Narrative:

The middle of feb/93, I purchased an small aircraft sel to tow banners this summer. I needed a waiver so I applied to the grr FSDO office for one. They were unable to give me one in time, so the company I was supposed to tow for on apr/xx/93 added me and my plane to their waiver. Upon meeting with FAA inspector from the grr FSDO office, he informed me of a violation relating to towing. He said all aircraft towing banners are required to have a restr airworthiness certificate. I can not find anywhere in the FARS where it says that. He said it says in the FAA's handbook and because so, I am in violation. Now I don't have their handbook and nor is it made available to me. Now I feel I shouldn't be violated for something I had no idea about. Callback conversation with reporter revealed the following information: reporter stated that since he had filed this report he had received the appropriate authorization from the FAA. However, he did not believe that a multiple purpose airworthiness certificate was the appropriate aircraft airworthiness certificate to be issued for his aircraft to tow banners since his type of aircraft had been certificated with the tow hook provision. However, he was advised that the authorization of waiver may not include the necessary provisions for the specific aircraft and that the 'special purpose aircraft certificate' is apparently necessary. He was advised that notwithstanding a violation of the FARS, he has the right to request a copy of any handbook of guidance issued to the FAA for certificating banner towing operations. He further stated that he was very displeased with the FAA FSDO inspector handling of his application to the point that he had engaged the services of an attorney to help obtain the requested waiver and was going to deal with another FSDO serving his area of certificate address in the future.

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Original NASA ASRS Text

Title: PLT OF SMA SEL ACFT TOWED A BANNER WHEN THE ACFT DID NOT HAVE SPECIAL AIRWORTHINESS CERTIFICATE AUTHORIZATION.

Narrative: THE MIDDLE OF FEB/93, I PURCHASED AN SMA SEL TO TOW BANNERS THIS SUMMER. I NEEDED A WAIVER SO I APPLIED TO THE GRR FSDO OFFICE FOR ONE. THEY WERE UNABLE TO GIVE ME ONE IN TIME, SO THE COMPANY I WAS SUPPOSED TO TOW FOR ON APR/XX/93 ADDED ME AND MY PLANE TO THEIR WAIVER. UPON MEETING WITH FAA INSPECTOR FROM THE GRR FSDO OFFICE, HE INFORMED ME OF A VIOLATION RELATING TO TOWING. HE SAID ALL ACFT TOWING BANNERS ARE REQUIRED TO HAVE A RESTR AIRWORTHINESS CERTIFICATE. I CAN NOT FIND ANYWHERE IN THE FARS WHERE IT SAYS THAT. HE SAID IT SAYS IN THE FAA'S HANDBOOK AND BECAUSE SO, I AM IN VIOLATION. NOW I DON'T HAVE THEIR HANDBOOK AND NOR IS IT MADE AVAILABLE TO ME. NOW I FEEL I SHOULDN'T BE VIOLATED FOR SOMETHING I HAD NO IDEA ABOUT. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: RPTR STATED THAT SINCE HE HAD FILED THIS RPT HE HAD RECEIVED THE APPROPRIATE AUTHORIZATION FROM THE FAA. HOWEVER, HE DID NOT BELIEVE THAT A MULTIPLE PURPOSE AIRWORTHINESS CERTIFICATE WAS THE APPROPRIATE ACFT AIRWORTHINESS CERTIFICATE TO BE ISSUED FOR HIS ACFT TO TOW BANNERS SINCE HIS TYPE OF ACFT HAD BEEN CERTIFICATED WITH THE TOW HOOK PROVISION. HOWEVER, HE WAS ADVISED THAT THE AUTHORIZATION OF WAIVER MAY NOT INCLUDE THE NECESSARY PROVISIONS FOR THE SPECIFIC ACFT AND THAT THE 'SPECIAL PURPOSE ACFT CERTIFICATE' IS APPARENTLY NECESSARY. HE WAS ADVISED THAT NOTWITHSTANDING A VIOLATION OF THE FARS, HE HAS THE RIGHT TO REQUEST A COPY OF ANY HANDBOOK OF GUIDANCE ISSUED TO THE FAA FOR CERTIFICATING BANNER TOWING OPS. HE FURTHER STATED THAT HE WAS VERY DISPLEASED WITH THE FAA FSDO INSPECTOR HANDLING OF HIS APPLICATION TO THE POINT THAT HE HAD ENGAGED THE SVCS OF AN ATTORNEY TO HELP OBTAIN THE REQUESTED WAIVER AND WAS GOING TO DEAL WITH ANOTHER FSDO SERVING HIS AREA OF CERTIFICATE ADDRESS IN THE FUTURE.

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.