Legal Interpretations
Gibb 2012
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. § 6 l. l l 3(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 - -- --------
Retrieved from ecfr.gov on July 18, 2026.