Legal Interpretations
Gibb 2012
Summary
The Question
What medical certificate must a private pilot hold to tow gliders or unpowered ultralight vehicles for compensation or hire under 14 CFR 61.113(g)?
Background
A requester asked about medical certification requirements for private pilots who tow gliders and unpowered ultralight vehicles for compensation or hire, as 14 CFR 61.113(g) permits.
The FAA’s Interpretation
A third-class medical certificate. 14 CFR 61.23 requires a third-class medical certificate when exercising the privileges of a private pilot certificate, and only a private pilot certificate is required to tow a glider or unpowered ultralight vehicle for compensation or hire, so the pilot must hold a third-class medical certificate.
- Requester
- Gibb
- Issued
- June 24, 2012
- Subject
- Pilot Certification & Privileges
Regulations Cited
Page 1
U.S. Deportment
of Transportation
Federal Aviation
Administration
1HI ! 4 'ltltt
Steven Gibb
Dear Mr. Gibb:
Office of the Chief Counsel
800 Independence Ave., SW.
Washington, DC 20591
This letter responds to your request for legal interpretation regarding the medical certification requirements for private pilots who tow gliders and unpowered ultralight vehicles for compensation or hire as permitted by 14 C.F.R. § 61.113(g). Section 61.23 requires a pilot to hold a third-class medical certificate when exercising the privileges of a private pilot certificate. Because a pilot is required to hold only a private pilot certificate to tow a glider or unpowered ultralight vehicle for compensation or hire, the pilot must hold a third-class medical certificate.
This response was prepared by Anne Moore, an Attorney in the Regulations Division of the Office of the Chief Counsel and coordinated with the Certification and General Aviation Operations Branch of Flight Standards Service. If you have any additional questions regarding this matter, please contact us at you convenience at (202) 267-3073.
Sincerely,
~-::.o~Assistant Chief Counsel for Regulations, AGC-200 - -- --------
Regulations Referenced
Snapshot retrieved August 6, 2026.