Ask the DAR

Towing gliders with an E/A-B aircraft, POH requirements, taxi-testing scenarios.

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Question: Can Experimental/Amateur-Built aircraft tow gliders? What is required? I assume it cannot be for compensation although the FAA now allows Private Pilot rated tow pilots to be compensated.

Answer: Yes Experimental/Amateur-Built aircraft can be used to tow gliders under certain circumstances. The operating limitations normally issued for these aircraft prohibit towing gliders, but an FSDO can issue exceptions. The FSDO will have to get authorization from a higher-up FAA authority, and some of them may not want to go the extra mile, but it can be done. You are correct that it may not be done for hire.

Question: I’m moving along on my Just Aircraft Highlander build, starting the engine installation. I’m wondering what the DAR will expect in regards to a Pilot’s Operating Handbook (POH) and equipment list. Is there a generally accepted format that I should follow?

Answer: There is no requirement for a POH or equipment list for Experimental/Amateur-Built aircraft. The operating limitations that will be issued at certification will suffice. A POH is a good idea and will impress your inspector, but it is not a requirement.

Question: Hypothetically speaking, let’s say I build an Experimental/Amateur-Built aircraft and decide to taxi it on a private field. The field has an FAA designator, but is labeled “Private,” and the aircraft does not have an N-number or airworthiness certificate. Now, suppose I have a mishap and destroy the plane, and someone decides to call the FAA—what is likely to be the FAA’s position? I assume they probably won’t be too concerned. Since it is not an airplane yet and has no registration, it seems like it would be no different than a golf cart or ATV running up and down the runway. Would there be a violation?

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Now, here’s the same basic scenario, but this time, the aircraft is registered with an N number, but does not have an airworthiness certificate. Would the FAA likely create a fuss since the aircraft really shouldn’t move until it has an airworthy certificate? Or can it taxi, as long as it is not intended to lift off? Would there be a violation?

Finally, here’s the third scenario: This time the aircraft is fully registered, with an airworthiness certificate and operating limitations, all legal. Here, I assume the FAA would write up their reports, but nothing illegal was done so they would leave. Would there be a violation? Your insight will be greatly appreciated.

Answer: That’s quite a list of hypotheticals you have there. Let’s see what we can come up with one by one.

The first example is pretty simple: no registration, no airworthiness certificate, no airplane, no violation!

The second scenario is also simple: no airworthiness certificate, no airplane, no violation! Aircraft may legally taxi without an airworthiness certificate.

Now let’s look at the third scenario: As long as there was no death or serious injury, no substantial property damage to anything other than the aircraft itself, there should be no violation. But please be careful out there!

Please send your questions for DAR Asberry to editorial@kitplanes.com with “Ask the DAR” in the subject line.


Mel Asberry is an experienced Designated Airworthiness Representative specializing in Experimental/Amateur-Built aircraft. He and his wife, Ann, have built seven amateur-built airplanes including two ultralight types, a Moni Motorglider, a Dragonfly Mk2, two RV-6s and a Zenair CH 601HDS. They are currently building a scratch-built biplane.

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Mel Asberry
Mel Asberry is an experienced Designated Airworthiness Representative specializing in Experimental/Amateur-Built aircraft. He and his wife, Ann, have built seven amateur-built airplanes including two ultralight types, a Moni Motorglider, a Dragonfly Mk2, two RV-6s and a Zenair CH 601HDS. They are currently building a scratch-built biplane.

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