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#11
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(a) says someone without a commercial license can't be paid to be PIC
unless he falls under one of the exceptions, and (g) provides an exception for towpilots. So a towpilot without a commercial license can be paid. I don't see how it can be interpreted in any other way. BTIZ wrote: Pete.. read 61.113(a) again please... it says private pilots may not act as PIC nor be Compensated except as in b through g... so... para G exempts him from the PIC limitation, but not from the compensation. BT "Pete Brown" wrote in message ... 61.113 (a) lays out the general prohibitions against private pilots flying for compensation, subject to the exceptions laid out in paragraphs (b) through (g). Read the plain language for what it says. Towing is one of the exceptions to 61.113(a) which only discusses piloting for compensation. If a private pilot could not be paid for towing, there would be no need whatsoever for paragraph (g). It would be excluded by 61.113(a). FAA inspectors are bound by the language, not whether they agree with or like the regulation. Pete Brown BTIZ wrote: "T o d d P a t t i s t" wrote in message 1) The wording in § 61.113(g) is quite clear and allows a private pilot to tow for compensation. no it is not clear... and that is the issue... 61.113(a) says a private pilot cannot act as PIC nor receive compensation except as provided in (b) through (g) (b) through (f) cover various circumstances when a private pilot may share pro rata expenses, be reimbursed for cost, fly as PIC for charity events etc, and fly as "incidental" to a business, but it never says he can be paid to be a pilot. (g) says he can be PIC for towing, it does not say he can get paid to do it. Sooo... (a) says he cannot be PIC of an aircraft carrying passengers or cargo except for (g), and (g) says he can be PIC for towing, it does not say he can be compensated. I've heard these comments about Mr Lynch in the past, and if his information is so bad, then why does the FAA keep updating it on their official gov web page? -- Peter D. Brown http://home.gci.net/~pdb/ http://groups.yahoo.com/group/akmtnsoaring/ |
#12
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IIRC, the 'intent' was to allow 'free' flying while towing, irrespective of
whether the time logged was for another rating. Previously that was considered 'indirect' compensation and wasn't allowed. Lynch's intent was to allow time building toward another rating without direct compensation. Direct compensation still requires a commercial rating and there was no intent to change that. However, the verbage was munged so badly that there was a FAQ created and still it's unclear and remains unrevised. I've heard comments that seem to indicate that there are some FBO's allowing (or having allowed) private tow pilots to fly without direct compensation. That may be limited to instructional flights only, where the commercial activity is clearly in the glider end of the rope. It may not be compliant with tow for hire insurance coverage. My own club carries tow for hire coverage so we can tow non-member gliders or tow in local competitions. We do allow private tow pilots to tow members only. The FAA rule is obscure at best. Lynch is long since retired I believe. Frank Whiteley "Greg Arnold" wrote in message news:jEGHd.12903$ru.1384@fed1read07... (a) says someone without a commercial license can't be paid to be PIC unless he falls under one of the exceptions, and (g) provides an exception for towpilots. So a towpilot without a commercial license can be paid. I don't see how it can be interpreted in any other way. BTIZ wrote: Pete.. read 61.113(a) again please... it says private pilots may not act as PIC nor be Compensated except as in b through g... so... para G exempts him from the PIC limitation, but not from the compensation. BT "Pete Brown" wrote in message ... 61.113 (a) lays out the general prohibitions against private pilots flying for compensation, subject to the exceptions laid out in paragraphs (b) through (g). Read the plain language for what it says. Towing is one of the exceptions to 61.113(a) which only discusses piloting for compensation. If a private pilot could not be paid for towing, there would be no need whatsoever for paragraph (g). It would be excluded by 61.113(a). FAA inspectors are bound by the language, not whether they agree with or like the regulation. Pete Brown BTIZ wrote: "T o d d P a t t i s t" wrote in message 1) The wording in § 61.113(g) is quite clear and allows a private pilot to tow for compensation. no it is not clear... and that is the issue... 61.113(a) says a private pilot cannot act as PIC nor receive compensation except as provided in (b) through (g) (b) through (f) cover various circumstances when a private pilot may share pro rata expenses, be reimbursed for cost, fly as PIC for charity events etc, and fly as "incidental" to a business, but it never says he can be paid to be a pilot. (g) says he can be PIC for towing, it does not say he can get paid to do it. Sooo... (a) says he cannot be PIC of an aircraft carrying passengers or cargo except for (g), and (g) says he can be PIC for towing, it does not say he can be compensated. I've heard these comments about Mr Lynch in the past, and if his information is so bad, then why does the FAA keep updating it on their official gov web page? -- Peter D. Brown http://home.gci.net/~pdb/ http://groups.yahoo.com/group/akmtnsoaring/ |
