems [14 CFR 21.25(b)(6) and (7)]. While aerial advertising is more commonly associated with a fixed-wing banner tow operation, other types of aerial advertising include balloons, blimps, and helicopters. For this report, banner towing is the activity primarily discussed because it involves access to an airfield and operation to and from an airport. A banner is an advertising medium supported by a temporary framework attached externally to an aircraft and towed behind the aircraft (FAA 2003). Banner towing is primarily a commercial activity, undertaken for compensation or hire. FAA has opined that a balloon or blimp that carries a banner can also be considered a commercial aeronautical activity. In a 1992 request for legal interpretation, the FAA provided an interpretation of several scenarios addressing balloon operations as a commercial operation (Terasaki 1992). Information contained in this chapter also applies to airships used for similar purposes and described in chapter seven. Banner tow operations are conducted primarily in areas where it is economically advantageous to do so. Nevertheless, the majority of U.S. airports have no experience with banner tow operations. In this study, few of the airports interviewed had incorporated minimum standards on banner towing because there was no expected demand for it. AIRSPACE ACCOMMODATION Any aircraft that tows anything into the air, other than a glider or unpowered ultralight vehicle, requires a waiver of regulations from the FAA (14 CFR 91, Part 91.113). Typical waiver requirements that affect airports are the following (FAA 2003): ⢠The certificate holder is to obtain the airport managerâs approval to conduct banner tow operations at each airport of intended operation. ⢠Notify appropriate airport officials in advance when banner tow operations will be in close proximity to each nontowered airport. ⢠If the airport involved has an FAA control tower, the holder is to inform the FAA control tower of the time of the banner tow operation. ⢠Banner pickup or banner drop should be in a pre-designated area not closer than 500 ft to taxi- ways, runways, persons, buildings, parked automobiles, and other aircraft whenever possible. If the tow plane lands with the banner attached, due care should be exercised to avoid obstacles and endangering other aircraft in the air or persons, property, or aircraft on the surface. ⢠Banner tow operations at airports will be conducted in accordance with ATC clearance or the local standard traffic pattern procedures established by airport management. AIRFIELD ACCOMMODATION Consideration for allowing banner tow operations on an airport primarily center on whether adequate space exists to conduct the activity safely. A banner can extend more than 250 ft in length. An aircraft climb performance dictates the necessary clear area for a successful banner lift. Based on the litera- ture search and interviews, the preferred banner operating area for airports is adjacent to a runway or taxiway that allows for a clear, obstacle-free approach and departure path for pickup and drop-off. chapter nine AERIAL ADVERTISING
48 Basic airport design standards suggest that the pickup and drop area be located a minimum of 250 ft from the centerline of an active runway, though it can be less at smaller design category GA airports. The distance allows for positioning the catch poles and staging personnel, vehicles, or equipment outside the runway safety areas, object-free areas, and object-free zones of an airport. Staging can be accomplished with from one to four individuals. NOTICES TO AIRMEN A NOTAM is generally a condition for obtaining a waiver. Sample NOTAMs are provided in Appendix G. SAFETY CONSIDERATIONS One of the risks with banner towing is the possibility of an emergency drop of the banner should the aircraft experience difficulty or should the banner malfunction. Identifying one or more secondary drop areas close to the pickup area is a best practice. For this reason, caution is suggested to minimize flying over taxiways. Another risk is the trailing aircraft hook catching on something other than the banner, such as a light fixture or sign. Access to the banner tow pickup and drop-off area can also be a safety consideration. Chapter fifteen contains an example of the Albert Whitted Airport in Florida having the banner area located where a primary runway and taxiway must be crossed for access. RELATED INFORMATION In a review of NTSB and FAA data, a news reporter found 191 banner-related accidents between April 1995 and July 2015 (Schroeder 2015). Not known is how many banner tow operations were conducted over that 20-plus-year period. Neither did the report identify the causes of the accidents or where they occurred (on the airport or away from the airport). A number of communities have sought to limit aerial advertising, primarily through enactment of ordinances that restrict aerial advertising over a particular area (276 F.3d 1109 2002; Weisberger 2008; Moore 2013; Riley 2013; Morales 2014). These efforts can conflict with established FAA preemption determinations that the federal government controls airspace. However, the issue is not fully clear, as evidenced by different rulings in court cases. The issue of free speech accommodation has also arisen in these cases (Namowitz 2013). Noise can be an issue for airports and the community, as the nature of banner tow operations requires high horsepower output to overcome the drag of the banner. Aircraft propellers are kept in high rpm and low pitch, which results in higher noise levels. Away from the airport, banner tow operators seek to maximize advertising effectiveness by flying at the lowest altitude allowed and continuously in a high viewing area. The FAA produces a number of documents that provide guidance to both aerial advertisers and airports. ⢠FAA/FS-I-8700-1 (FAA 2003) Information for Banner Tow Operations ⢠AC 00-61 (FAA 2000b) Event Planning Guide ⢠AC 91-45C (FAA 1990b) Waivers: Aviation Events The Information for Banner Tow Operations is an informative guide on banner tow operations (FAA 2003). It provides safety recommendations, lists procedures, and discusses the waiver require- ments needed when conducting operations.
