I haven't looked it up but if I recall my definitions the FAA does not
consider an ultralight vehical to be an Aircraft. While It may meet
the definiation of a glider, if meets the definition of an ultralight
the FAA does not reconginize it as an aircraft and as a result it does
not need to be registered, Certified or require a Pilot Certificate to
fly it.

I do not recall any regulation concerning towing of ultralight
vehicals so 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. They would have
to be careful not to be receiving any compensation for doing so.

I contacted the Spokane FSDO and spoke to Chuck Roberts (800-341-2623)
about this. He did not think there was any problem towing ultralights,
providing they were compatible with the tow plane (Vne). The
definition of glider and aircraft does not include any mention of
certification, so an ultra-light is an aircraft and an ultra-light
glider is a glider per the FARs. He did allow that the FARs do refer
to ultra-lights as "vehicles" instead of aircraft. He said the purpose
here is to prevent ultra-lights from becoming entangled with other
FARs that cover "aircraft". Chuck said that if you want to get the
issue resolved you can write him (or any FSDO) a letter requesting a
clarification of the FARs. This would then be forwarded to FAA legal
who would (eventually) issue a ruling. Also, the tow plane operator
can request a waiver to tow ultra-lights, but the waiver would only be
valid for that particular tow plane.

As far as insurance goes, if the FARs allow it and it isn't
specifically excluded in the policy then you are covered.

Tom Seim
Richland, WA