#13
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![]() "Pete Brown" wrote in message ... Safety was not the issue. Huh? Commercial pilots are tested to a higher standard and must have more flight hours to even qualify to be tested. I agree that pilot competency is a very individual thing, but having passed the requirements for the Commercial does establish a certain minimum. Vaughn |
#14
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At 05:30 20 January 2005, Pete Brown wrote:
(yada yada yada) In the old days, prior to the rewrite the SSA had an exemption, much like the data plate exemption, that allowed towing by private pilots for compensation by SSA chartered clubs. (Up to that point, compensation, as defined by the FAA, included the logging of time even if the pilot was not paid.) I don't believe there ever was an 'exemption' per se, but an understanding by John Lynch and his predecessors in the General/Commercial division at FAA. IIRC, logging flight time surfaced as a 'compensation' issue in the context of drug testing rules from which soaring operators were excluded in 1988/89. I believe 61.113(g) was intended to codify the intent that tow pilots - particularly those active in club operations - need not be commercial rated if 'compensation' is limited to the logging of flight time. Lynch (who has not retired, but was on a leave of absence for military duty last year) phrased it in the October 2004 edition of the Part 61 FAQ: 'Q&A 619 § 61.113(g); Yes. . . A private pilot who meets the requirements of § 61.69 of this part may act as pilot in command of an aircraft towing a glider . . And yes, a private pilot who meets the requirements of §61.69 of this part may log pilot in command flight time while towing a glider. That is what was intended when paragraph § 61.113(g) was drafted into Part 61. Later in the same document, Lynch explains with respect to § 61.113(g): 'The answer is no, a private pilot may not receive compensation for towing a glider. The intent, and the wording of the § 61.113(g), was to permit a private pilot who meets the requirements of § 61.69 of this part to “. . . act as pilot in command of an aircraft towing a glider” for the purpose of logging pilot in command (PIC) time. The new rule was never intended to conflict with the FAA’s long standing legal interpretations and policies on compensation for private pilots. And the wording of the § 61.113(g) only addresses the issue that permits a private pilot to “. . . act as pilot in command of an aircraft towing a glider” for the purpose of permitting a private pilot to log pilot in command time. As you recall, the wording of the old § 61.69 permitted a private pilot to act as a PIC but was moot on logging the time. The § 61.113(g) was issued to correct it. However, we agree the wording of the § 61.113(a) may be confusing. In the next go-around on correcting some of the wording mistakes, we have recorded it as a needed correction to conform the intent and the wording of § 61.113(g).' Judy The rewrite in 1997(?) of Part 61 was supposed to eliminate the need for the towing exemption. All they did was further confuse the issue. Pete -- Peter D. Brown http://home.gci.net/~pdb/ http://groups.yahoo.com/group/akmtnsoaring/ |
#15
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Vaughn:
I agree that tow pilots must have a much higher degree of competency and experience and 61.69 established the higher standards for knowledge, experience and training that the FAA thought necessary for glider towing. The FAA thought it important that tow pilots know about speeds, safety matters , and signals etc, that are pertinent to glider operations, none of which subjects are covered in the training for commercial pilots. That's one of the primary reasons that a tow pilot must get ground and flight training by a CFIG and make at least three tows while accompanied by a tow "qualified" pilot. The FAA's assumption is that certificated pilots can fly airplanes but don't know much about glider ops without additional training. Hence it requires the the training and experience that is unique to gliders towing ops. Have you ever been towed by a thoroughly competent commercial pilot who strictly maintains the runway heading in a stiff crosswind instead of drifting downwind (when field conditions permit) because he is unaware of the complications for a glider in the event of a low rope break ? Or been dragged down wind too far because the pilot is not as sensitive to those conditions as we glider pilots? The FAA further requires a unique towing currency provision for tow pilots. A tow pilot towing every day for a year must make at least three flights while accompanied by "qualified" tow pilot or make three flights as PIC in a glider to remain current for the coming year. Flying commercially every day as a charter pilot or shooting instrument approaches does not solve the legal or practical requirements of maintaining tow pilot currency. All of these requirements reflect the fact that the FAA appropriately recognized that towing required a unique set of skills and experience. Vaughn wrote: "Pete Brown" wrote in message ... Safety was not the issue. Huh? Commercial pilots are tested to a higher standard and must have more flight hours to even qualify to be tested. I agree that pilot competency is a very individual thing, but having passed the requirements for the Commercial does establish a certain minimum. Vaughn -- Peter D. Brown http://home.gci.net/~pdb/ http://groups.yahoo.com/group/akmtnsoaring/ |
