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Practically speaking, what should a pilot of a GA aircraft be doing differently when (if?) they have to fly through an area with a sUAS NOTAM?

I have flown (while in PPL training with a CFI) in a class D before with tower service and military drones. However, they were talking on airband and with a wingspan that was probably at least double that of my Cessna 150 so "see and avoid" would work, and they were in contact with the tower, and the tower kept us spaced apart.

In most cases, you could just fly around the NOTAM area. However, in the case where a drone is operating from an airport (which may be under special permission from the airport - the class D airport is apparently designated a special drone development area, and I believe the same is the case for the pictured scenario) a pilot will likely be sharing airspace with the drone.

VFR chart with a done NOTAM plotted at an airport

This pictured case is at an untowered airport. What must a pilot do to operate safely in this scenario and not be in violation of 91.13? Nothing in the NOTAM states the size of the drone, so I would assume they could be smaller than a person -- and thus very hard to see and avoid.

Should the GA pilot expect to coordinate over CTAF with the sUAS pilot, or would a sUAS pilot even be allowed to make calls on the airport CTAF? Or is that disallowed, like ADSB out for drones?

If the drones had ADSB out, and talked on CTAF, I would be comfortable as I have ADSB in. If they were the size of GA planes and talked on CTAF I would be careful but consider it the same risk as flying around other GA traffic that may or may not have ADSB out.

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  • $\begingroup$ In no way is this a complaint against the sUAS folks...I'd actually prefer flying around them as long as they are talk'n and sqwauk'n (ADSB out) over some (opinionated) NORDO GA guy that expects "see and avoid" to work 100% of the time. $\endgroup$
    – Azendale
    Commented Mar 6 at 3:50
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    $\begingroup$ Talking to the sUAS operator in this case, the necessity of being at this untowered airport comes from testing and calibrating a NAVAID based on the airport. They are working on a portable CATI precision landing system that can do curved approaches with the standard LOC & GS needles and a 3A/C transponder. They say it takes them about 2 hours to go from coming in on a trailer to having a full blown ILS and PAR. $\endgroup$
    – Azendale
    Commented Mar 6 at 15:14
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    $\begingroup$ I've asked about their system before: aviation.stackexchange.com/q/94343/25251. I'd like to be courteous and not in their way but would also love to try flying a "bent ILS" (in VMC under VFR rules of course). I figured maybe there was a standard way the NAS separates this traffic or maybe best practice for coordination rather than the "airspace never overlaps" approach, since it looks like it could overlap with the final for runway 25. This is at the KDLS airport. $\endgroup$
    – Azendale
    Commented Mar 6 at 16:05
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    $\begingroup$ I imagine that if I were in your situation if there weren't a lot of radio traffic on CTAF I might go ahead and ask on CTAF if the unmanned aircraft/drone operators are up on on frequency and able to transmit regarding deconfliction. Then you might be able to find out if what you want to do would inconvenience them. I think you could be confident that they'd stay clear of you regardless especially if you state all your intentions over CTAF; on an airport project like this they are almost certainly listening. $\endgroup$ Commented Mar 7 at 15:16
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    $\begingroup$ I'm really not sure about the details of the regs regarding someone on the ground transmitting on CTAF in a case like this, and to what extent they are strictly observed or sometimes "bent". Since the Dalles OR airport is in uncontrolled airspace all the way to the surface, my statement about the FAA possibly requiring CTAF transmissions as a condition of authorization for the sUAs operations, probably wouldn't pertain here. $\endgroup$ Commented Mar 7 at 15:20

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This is an issue that pilots will encounter more frequently in the future than in the past. For example, the Academy of Model Aeronautics (AMA) has negotiated a process with the FAA that allows modellers who are holding special events in Class G airspace with overlying Class E airspace to get permission to fly up the base of the overlying Class E airspace (typically 700' or 1200' AGL) rather than the generally-allowed 400' AGL, and the process involves the issuance of a NOTAM. Also, the special areas called "FRIAs" (Federally Recognized Identification Areas) where model airplanes and other sUAs will be exempted from the new "RID" (Remote Identification)1 requirements have NOTAMs associated with them if they are near airports.

