AIM ¶ 11-3-1 — Large Public UAS Operations
AIM 11-3-1 explains large public UAS operations, DoD groups, airspace use, transponders, and ATC procedures pilots should know for checkrides.
In Plain English
Large public UAS (think military drones like the MQ-9 Reaper or RQ-4 Global Hawk) can be as big as airliners and often operate from public/military dual-use airfields. Because they typically climb quickly to and operate at very high altitudes under positive ATC control, civil pilots rarely encounter them.
Key points for student pilots:
- Public aircraft operators are responsible for their own airworthiness and pilot qualifications, but the UAS PIC must still comply with all ATC instructions using standard phraseology.
- The DoD UAS classification system has 5 groups based on max gross weight, altitude, and speed. Groups 1–3 stay near military bases or in restricted/prohibited airspace. Groups 4 and 5 are the largest (>1,320 lbs); Group 4 usually operates below 18,000 ft MSL, Group 5 well above.
- Large UAS typically operate IFR, are transponder-equipped, and are separated from other traffic by ATC.
- Per 14 CFR 91.215(e)(2), a Part 91 unmanned aircraft may only operate with a transponder on if on a flight plan with two-way ATC comms, or if otherwise authorized.
- Per 14 CFR 107.52, sUAS under Part 107 may not operate with a transponder on unless authorized.
- Launch/recovery uses TFRs; en route ops use MOAs, restricted, warning, and alert areas.
AIM Source Text
FAA AIM ¶ 11-3-111-3-1. 11-3-1. Large Public UAS Operations
Large public UAS may have wingspans as large as commercial airliners, and may operate in and out of public/military dual-use airfields. Due to the high altitudes at which these UAS routinely operate, and the means through which they reach and vacate operating altitudes, encounters with manned or low-altitude unmanned traffic are rare. Public users operating as “public aircraft” retain the responsibility to determine airworthiness and pilot qualifications. Aircraft certification and operating rules apply to the entire UAS, including the aircraft itself, the flight crew with their associated qualifications, the control station, and command and control links. NOTE- Large UAS operating in controlled airspace generally communicate on radio frequencies or through an ATC-to-PIC ground communications link assigned to that sector, terminal area, or control tower. The UAS PIC is required to comply with all ATC instructions and uses standard phraseology per FAA Order JO 7110.65, Air Traffic Control, and this manual. REFERENCE- 49 USC 40102, Definitions. 49 USC 40125, Qualifications for Public Aircraft Status. FAA Order JO 7110.65, Air Traffic Control. AIM, Para 11-4-3, Airspace Access for Public Aircraft Operations PAO. Operating characteristics of large public UAS. To illustrate the sizes and performance of large public UAS, consider the DoD UAS classification system. The categories (see FIG 11-3-1 ) are separated based on MGOW, normal operating altitude, and flying speed. These classifications do not apply to non-DoD civil aircraft. Generally, Groups 1 through 3 UAS will operate on and above military bases, in restricted or prohibited airspace. For this reason, these smaller tactical public aircraft will rarely be encountered by civil pilots. Groups 4 and 5 are the largest of DoD UAS, weighing over 1,320 pounds, and operating at all speeds and altitudes. Group 4 aircraft operate at all altitudes, usually below 18,000 feet MSL. Group 5 aircraft typically operate well above 18,000 feet MSL. UAS in Groups 4 and 5 require airfields with specially approved surfaces to safely operate. For specifications and descriptions of the aircraft models that the DoD operates, refer to military service fact sheets. NOTE- The category chart does not specify the actual high gross weights at which some DoD UAS actually operate. For instance, the RQ-4 Global Hawk regularly operates at approximately 32,000 pounds.) JP 3-30, III 31, Joint Publication 3-30, provides the UAS Categorization Chart and may be reviewed at: https://www.jcs.mil/Portals/36/Documents/Doctrine/pubs/jp3_30.pdf?ver=2019-09-04-142255-657 . These websites provide unclassified descriptions, performance, and specifications of the varied UAS in the DoD's large category fleet: USAF Fact Sheets at https://www.af.mil/About-Us/Fact-Sheets/ and USN Fact Files at https://www.navy.mil/Resources/Fact-Files/ . FIG 11-3-1 DoD UAS Categories Large Public UAS Engineering Characteristics and Operating Areas: Large public UAS may be sharing airspace with civil aircraft in the NAS. A wide variety of aircraft performance, voice radio communications, command and control link architecture, and operating procedures exists throughout the DoD and other large public UAS enterprises. For example, Group 4 DoD aircraft, such as the MQ-1 Predator and MQ-9 Reaper, are typically propeller-driven with propulsion units that are internal combustion piston- or turbine-powered. The largest public UAS include single-engine jet aircraft such as the RQ-4 Global Hawk and MQ-4C Triton. VLOS and BVLOS link systems provide command and control for these large UAS operations. Voice communication capability in the largest public UAS is far more extensive than in the smaller aircraft. Many models are limited to a single voice radio transmitter and receiver system for control inside airspace managed by and/or delegated to the DoD. Many of the larger public UAS are equipped with transponders to assist ATC with position and tracking information. These UAS usually operate under IFR under positive ATC control and will tend to be found at very high altitudes; not likely to be encountered by civil aircraft operators. Launch and recovery operations will be likewise under positive ATC control and these UAS will be separated from any other known aircraft traffic. Encounters with low-altitude small UAS, being flown in uncontrolled airspace or under low-altitude controlled airspace authorizations, are therefore unlikely. In accordance with 14 CFR section 91.215(e)(2), ATC Transponder and Altitude Reporting Equipment and Use, no person may operate an unmanned aircraft under part 91 with a transponder on unless: (1) the operation is conducted under a flight plan and the person operating the unmanned aircraft maintains two-way communications with ATC; or (2) the use of a transponder is otherwise authorized by the Administrator. NOTE- In accordance with 14 CFR section 107.52, ATC Transponder Equipment Prohibition, unless otherwise authorized by the Administrator, no person may operate a sUAS under part 107 with a transponder on. REFERENCE- 14 CFR Section 91.215, ATC Transponder and Altitude Reporting Equipment and Use. 14 CFR Section 107.52, ATC Transponder Equipment Prohibition. Large Public UAS Launch, Recovery, and Operating Areas: Large public UAS operations are widespread, they are also carefully managed to ensure enhanced safety for other NAS users. For this reason, DoD UAS operate in many types of special use airspace. See FIG 11-3-2 for examples of Special Use Airspace (SUA) used by DoD UAS. FIG 11-3-2 DoD Special Use Airspace Temporary Flight Restrictions (TFRs) are issued for the surrounding UAS operating locations and allow for the launch and recovery of larger UAS. Once outside of the terminal environment, DoD UAS utilize the full range of SUA, including Military Operating Areas (MOA), restricted areas, warning areas, and alert areas to conduct their missions.
Oral Exam Questions a DPE Might Ask
Q1Who is responsible for airworthiness and pilot qualifications of a public UAS, and must they still follow ATC instructions?
Per AIM 11-3-1, public aircraft operators retain responsibility for determining airworthiness and pilot qualifications. The UAS PIC is still required to comply with all ATC instructions using standard phraseology per FAA Order JO 7110.65.
Q2Where would you most likely encounter large DoD UAS, and why are civil encounters rare?
Per AIM 11-3-1, large DoD UAS (Groups 4 and 5) operate from specially approved airfields, typically IFR under positive ATC control at very high altitudes, with launch/recovery protected by TFRs and missions flown in special use airspace such as MOAs, restricted areas, warning areas, and alert areas — making encounters with civil aircraft unlikely.
Q3Under what conditions may an unmanned aircraft operate with a transponder turned on?
Per AIM 11-3-1 (citing 14 CFR 91.215(e)(2)), no person may operate a Part 91 unmanned aircraft with a transponder on unless the operation is conducted under a flight plan with two-way ATC communications, or use of the transponder is otherwise authorized by the Administrator. Under Part 107 (14 CFR 107.52), sUAS may not operate with a transponder on unless authorized.
Related Paragraphs in AIM Chapter 11