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When a soaring club provides towplanes to a regional or national
contest, how is a club typically compensated for loaning out their equipment, or are they? Is a contest and the use of a club towplane by non-club members seen as a "commercial" operation? And if so, does the towplane need a 100 hour inspection to be legal? How are tow fees assesed so that contestants, who are probably not members of the club providing the towplane, pay a fair amount so that club members are not subsidizing their tow fee? Brad |
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On Mar 17, 10:14*am, Brad wrote:
When a soaring club provides towplanes to a regional or national contest, how is a club typically compensated for loaning out their equipment, or are they? Is a contest and the use of a club towplane by non-club members seen as a "commercial" operation? And if so, does the towplane need a 100 hour inspection to be legal? How are tow fees assesed so that contestants, who are probably not members of the club providing the towplane, pay a fair amount so that club members are not subsidizing their tow fee? Brad Brad, each contest manager has their "own" concepts of how the tow plane thing works...I can only tell you what I do in the west (arizona, utah, and new mexico). I will also preface this by telling you that I overly compensate my tow pilots, because without them you can't have a contest! new SSA sanctioning rules require a million dollar liability insurance policy paid for by the plane owner, with the pilot listed. I pay for one tank of gas fuel (ferry fee) i pay the pilots a standard fee for every single tow. Every contest (sanctioned) has to keep a record of every tow plane, every glider, and every time each was towed. I also pay for lodging for my tow pilots I also pay for catered event meals for my pilots Oh, I also give each of my tow pilots a free contest t-shirt. Every day after the launch, I go over my tow log with each tow pilot to make sure we agree. At the end of the contest, I pay them the set amount per tow and the tank of gas. The Tow planes do not have to be insured as a "commercial" operation, as long as they have a liability insurance policy. I calculate the tow fee amount based on the gas required to launch, drop tow at 2,000 agl, and return. Some contests charge their contestants per tow, and transfer the money to the tow pilots, some contests just charge a standard amount to the contestants, and then work separate deals with their tow pilots. (the amounts you are allowed to charge for contest registrations and tows are listed in the rules). If my calculations prove to be more than the maximum allowed by the rules, then (and only then) I apply for a contest waiver to charge what is necessary. Also, I would recommend that you talk to some of the "chief tow pilots" around the country with lots of experience. One of the ones I recommend, is Bob Lynn out of Colorado. They can guide you as to the requirements, and what they recommend. Also, John Seaborn has been writing a contest manager's organization guide that is absolutely wonderful, and can help new contest organizers. Also, there is always the option of getting an experienced contest manager to train you in your first contest. I hope this helps Micki |
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Micki -
This is a bit of a subject jump - but where would one find John Seaborn's guide? We're trying to encourage some folks to try a "mini contest" out in Ephrata this spring/summer (18m Nats are preventing a normal Regional there this year)... But the "mini contest" is being put on largely by folks that have never run a contest before, so any organizational guide or "CD/CM manual" would be great! Thanks, take care, --Noel |
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On Mar 17, 1:14*pm, Brad wrote:
When a soaring club provides towplanes to a regional or national contest, how is a club typically compensated for loaning out their equipment, or are they? Is a contest and the use of a club towplane by non-club members seen as a "commercial" operation? And if so, does the towplane need a 100 hour inspection to be legal? How are tow fees assesed so that contestants, who are probably not members of the club providing the towplane, pay a fair amount so that club members are not subsidizing their tow fee? Brad Use of club tugs at contests is now an available endorsement under the SSA insurance program. Our club policy has it and it was automatic this year on renewal. That said, current concensus is that this is a "for hire" situation and the insurance company expects that pilots flying will have the appropriate certificate and that the tug will have appropriate inspections for this use(read 100 hr). BTW- if you do annual every 100 hr, you can roll these over and never have this concern. There is some ambiguity in resposes by FAA related to certificates required, but the prudent thing to do is to use commercially rated pilots. This is clearly what the insurance company expects. Currently approved tow rates for contests should create no financial issues for tow providers. Good Luck UH |
#5