#16
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At a local club the board uses a mix of private and higher
licensed, and tow qualified pilots, to tow their club gliders, without compensation. I've never heard so much as a peep out of the FSDO about this. Is there anyone who has ever, in the history of flight, had an enforcement action for getting flight time, and only flight time, while towing a glider (commercially or not)? If not, isn't this just a little bit academic? Look, I love a good magnifying glass as much as the next guy, but I'm guessing the FAA cares not even a whit. The insurance companies are doing a much better job enforcing and "fining" violators than the FSDO ever will... Oh, in my honest opinion ![]() In article , Judy Ruprecht wrote: At 05:30 20 January 2005, Pete Brown wrote: (yada yada yada) In the old days, prior to the rewrite the SSA had an exemption, much like the data plate exemption, that allowed towing by private pilots for compensation by SSA chartered clubs. (Up to that point, compensation, as defined by the FAA, included the logging of time even if the pilot was not paid.) I don't believe there ever was an 'exemption' per se, but an understanding by John Lynch and his predecessors in the General/Commercial division at FAA. IIRC, logging flight time surfaced as a 'compensation' issue in the context of drug testing rules from which soaring operators were excluded in 1988/89. I believe 61.113(g) was intended to codify the intent that tow pilots - particularly those active in club operations - need not be commercial rated if 'compensation' is limited to the logging of flight time. Lynch (who has not retired, but was on a leave of absence for military duty last year) phrased it in the October 2004 edition of the Part 61 FAQ: 'Q&A 619 § 61.113(g); Yes. . . A private pilot who meets the requirements of § 61.69 of this part may act as pilot in command of an aircraft towing a glider . . And yes, a private pilot who meets the requirements of §61.69 of this part may log pilot in command flight time while towing a glider. That is what was intended when paragraph § 61.113(g) was drafted into Part 61. Later in the same document, Lynch explains with respect to § 61.113(g): 'The answer is no, a private pilot may not receive compensation for towing a glider. The intent, and the wording of the § 61.113(g), was to permit a private pilot who meets the requirements of § 61.69 of this part to “. . . act as pilot in command of an aircraft towing a glider” for the purpose of logging pilot in command (PIC) time. The new rule was never intended to conflict with the FAA’s long standing legal interpretations and policies on compensation for private pilots. And the wording of the § 61.113(g) only addresses the issue that permits a private pilot to “. . . act as pilot in command of an aircraft towing a glider” for the purpose of permitting a private pilot to log pilot in command time. As you recall, the wording of the old § 61.69 permitted a private pilot to act as a PIC but was moot on logging the time. The § 61.113(g) was issued to correct it. However, we agree the wording of the § 61.113(a) may be confusing. In the next go-around on correcting some of the wording mistakes, we have recorded it as a needed correction to conform the intent and the wording of § 61.113(g).' Judy The rewrite in 1997(?) of Part 61 was supposed to eliminate the need for the towing exemption. All they did was further confuse the issue. Pete -- Peter D. Brown http://home.gci.net/~pdb/ http://groups.yahoo.com/group/akmtnsoaring/ -- ------------+ Mark J. Boyd |
#17
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![]() "Pete Brown" wrote in message ... Vaughn: I agree that tow pilots must have a much higher degree of competency and experience Good! and 61.69 established the higher standards for knowledge, experience and training that the FAA thought necessary for glider towing. Then the FAA didn't think much (more below). The FAA thought it important that tow pilots know about speeds, safety matters , and signals etc, that are pertinent to glider operations, none of which subjects are covered in the training for commercial pilots. That's one of the primary reasons that a tow pilot must get ground and flight training by a CFIG and make at least three tows while accompanied by a tow "qualified" pilot. Three tows ain't much! The FAA's assumption is that certificated pilots can fly airplanes but don't know much about glider ops without additional training. Hence it requires the the training and experience that is unique to gliders towing ops. Have you ever been towed by a thoroughly competent commercial pilot who strictly maintains the runway heading in a stiff crosswind instead of