Legal Interpretations
Torres 2011
Summary
The Question
May a private pilot place a free aircraft cover bearing commercial advertising on a parked aircraft without violating 14 CFR 61.113?
Background
A prospective business owner planned to provide private pilots with aircraft covers printed with commercial advertising or logos, presumably at no cost but with no additional compensation, used only while the aircraft is parked, stationary, and out of service at a tie-down.
The FAA’s Interpretation
Yes. A private pilot acts as pilot in command only when the aircraft is operating, so using an advertising cover on an aircraft that is stationary, not operational, and parked at a tie-down is not prohibited by 14 CFR 61.113. The cover may also be carried in the airplane, provided it is not stowed so as to present a commercial display or in a manner contrary to safe operation.
- Requester
- Torres
- Issued
- March 17, 2011
- Subject
- Pilot Certification & Privileges
Regulations Cited
Page 1
U.S. Department
o f Tronsportofion
Fec:Sera Aviation·
Administration
M~R 1T 2011
Ms. Karen Torres
Dear Ms. Torres:
QffiQO of ttle Chief Counsel 800 Independence Ave., S.W.
Washington. D.C. 20591
This letter responds to your request for an interpretation of 14 C.F.R. §61.113, Private pilot privileges and limitations: Pilot in command. Specifically, your request raises a question regarding the extent of the prohibition on a private pilot acting as pilot in command of an aircraft for compensation or hire.
Your request indicates that you wish to pursue a business opportunity that would provide aircraft covers to private pilots, presumably at no cost to the pilot, but with no additional compensation, which wouJd have commercial advertising or a logo printed on the outer cover surface. Th~se covers would only be used while the aircraft is not in service, parked at a tie-doMJ location and stationary.
After presentation of the facts above, you ask for an interpretation of two questions. One, would a private pilot be allowed to use an aircraft cover with advertising, provided for free to the private pilot, and place it on an aircraft that is not in service? Secondly, you ask whether a private pilot would be able to transport the aircraft cover within their airplane to their next stop or parking location for use?
In response to your first question, I would emphasize that a private pilot is only acting as pilot in command of an aircraft when it is operating. Therefore, using an aircraft cover which had commercial advertising or logos printed on the outside of the cover, while the aircraft is stationary, not operational and parked at a tie-down location is not prohibited by 14 C.F.R. §61.113. The answer to your second question is yes, the cover can be transported in the airplane provided that it is not stowed in a manner as to present a commercial display or in a manner that is contrary to the safe operation of the aircraft.
Page 2
We trust that the above responds to your concerns. If you have additional questions or need further infonnatio~ please contact my staff at (202) 267-3073. This response was prepared by Neal O'Hara, an attorney in the Regulations Division of the Office of the Chief Counsel, and was coordinated with the Certification and General Aviation Operations Branch of the Flight Standards Service.
Sincerely,
~&-¥fl--
Rebecca B. MacPherson
Assistant Chief Counsel for Regulations, AGC-200
Regulations Referenced
Snapshot retrieved August 6, 2026.