Can a Private Pilot be Compensated for Towing Gliders?

Not so long ago, a private pilot could only act as PIC while towing gliders as long as he wasn’t receiving any form of compensation; including the logging of flight time. This put a strain on flying clubs. So, back in 1990, Ms. Judy Lincoln wrote the FAA, seeking interpretation of 14 C.F.R. § 61.118, which was later changed to § 61.113. At issue, was whether or not “logging of flight time” was considered compensation.

Generally speaking, private pilots are not allowed to receive compensation beyond their pro-rata share of flight expenses. It was on this basis – that private pilots are prohibited from receiving compensation in any form – that the Lincoln Interpretation found that logging of PIC time was considered compensation and therefore impermissible for a private pilot to tow gliders without sharing in the aircraft operating expense.

In a letter dated March 19, 2009, then-chairman of the Soaring Society of America (SSA), Phillip C. Umphres, requested further clarification from the FAA on the matter. In what has become known as the Umphres Interpretation. The FAA response dated November 3, 2010 states, in relevant part:

“The text of § 61.113(g) does not limit the compensation that a private pilot may receive to only the logging of PIC flight time despite a suggestion to that effect by the Soaring Society of America in a comment to the 1995 NPRM. See 62 Fed. Reg. 16220, 16267. Furthermore, the preamble to the 2004 final rule more clearly states the intent of § 61.113(g). Accordingly, § 61.113(g) permits a private pilot to act as PIC for compensation or hire of an aircraft towing a glider or unpowered ultralight vehicle. Nevertheless, although the glider and unpowered ultralight vehicle being towed and its passengers are not considered passengers or property for the purposes of § 61.1 13(a), § 61.1 13(a) does not permit a private pilot to carry passengers or property in the tow plane for compensation or hire.”

Pay close attention to the text above – “61.113(g) does not limit the compensation that a private pilot may receive to only the logging of PIC time…” This is great news but don’t expect livable wages. Many glider clubs are already running on thin financial margins, there’s not much money left over to pay tow pilots. Additionally, there are often but not always, other pilots in the area that tow on a volunteer basis. Your results may vary.

A Secret Way to Build Hours and Make Friends

It’s not unheard of for low-time pilots to look for ways to “build time” and experience after earning their private pilot certificate. Some of the more common methods out there involve flying as a safety pilot (while a buddy is under the hood) or sharing costs (pro-rata) with non-pilot friends while traveling to new destinations by small plane. Both of these are great ways to improve experience and build flight time while working toward additional ratings. Not many people know or talk about the ability of a private rated pilot to build time while towing gliders. That being said, don’t expect to reach 100 hours PIC in airplanes and then be able to walk down to the nearest glider operation and start towing.

The majority of tow planes used in the States are of the tailwheel variety. This alone will require a tailwheel endorsement for a newly minted pilot. Learning to fly tailwheel is akin to leveling up your flying skills – it’s absolutely worth doing and adds depth to the pilot’s flying tool bag. Additionally, a large number of glider locations use the venerable Piper Pawnee high-performance tail wheel aircraft for tow duties; one of the most common having 235 horsepower. In that case, you’d also need a high-performance endorsement. There are some places that use Cessna 182’s which are tricycle gear but high-performance.

As was mentioned above, being legal to tow planes is one thing – finding a place that will allow you to tow with just the legal minimums is an entirely different story. One example is a soaring club in Southern California. The club uses a Cessna 182 and they require total time of 500 hours, 250 PIC, high-performance endorsement, and 25 hours of experience in 182’s.

Another location in Northern California uses Pawnees as their tow planes. They won’t let you touch a tow plane until you have your glider rating. This is to ensure that random pilots with the required minimums don’t just come in with zero idea what it’s like to be on the tail end of the rope and try to do it safely. Towing is both an art and a science.

What is Required to Tow Gliders

According to the FAA, there is a short checklist of items that will make you qualified (legally) to tow gliders. Of course, personal skill level, required endorsements (tailwheel and/or high-performance), insurance coverage requirements, and glider club/operation requirements will all be part of the equation.

The pilot must:

Hold at least a private pilot certificate with appropriate category rating;

Have logged at least 100 hours as pilot in command in the same category as the aircraft being used for aero tow;

Have a logbook endorsement from an authorized instructor certifying you have received ground and flight training in gliders and are proficient in the areas listed in part 61.69(a)(3)(i)(ii)(iii) and (iv);

Have a logbook endorsement from a pilot that already meets the requirements of part 61.69(c) and (d), who has accompanied the pilot on three flights which has certified them to have accomplished at least three flights in an aircraft while towing a glider or simulating towing procedures; and

In the preceding 12 months has performed three actual or simulated tows accompanied by a qualified pilot or has been towed for three flights in a glider.

§ 61.113 Private pilot privileges and limitations: Pilot in command

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

(c) A private pilot may not pay less than the pro rata share of the operating expenses of a flight with passengers, provided the expenses involve only fuel, oil, airport expenditures, or rental fees.

(d) A private pilot may act as pilot in command of a charitable, nonprofit, or community event flight described in § 91.146, if the sponsor and pilot comply with the requirements of § 91.146.

(e) A private pilot may be reimbursed for aircraft operating expenses that are directly related to search and location operations, provided the expenses involve only fuel, oil, airport expenditures, or rental fees, and the operation is sanctioned and under the direction and control of:

(1) A local, State, or Federal agency; or

(2) An organization that conducts search and location operations.

(f) A private pilot who is an aircraft salesman and who has at least 200 hours of logged flight time may demonstrate an aircraft in flight to a prospective buyer.

(g) A private pilot who meets the requirements of § 61.69 may act as a pilot in command of an aircraft towing a glider or unpowered ultralight vehicle.

Disclaimer: This post is not legal advice, flight instruction, or ground instruction. For answers to questions specific to your situation and experience, consult a flight instructor in your area.

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