They may not be correctly looking at FAR 91.311 
 
 
There has been a persistent notion among some aviation snobs that 
ultralights - aircraft operated under 14CFR Part 103 - are not "proper 
aircraft."  They are.  One would think that in gliding, where many of 
us operate under the even more illegitimate-sounding category of 
"Experimental" this notion would be less prevalent.  Apparently not. 
I too have encountered at least one gliderport where "It must have an 
N Number" is a requirement for operations.  Weird. 
 
However, the FAA does not share this attitude: they consider 
ultralights to be perfectly valid aircraft - gliders too.  Heck, they 
even think "Experimental" aircraft are okay under certain 
circumstances - although they do require program letters for those 
(not required for ultralights). 
 
91.311 says that you need a waiver to tow anything other than a 
glider, and if you're towing a glider it must be done in compliance 
with 91.309.  Going to look at 91.309, it requires that the person 
towing a glider must be properly qualified, that the towing aircraft 
must have a tow-hitch, that the tow-line be in a certain strength 
range, that the controlling entity for the airspace (in controlled 
airspace) must be advised of the towing operation, that the tow pilot 
and glider pilot have a joint plan of action and that the tow pilot 
must be careful where the rope is dropped.  Well, nothing in any of 
that about ultralights. 
 
Perhaps BT is operating under the misapprehension that an ultralight 
vehicle is not a glider?  Let's go to definitions: Part 1.1 (General 
definitions) defines a glider without any reference to whether or not 
it is operated under Part 103 (i.e., is an ultralight): it requires 
only that it be a heavier than air aircraft, supported in flight by 
the dynamic reaction of the air against its surfaces, and not rely 
principally on an engine. 
 
All of the relevant sections of 14CFR follow.  I've thrown in the 
definition of "aircraft" as well, in case anyone thinks that an 
ultralight may not be a "glider" because it's not an "aircraft."  Not 
to worry: it is. 
 
 
§ 91.311   Towing: Other than under §91.309. 
No pilot of a civil aircraft may tow anything with that aircraft 
(other than under §91.309) except in accordance with the terms of a 
certificate of waiver issued by the Administrator. 
 
 
§ 91.309   Towing: Gliders. 
(a) No person may operate a civil aircraft towing a glider unless— 
 
(1) The pilot in command of the towing aircraft is qualified under 
§61.69 of this chapter; 
 
(2) The towing aircraft is equipped with a tow-hitch of a kind, and 
installed in a manner, that is approved by the Administrator; 
 
(3) The towline used has breaking strength not less than 80 percent of 
the maximum certificated operating weight of the glider and not more 
than twice this operating weight. However, the towline used may have a 
breaking strength more than twice the maximum certificated operating 
weight of the glider if— 
 
(i) A safety link is installed at the point of attachment of the 
towline to the glider with a breaking strength not less than 80 
percent of the maximum certificated operating weight of the glider and 
not greater than twice this operating weight. 
 
(ii) A safety link is installed at the point of attachment of the 
towline to the towing aircraft with a breaking strength greater, but 
not more than 25 percent greater, than that of the safety link at the 
towed glider end of the towline and not greater than twice the maximum 
certificated operating weight of the glider; 
 
(4) Before conducting any towing operation within the lateral 
boundaries of the surface areas of Class B, Class C, Class D, or Class 
E airspace designated for an airport, or before making each towing 
flight within such controlled airspace if required by ATC, the pilot 
in command notifies the control tower. If a control tower does not 
exist or is not in operation, the pilot in command must notify the FAA 
flight service station serving that controlled airspace before 
conducting any towing operations in that airspace; and 
 
(5) The pilots of the towing aircraft and the glider have agreed upon 
a general course of action, including takeoff and release signals, 
airspeeds, and emergency procedures for each pilot. 
 
(b) No pilot of a civil aircraft may intentionally release a towline, 
after release of a glider, in a manner that endangers the life or 
property of another. 
 
 
 
§ 1.1   General definitions. 
.. 
.. 
Aircraft means a device that is used or intended to be used for flight 
in the air. 
.. 
.. 
Glider means a heavier-than-air aircraft, that is supported in flight 
by the dynamic reaction of the air against its lifting surfaces and 
whose free flight does not depend principally on an engine. 
 
		
	
		
		
		
		
		
	
		 
			
 
			
			
			
				 
            
			
			
            
            
                
			
			
		 
		
	
	
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