Commercial Rating for Towing Gliders not needed? in US

On Nov 2, 10:59*pm, T wrote:
On Nov 2, 8:51*pm, Tony wrote:



If you look to the history of 61.113 and Pvt Pilot Priviledges,
paragraph (g) was written to allow Pvt Pilots to count the hours as
tow pilot in their logbooks towards additional ratings. FAA did
consider that accumulation of free hours was non monetary compensation
and not allowed before the rewrite of 61.113(g).

The only "except as proivided in (b) thru (g)" that includes
compensation is (b)

I'll stand that paragraph 61.113(g) states that a Pvt Pilot may act as
PIC for tow operations, he may not be compensated for it.

T

I'm confused. *You first say that (g) allows a private pilot to
receive compensation (flight time towards a rating) but then you still
believe that a private pilot can tow but not be compensated for it?

are you trying to delineate between monetary and non-monetary
compensation? attempting to determine what you think the FAA's intent
was with a reg instead of what they wrote?

Yes.. we are delineating between monitary and non-monitary.
The FAA had determined, and rewrote 61.113(g) in the early 90s to
reflect that (I think it was 1994)
That's why I said it was not allowed.. BEFORE THE REWRITE,, I believe
then it was 61.118 in 1990.
The FAA, with the help of SSA , determinded that a private pilot
logging hours for glider tow, was not compensation.
We are looking for that letter.

T

gotcha. I thought this discussion sounded familiar and sure enough we
went through it on the Pilots of America forum last year.
http://www.pilotsofamerica.com/forum...317#post539317

The eventual conclusion by some there after 5 or so pages of
discussion seemed to be that they determined that the intent of the
FAA was to allow for logging of flight time by private pilots but that
they shouldn't be able to get paid money. Thats all fine and well
with me but I really think the FAA should've just spelled that out in
the regulation instead of using the blanket "compensation" which we
all know can mean flight time or money or any other sort of
compensation.

I recall that at one time, in the last few years, the SSA got a ruling
(and published), a letter from the FAA, regarding Pvt. Pilot Tow
pilots. The ruling basically said that flight time for Pvt Pilots
towing gliders in a club was not to be considered as "compensation"
and that a Commercial license was not required to tow. I can't recall
what was ruled for the commercial operation or commercial rides in a
club.

I spent some time looking around the SSA site but was not able to find
the letter. Does any one else remember it and know where it is
located?

Mike

The history is as follows:

Before the rewrite of Part 61 by John Lynch of the FAA more than a few
years ago, the SSA used to apply for and receive an exemption from the
FAA to allow SSA member clubs to use private pilots as tow pilots where
the clubs where charging members for tows. The exemption was in the form
of the letter from the FAA to the SSA and had to be renewed every two
years, creating a lot of red tape for both the FAA and the SSA.

At that time, the FAA interpreted the regulation to mean that a private
pilot getting free stick time while towing for a club was receiving
compensation which was prohibited by the regs then in effect. The
exemption granted to the SSA by the FAA allowed private pilots towing
for an SSA club to tow when the club was charging members for the tow
but it prohibited the private pilot from logging the time and using it
to count towards a higher rating.

The rationale for the FAA came from 30's era regulatory thinking that
commercial pilots had to be protected from competition in order to
foster the growth of aviation.

Both the SSA and the FAA eventually got tired of the biennial exemption
renewal process. The result was substantially the language in 61.113 we
now have. There was one minor tweak later on to include the towing of
unpowered ultralight vehicles.








--

Pete Brown
Anchorage Alaska

Going home after a long day
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The fleet at Summit. Mt. McKinley is about 45nm away at 20,320 msl.
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The 170B at Bold near Eklutna Glacier
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In article Tony writes:

gotcha. I thought this discussion sounded familiar and sure enough we
went through it on the Pilots of America forum last year.
http://www.pilotsofamerica.com/forum...317#post539317

The eventual conclusion by some there after 5 or so pages of
discussion seemed to be that they determined that the intent of the
FAA was to allow for logging of flight time by private pilots but that
they shouldn't be able to get paid money. Thats all fine and well
with me but I really think the FAA should've just spelled that out in
the regulation instead of using the blanket "compensation" which we
all know can mean flight time or money or any other sort of
compensation.


Tony,

This was also discussed in some detail in this newsgroup in March, 2009,
under the subject "Commercial vs Private, towing" .

Cindy Brickner wrote a fairly complete description of the steps in that
thread.

When the FAA tired of issuing waivers (which said the time could not be
used for further ratings), they changed the rules and specifically said
the time could be accrued as legitimate compensation.

(Quoting Cindy here)
In 2004, FAA rewrote Part 61 again, to include towing of ultralight
vehicles under Sport pilot and Light Sport Aircraft rules. At that
time, in the comments of adoption, the FAA stated that Private pilots
were indeed allowed to tow gliders for compensation and hire (their
words, not mine). But the FAA declined to extend that privilege to
Sport or Recreational pilots. The FAA referred to 61.113(g).
(end quote)

From those steps, it seems that they did intend to allow Private pilots
to be paid based on the comments of adoption that Cindy mentioned. The
conclusion of discussions here, or in pilotsofamerica.com, would seem to
have less relevance to the rules than the written text of the rules and
the comments released by the FAA when the rules were put into place.


You were indeed correct, though, that this had been discussed before,
apparently more than once.

Alan