It could be argued that as far as the regulations are
concerned there are no tow pilot requirements for towing ultralight
vehicals. As such a newly licensed recreational Pilot might be able

to

Tow ultralight vehicals with no endorsements required.



Again, on the contrary, 14 CFR 91.311 requires an exemption to use an
aircraft to tow anything other than a glider, and a glider can only be
towed subject to the relevant requirements.


It looks like the USHGA has an exemption No. 4144 from the FAA that
covers the towing of unpowered ultralight aircraft by powered ultralight
aircraft where both aircraft would be operating under part 103 There
are a lot of requirements spelled out under the USHGA rules part 104
that cover required pilot training and also related to equipment and
which the exemption requires be met. See:

http://www.ushga.org/104-part-2.asp#4144

The case where a towplane operating under part 61 and 91 would be towing
an unpowered ultralight that was not registered, and therefore operating
under part 103, would appear to have been not accounted for under either
part 103 or part 61 and 91 and likely appears to be not allowed without
another waiver, at least on the part of the towplane operating under
part 61 and 91.



It does seem to me that the FAA wanted to stay away from having
anything to do with ultralight vehicles, and probably didn't have in
mind the possibility that one might be towed by a certificated
aircraft. So certainly if substantial amounts of common sense aren't
applied by pilots themselves and people start towing hang gliders with
Pawnees, the FAA is likely to feel compelled to step in. Hang glider
pilots, in general, seem to have a fair understanding of what would
happen to a flexwing towed at 70 knots, and Pawnee pilots probably
have enough common sense not to try it, but then again to paraphrase
someone or other, no-one ever got rich by over-estimating the
intelligence of the public...


This is almost exactly what they say in U.S. DOT FAA Advisory Circular 103-7
see http://www.ultralighthomepage.com/AC103-7/ac103-7.html

They mainly care about protecting the non-flying public, and other
members of the flying public using the same airspace, but:

"Part 103 is based on the assumption that any individual who elects
to fly an ultralight vehicle has assessed the dangers involved and
assumes personal responsibility for his/her safety."

" e. You are Responsible for the Future Direction the Federal
Government Takes
With Respect to Ultralight Vehicles, The actions of the ultralight
community
will affect the direction Government takes in future regulations.
The safety
record of ultralight vehicles will be the foremost factor in
determining the need
for further regulations."