drifting downwind (when field conditions permit) because he is unaware of the complications for a glider in the event of a low rope break ? Or been dragged down wind too far because the pilot is not as sensitive to those conditions as we glider pilots? Damn right I have! The FAA further requires a unique towing currency provision for tow pilots. A tow pilot towing every day for a year must make at least three flights while accompanied by "qualified" tow pilot or make three flights as PIC in a glider to remain current for the coming year. Again, not much Flying commercially every day as a charter pilot or shooting instrument approaches does not solve the legal or practical requirements of maintaining tow pilot currency. Nor does shooting touch & goes or taking $100.00 hamburger flights in your typical Cezzna. All of these requirements reflect the fact that the FAA appropriately recognized that towing required a unique set of skills and experience. The reality is that it takes far more than three tows to produce a competent tow pilot. 61.69 provides a bare minimum of training. I would not think of sending one of my solo students up behind a new tow pilot (Private, Commercial, ATP, whatever) who had just shown up at the field and barely complied with 61.69. Would you? Actually; I have virtually no disagreement with what you have written above, and agree that any given Private pilot might easily be a better tow pilot than any given Commercial. That said, the reality is that I would rather have an unknown Commercial pilot on the front of my tow rope than an unknown Private pilot because the Commercial pilot has been trained to a higher standard and probably has more experience. I have had some wild tows in my life and that is something I can happily live without. Don't get me wrong, in a club situation I could be happy and honored to tow behind a good Private pilot, particularly one that was also a glider pilot. But It *IS* about safety. Vaughn petency is a very individual thing, but having passed the requirements for the Commercial does establish a certain minimum. Vaughn -- Peter D. Brown http://home.gci.net/~pdb/ http://groups.yahoo.com/group/akmtnsoaring/ |
#18
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My own club carries tow for hire coverage so we
can tow non-member gliders or tow in local competitions. We do allow private tow pilots to tow members only. The FAA rule is obscure at best. Lynch is long since retired I believe. Frank Whiteley Frank, I have been instructed the same by our insurance carrier.. probably the same carrier.. the same thing.. if we even add the "CAP" clause, the tow pilot for "commercial tow" must be Commercial rated, the only Pvt tow pilot we have, could only tow club members. BT |
#19
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Vaughn wrote:
"Pete Brown" wrote in message That's one of the primary reasons that a tow pilot must get ground and flight training by a CFIG and make at least three tows while accompanied by a tow "qualified" pilot. Three tows ain't much! It's worse than this. You don't need three tows. You can do three "simulated tows" instead to become qualified. This is how I was initially "qualified." Got the endorsements to prove it. Saved $100 on the insurance increase for adding a tow pilot. Yee-ha! After that I did enough tows to ensure I knew I could do at least the basics of towing... Of course I did this with supervision. The experienced tow pilot sat in the right seat. ![]() tow and made him do it. :P I sure wouldn't tow no "first solo" student, or a ballasted ship, as my very first tow, or even my first dozen. But there ARE tow syllabi and good towpilot mentors that can get a pilot to the level that with an experienced glider guy behind him, he'll be safe enough to tow with reasonable safety. IMHO, right? Otherwise it looks like we'll need to invest in some wenches instead... -- ------------+ Mark J. Boyd |
#20
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I believe it's only legal in Nevada to invest in wenches!
![]() Almost springtime! Larry Mark James Boyd wrote: Vaughn wrote: "Pete Brown" wrote in message That's one of the primary reasons that a tow pilot must get ground and flight training by a CFIG and make at least three tows while accompanied by a tow "qualified" pilot. Three tows ain't much! It's worse than this. You don't need three tows. You can do three "simulated tows" instead to become qualified. This is how I was initially "qualified." Got the endorsements to prove it. Saved $100 on the insurance increase for adding a tow pilot. Yee-ha! After that I did enough tows to ensure I knew I could do at least the basics of towing... Of course I did this with supervision. The experienced tow pilot sat in the right seat. ![]() tow and made him do it. :P I sure wouldn't tow no "first solo" student, or a ballasted ship, as my very first tow, or even my first dozen. But there ARE tow syllabi and good towpilot mentors that can get a pilot to the level that with an experienced glider guy behind him, he'll be safe enough to tow with reasonable safety. IMHO, right? Otherwise it looks like we'll need to invest in some wenches instead... -- ------------+ Mark J. Boyd |
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