On Wed, 4 May 2005 11:19:24 -0400, "TaxSrv" wrote
in ::

"Larry Dighera" wrote:
...
I believe a waiver is only necessary for airmen who
don't hold a Commercial Certificate or ATP.

The waivers I've seen obtained by my friend in this business and his
pilots I believe say a commercial certificate is required. Whether or
not they would issue a waiver to a private pilot, thus for
noncommercial activity, would be a question to be posed to the FSDO.

Given:

§ 91.311 Towing: Other than under §91.309.

No pilot of a civil aircraft may tow anything with that aircraft
(other than under §91.309) except in accordance with the terms of a
certificate of waiver issued by the Administrator.

It would appear that any towing by any pilot with the exception of
Gliders and unpowered ultralight vehicles requires a waiver.