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![]() wrote in message ... On Mar 17, 1:14 pm, Brad wrote: When a soaring club provides towplanes to a regional or national contest, how is a club typically compensated for loaning out their equipment, or are they? Is a contest and the use of a club towplane by non-club members seen as a "commercial" operation? And if so, does the towplane need a 100 hour inspection to be legal? How are tow fees assesed so that contestants, who are probably not members of the club providing the towplane, pay a fair amount so that club members are not subsidizing their tow fee? Brad Use of club tugs at contests is now an available endorsement under the SSA insurance program. Our club policy has it and it was automatic this year on renewal. That said, current concensus is that this is a "for hire" situation and the insurance company expects that pilots flying will have the appropriate certificate and that the tug will have appropriate inspections for this use(read 100 hr). BTW- if you do annual every 100 hr, you can roll these over and never have this concern. There is some ambiguity in resposes by FAA related to certificates required, but the prudent thing to do is to use commercially rated pilots. This is clearly what the insurance company expects. Currently approved tow rates for contests should create no financial issues for tow providers. Good Luck UH UH--- Where did the consensus come from? Clearly charging for tows makes it "for hire". Is there consensus as well about towpilot required certificates. FAR 61.113 "Private Pilot Privileges" list exceptions to the "no compensation" rules. Sub Paragraph (g) allows "towing a glider". It is totally unequivocal, and the sentence structure is plain. This is in contrast with the sentence structures referring to qualifications of a towpilot, in another paragraph. We have run into a problem due to this for the upcoming 15m Nationals at Cordele. We have, with some difficulty, finally rounded up enough Commercial rated towpilots, but it will cost more ferry fuel. I have sought clarification via the SSA Government Liason Committee and they are working on it. Hartley Falbaum "KF" Georgia, USA |
#6
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![]() When a soaring club provides towplanes to a regional or national contest, how is a club typically compensated for loaning out their equipment, or are they? Is a contest and the use of a club towplane by non-club members seen as a "commercial" operation? And if so, does the towplane need a 100 hour inspection to be legal? How are tow fees assesed so that contestants, who are probably not members of the club providing the towplane, pay a fair amount so that club members are not subsidizing their tow fee? Brad SNIPPED. I have sought clarification via the SSA Government Liason Committee and they are working on it. Hartley Falbaum "KF" Georgia, USA It seems possible that a couple folks are fishing either separately or collectively for information, or speculating. Brad: How is a club towplane compensated? By a check for US dollars. Is a club-tug towing in a contest a “Commercial operation”? According to typical arrangements and typical insurance, yes. Does the tug then need a 100-hour inspection? No. How are tow fees assessed so the club isn’t subsidizing a contest? Ask your club’s officers. Costs are different across the US. Private Pilot Towing I was contacted following some local conversations about an interpretation of the FARs as a part of the Governmental Liaison Committee for SSA. The question posed to me was whether or not a Private pilot could be “compensated” for towing at a contest…. In the example given, “could the Private certificate tow pilot be provided meals or lodging?” I cited 61.113(g) as the FAR in play. I also read it as a very simplistic sentence, which I had observed change in an FAR update in about 2004. Based on the 2004 documents published with that change, I believed it was a pretty plain conclusion that private pilots could tow and be compensated. I also warned the contest organizers raising the issue that the FAR may not be the most limiting consideration. The tow plane’s Insurance coverage would likely be the most restrictive document on the subject of which human may provide service to whom. In the dark ages, private pilots couldn’t tow anything. A Chapter (which is no longer in existence in Region 8) asked for help from SSA. They couldn’t find enough Commercial pilots and sought relief. SSA helped. SSA negotiated a waiver from the FAA, to allow club operations to use Private pilots -- if the pilots did not use the accumulation of flight time toward a furtherance of ratings. Accumulating flight time was considered by FAA to be “compensation”, as total time has value toward aviation employment. The waivers continued for many years, until the FAA decided there was NO safety issue under this SSA-initiated-documented program. Rather than continue wavier extensions, they changed the privileges of Private pilots in 1997 to allow glider towing, and noted that time could be accrued. But the FAA was silent on other forms of compensation. This was another instance of SSA’s action benefiting all US glider ops, not just “members”. 