Becoming a pilot can be a significant time and financial investment, and so it would be nice to be able to earn some of that back with something less involved than going to the airlines. Banner towing is one of the jobs you can do as a lower time pilot to earn money, but a common question is do you need a commercial pilot’s license for banner towing?
Yes, you need a commercial pilot’s license to tow banners, but not an instrument rating. 14 CFR 91.311 says that banner towing can occur when it’s in accordance with a certificate of waiver issued by the FAA. The certificate of waiver section 3-64(A)(4) says that “when banner towing operations are conducted for compensation or hire, the pilot must have at least a limited Commercial Pilot Certificate (without an instrument rating) and at least a second-class medical certificate.”
There you have it, yes you do need a commercial license to tow banners. In the rest of this post we’ll go through some other common questions associated with this topic.
What is a limited commercial pilot certificate?
A limited commercial pilot certificate simply means you possess a commercial pilot’s license but not an instrument rating. This comes from 14 CFR 61.113(b)(1): A person who applies for a commercial pilot certificate with an airplane category or powered-lift category rating and does not hold an instrument rating in the same category and class will be issued a commercial pilot certificate that contains the limitation, “The carriage of passengers for hire in (airplanes) (powered-lifts) on cross-country flights in excess of 50 nautical miles or at night is prohibited.”
The regulation further goes onto say that once you get your instrument rating, the limits of your commercial license go away immediately. If your only intent is to tow banners, tow gliders, or do skydive operations, then this limited commercial pilot certificate really won’t hold you back because none of those things would require you to fly for hire at night or outside 50 nautical miles of the airport.
Can you get paid as a private pilot?
We now know that in order to tow banners for hire you need a commercial pilot’s license. But if you only have your private currently, what else might you be able to do and get paid for it? We covered this topic pretty extensively in “Can you get paid as a private pilot?” but here is the overview:
- For the most part you cannot get paid as a private pilot. 14 CFR 61.133 covers the seven different areas in which you can receive money for flying, but under most of these scenarios you won’t get paid to fly, but just reimbursed for certain expenses.
- You can be paid to tow gliders if you meet the minimum experience and training requirements under 61.69. This (61.133(g)) is one of the only clear cut scenarios where the FAA is pretty straightforward that you can get paid (more than just reimbursed) to fly with only a private pilot’s license. It’s curious that the FAA allows you to tow gliders without a commercial license but requires it in order to tow banners. You’d think it would be the other way around!
- You can reimbursed by your passengers for pro-rata expenses limited to just the fuel, oil, airport, and rental costs associated with the flight. This isn’t really getting “paid” to fly but more just reimbursed your share of the direct expenses with the flight.
- There are other situations like flight demonstrations as an aircraft salesman and test flights for light sport aircraft, where you can be paid to fly but this is a bit of a gray area and the FAA leaves it somewhat vague.
- The best course of action is to just get your commercial license and stay out of any gray area. There aren’t many paid opportunities for you as a private pilot anyways, and so getting your commercial license will make you much more hirable and provide you with more flexibility when it comes to paid opportunities. A private pilot’s license is meant to mainly be just that: private operations not for hire.
How long does the commercial license take and how much does it cost?
The commercial license is one of the easier ratings as it is really just a review of your private pilot’s license with some added maneuvers. The book knowledge mainly just covers when you can and cannot get paid to fly as a commercial pilot, whereas the flight mainly just covers maneuvers that demonstrate your mastery over the aircraft. It is not a particularly hard rating.
In terms of cost, it kind of depends on how many of the prerequisites you have already accomplished prior to beginning your training. For instance if you have already completed your 300nm solo cross country, that is a significant flight you can cross off your list. If you haven’t yet completed that and have to include that in your commercial training costs, that’s another 5 or so flight hours that you wouldn’t otherwise need to do.
You’ll also need 10 hours of complex aircraft time which is generally more expensive to rent than your standard Cessna 172 that isn’t complex. If you already have these hours then really all that is left is learning the maneuvers and reviewing the ground school knowledge and you’re ready for the checkride.
All of that to say, the training can be as little as 5 flight hours or as long as 20, depending on how many pre-requisites you have already accomplished. This means that the average cost is somewhere between $2,000-5,000 for the commercial license. Keep in mind that the commercial license has a minimum hour requirement of 250 flight hours, but you can start training before you have 250 flight hours as long as you meet that requirement before your check ride.
Think Ahead for Your Commercial License
If you’re currently working on your private pilots license or contemplating your commercial license, be sure to think ahead as much as you can so that you can “double dip” some of your training and knock out some of the requirements of the commercial license before you even start training. For example, while working on your private license, see if you can do 10 of the training hours in a complex airplane so that you have crossed this off the list when you work on your commercial.
If you already have your private license and either own or are renting airplanes, next time you are planning on doing a solo cross country, see if you can stretch it to 300nm to have it count towards the commercial. I frustratingly did not do this and my longest solo cross country was 8nm short of meeting the requirement. 8 miles! I had to go do a 5 hour cross country to get the full 300nm leg requirement, which was fun but cost me another $600+ that I probably could have avoided had I been aware of that requirement and made that other cross country 8nm longer.
Single vs. Multi-Engine Commercial
Also note that the commercial license is regarded as two separate licenses when it comes to single and multi-engine. In other words, you can have your multi-engine commercial license but only your single engine private pilot’s license, or vice versa. It’s similar to how the CFI is set up where you can have your single engine CFI but the MEI (multi-engine instructor) is a different rating.
Conclusion
If you’re planning on seeking out paid pilot positions, I would highly recommend getting your commercial license and not trying to find ways to skirt around the regulations with just a private pilot’s license. Once you have the commercial license, you’ll always have the commercial license and so all that is needed to be eligible for paid positions is to make sure your second-class medical certification is up to date.
If you already have the minimum 250 hours needed as well as some of the prerequisites (solo cross country, complex time, etc.) then it can be a really affordable rating. It’s not nearly as difficult as your private license or instrument rating and so I highly recommend just knocking it out when you can, trusting that you’ll make it back. Plus once you have your commercial license you will be able to network better in the flying community and let others know that you are hirable for positions, instead of just telling them you’re a private pilot. You never know where those conversations might lead down the road and someone would have an open position for you.
Blue skies!
