I tried searching with terms I think were correct around the net, but no satisfying results.

I have seem many times small planes circling around when there is some special event going on. They have advertising banners trailing behind them. For busy airspaces like the San Francisco bay area where you just have to glance up to spot a plane, how does this work with ATC?

Do these planes have to stay under certain level that is not controlled by ATC or ATC just allocates them a block of area and declares it off limits for others?

Do they have to declare their intention of circling special event areas given the security concerns and large gathering of people?


3 Answers 3


An aircraft conducting a banner towing operation must have prior approval (written letters of authorization) from any ATC authority they will be conducting operations prior to the banner tow operation. A copy of this letter must be carried on board the aircraft. The local FSDO must also be involved (which will handle the 7711-2 application).

The first thing you need to do is to file Form 7711-2 "Certificate of Waiver or Authorization Application" detailing all regulations which will be violated (minimum safe altitudes/separation, etc).


  • Conduct all banner tow operations in VFR weather conditions defined by Title 14 of the Code of Federal Regulations (14 CFR) part 91, section 91.155. Operations shall be conducted only between the hours of official sunrise and official sunset.

  • The certificate holder shall obtain the airport manager’s 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 non-towered airport.


Operations outside the geographic area of the issuing FSDO will be coordinated with the appropriate jurisdictional FSDO in advance and the operator will comply with all special provisions imposed by that office.


They would coordinate with ATC beforehand to fly low & slow near congested areas.

For example, go to skyvector.com and enter KSFO and KOAK as a flight. You can see all the controlled airspace, the levels it starts at and how high it goes. I don't know where the area you are discussing is in relation to the controlled airspace


It depends what airspace they are in. Typically most airports in major cities with class B and class C airspace have surface areas and then shelves extending out as far as 30 NM from the central airport. Below these shelves is either Class E and Class G airspace which either will not require ATC clearance to operate in or is uncontrolled altogether. Here, a banner tow aircraft can operate without a flight plan, or flight following with relative ease. If you look at the airspace around San Francisco, you’ll notice that most of it are shelves, which banner tow aircraftcan fly under

If banner tow ops are necessary within the surface areas, any licensed commercial pilot may operate in these areas with the appropriate ATC clearance and be equipped with a transponder with altitude reporting capability. Some major airports may request you pre arrange this flight with ATC prior to flight to allow controllers to anticipate flight activity by a banner towing aircraft and route their traffic accordingly.

  • $\begingroup$ If the pilot is not being compensated, the requirement drops down to a Private Pilot with 200 hours PIC, you don't have to be a commercial pilot necessarily. $\endgroup$
    – Ron Beyer
    May 10, 2018 at 19:54
  • $\begingroup$ Technically true, though very few, if any banner tow flights are private ventures. One can more or less assume they are commercial ventures. $\endgroup$ May 10, 2018 at 20:00

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