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). Since a few folks in SSA disagreed with my recent answer, and talked to a person in FAA who agreed with them, SSA has sent a formal letter to the FAA to ask for an interpretation of 61.113 (g). I don’t anticipate SSA getting an answer to that letter before most, if not all, of the 2009 soaring season is completed. The SSA Group Insurance Program was modified to include Private pilots towing internally to the club’s operations many years ago. Private pilots were insured to operate club tugs, including towing club members giving rides for hire or instruction. Meanwhile, soaring goes on. 100-Hour Inspections As far back as the late 1970’s SSA did receive a formal FAA letter of interpretation that states that towing a glider is specifically NOT carrying passengers. If your towplane: 1) does NOT give flight instruction for hire, 2) does NOT carry passengers for rides (for this you need drug testing, etc. see Part 136 Air Tours), then the tug does NOT need 100-hour inspections. Save some club/ school bucks. If you are training tow pilots, that doesn’t require a CFI-A trainer. The trainee is part of the tug flight crew, not a passenger. No 100-hour is required. Usually, this operation IS included in SSA Group coverage. (Check your tow pilot’s recent experience needs for 2009, as this is formally Spring now. FAR 61.69 (a) 6.) Contest Towing Who can tow at contests? SSA contest rules don’t specify anything but a liability insurance requirement for each tug, and FAR compliance. SSA contest rules do set the maximum entry fees, and the maximum value calculated for tow fees, adjusted annually to reflect current costs. If the fees didn’t meet tug expenses, contests wouldn’t get launched. The SSA Group Program was recently modified to include club tugs towing at SANCTIONED contests, provided they were using Commercial tow pilots, and the tugs and pilots could be paid at any exorbitant rate they could negotiate (my tongue is firmly in-cheek here, folks.) Contest staff is charged with being certain their contracted tugs are operated within their coverage. Could a tug owner have liability coverage, and the insurance include a Private pilot towing? Sure. But that isn’t a very likely scenario. Fly safely, and renew your SSA membership. Cindy Brickner |
#7
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On Mar 21, 7:30*am, "HL Falbaum" wrote:
wrote in message ... On Mar 17, 1:14 pm, Brad wrote: When a soaring club provides towplanes to a regional or national contest, how is a club typically compensated for loaning out their equipment, or are they? Is a contest and the use of a club towplane by non-club members seen as a "commercial" operation? And if so, does the towplane need a 100 hour inspection to be legal? How are tow fees assesed so that contestants, who are probably not members of the club providing the towplane, pay a fair amount so that club members are not subsidizing their tow fee? Brad Use of club tugs at contests is now an available endorsement under the SSA insurance program. Our club policy has it and it was automatic this year on renewal. That said, current concensus is that this is a "for hire" situation and the insurance company expects that pilots flying will have the appropriate certificate and that the tug will have appropriate inspections for this use(read 100 hr). BTW- if you do annual every 100 hr, you can roll these over and never have this concern. There is some ambiguity in resposes by FAA related to certificates required, but the prudent thing to do is to use commercially rated pilots. This is clearly what the insurance company expects. Currently approved tow rates for contests should create no financial issues for tow providers. Good Luck UH UH--- Where did the consensus come from? Clearly charging for tows makes it "for hire". Is there consensus as well about towpilot required certificates. FAR 61.113 "Private Pilot Privileges" list exceptions to the "no compensation" rules. Sub Paragraph (g) allows "towing a glider". It is totally unequivocal, and the sentence structure is plain. This is in contrast with the sentence structures referring to qualifications of a towpilot, in another paragraph. We have run into a problem due to this for the upcoming 15m Nationals at Cordele. We have, with some difficulty, finally rounded up enough Commercial rated towpilots, but it will cost more ferry fuel. I have sought clarification via the SSA Government Liason Committee and they are working on it. Hartley Falbaum "KF" Georgia, USA Maybe concensus is the wrong term , but I don't know of any contest organizer, and several have been looking at this including you, that see a way around the insurance company interpretation that contest towing is for hire and from their point of view , a commercial operation. This does NOT mean that their position agrees with the applicable FAR's and official interpretations of them. The SSA underwriters took a big hit from thr Toanapah accident and I assume this affects their thinking in risk management. It certainly does make it harder for all of us in the contest system to keep the sport affordable and accessible. UH |
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