You are right that the small size of many of these sUAs (think of a typical model airplane) makes them impractical to see and avoid. It is up to the sUA pilot to see and avoid full-scale traffic. (See for example 49 USC 44809 (a)(4), FAR 107.19(c), and FAR 107.37 (a) and (b).)

Should the GA pilot expect to coordinate over CTAF with the sUAS pilot, or would a sUAS pilot even be allowed to make calls on the airport CTAF?

A GA pilot should not expect to coordinate over CTAF with the sUA pilot. In some situations the sUA pilot may be monitoring CTAF-- the FAA has actually made this a condition of some of the special permits it has issued to allow modellers to fly as high as 2000' AGL at some locations. But this should not be assumed to be the case generally. As to whether it would even be legal for a sUA pilot to transmit on a CTAF frequency to enhance the safety of full-scale aircraft-- that would likely be dependent upon whether or not the FAA has specified that such transmissions be made as a condition of the authorization for the mission.2

What you should do is just operate normally. In the vicinity of an airport, you could enhance safety by sticking to the normal traffic patterns and not doing anything too unusual. If you happen to observe an sUA being flown in a manner that you believe to be unsafe, be sure to note your exact altitude and whether the sUA is above or below you, as well as making your best estimate of the sUAs altitude and location, and whether it appears to be a quadcopter/multicopter or a more traditional winged aircraft, so that you can submit an accurate report.

Of course, it also goes without saying that you should pay attention to the altitude ceiling listed in the NOTAM. In the particular case in your image, it was only 400' AGL, so if you are flying circuits in the pattern at that airport, you'll be over that altitude much of the time.

Keep in mind that the FAA makes no distinction between "sUAs" (small Unmanned Aircraft or small Unmanned Aircraft Systems) and model airplanes, and model airplanes have been safely sharing the skies with full-scale airplanes for many many decades, often ranging up to 600' to 800' AGL, or much higher for some particular disciplines (e.g. soaring where 2000' AGL would not be at all unusual). You just didn't know that they were there. In the past the FAA has issued various recommendations that model airplanes stay below 400' AGL but these were generally not codified into actual regulations, and were often ignored by many modellers who knew that they could safely operate much higher with no appreciable risk to full-scale aircraft. 49 USC 44809, the "Special Exception for Limited Recreational Operations of Unmanned Aircraft", became law in 2018 and tightened things up in this regard, and the special permissions that the FAA sometimes now issues to deviate from this law sometimes involve the issuance of a NOTAM. Within controlled airspace, the Special Exception allows the FAA to specify altitudes much lower than 400' as the ceiling for sUA operations, and again, special permissions to exceed these specified altitudes may involve NOTAMs.

In summary, sUAs operations for various commercial purposes are certainly becoming more common and will undoubtedly continue to do so, but another factor causing sUAs-related NOTAMs to appear with increasing frequency is the fact that the FAA has promulgated new regulations which now cause NOTAMs to be generated in relation to traditional model airplane flying at some locations where these hobby activities have already been going on unchanged for many decades. In either situation, it is the responsibility of the sUAs "operator" to avoid full-scale aircraft.

Footnotes:

  1. In its current form, RID or "Remote ID" is a device that transmits a signal that allows law enforcement or other parties to identify a sUA in flight. Think of it like an electronic license tag. It does not facilitate in-flight avoidance of the sUA by other sUAs or by full-scale aircraft, though this concept was part of the original proposal NPRM.

  2. Both FAR Part 107 and 49 USC 44809, the "Special Exception for Limited Recreational Operations of Unmanned Aircraft", require "prior authorization" for sUAs flights in controlled airspace. Sometimes this authorization is delivered by an automated on-line system called "LAANC", or provided by standing Letters of Authorization with local ATC for operations at specific "Fixed Sites". The FAA is free to set whatever conditions it desires, including altitude limits, as a condition of such authorization.

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