Old regulation still causes misunderstandings
Anyone who has already gained experience as an aeroplane pilot in glider towing and subsequently also wants to tow with a microlight aeroplane might initially assume that their previous flight experience will be fully credited. After all, the fundamental requirements for safe towing operations do not suddenly differ simply because the tow plane is classified under aviation law as a sports aircraft rather than an aeroplane.
However, it is precisely at this point that differences of opinion keep arising in practice.
Some references are still made to the former NfL II-73/02. Under certain conditions, this allowed flight experience on aeroplanes to be taken into account for obtaining a microlight towing rating. For pilots who already held a corresponding towing rating on aeroplanes, this was a thoroughly understandable simplification.
However, this former regulation can no longer be used today as a basis for the issuance of a glider towing rating.
Today, Section 84 of the Aviation Personnel Ordinance (LuftPersV) is decisive
The relevant provision can now be found in Section 84 of the Aviation Personnel Ordinance. It sets out the technical requirements for the towing rating for pilots of motorised recreational aircraft.
For the towing of other aircraft or other objects without snatch towing, § 84 paragraph 2 LuftPersV initially requires practical experience of at least 30 flight hours as pilot-in-command of powered microlights after obtaining the corresponding pilot's licence.
Within these 30 hours, at least five flight hours must also have been completed on the variant on which the tow rating is to be obtained.
The crucial factor here is the wording „motor-driven air sports equipment“. The text of the regulation explicitly does not speak of motor-driven aircraft in general, nor of aeroplanes. Consequently, flight hours on an aeroplane operated under EASA rules cannot currently replace the required 30 hours.
The current version of Section 84 of the German Aviation Personnel Ordinance (LuftPersV) explicitly confirms this requirement. The requirements for the microlight tow rating published by the DAeC also specify at least 30 hours as pilot-in-command of an aerodynamically controlled microlight aircraft after obtaining the microlight licence.
Why older information can lead to a different result
The confusion is also historically understandable. The requirements have changed over time.
Older versions of Section 84 of the German Aviation Personnel Ordinance (LuftPersV) still used the much broader term „motor-driven aircraft“. It was only later that the provision was explicitly amended to apply to „motor-driven microlights“.
This has created a key distinction: although an aircraft is an aerial vehicle, it is not an air sports device. The wording chosen today therefore expressly restricts the creditable flight experience to the corresponding aircraft category.
The former NfL II-73/02 cannot override this current statutory regulation. It no longer forms part of the applicable set of rules and can therefore not serve as a basis for recognising aeroplane hours instead of the UL flight hours required under section 84.
what applicants must specifically prove today
Anyone wishing to obtain a tow rating for an aerodynamically controlled microlight aircraft must therefore first demonstrate the prescribed experience on microlights.
A minimum of 30 flight hours as pilot-in-command of microlights after obtaining the corresponding licence is required. This must include at least five hours on the microlight type on which the towing rating is to be acquired.
Additional requirements apply to the actual towing training. For sailplane towing, a minimum of five flights in sailplanes in tow must generally be carried out under the guidance and supervision of a suitably rated flight instructor. These must have been completed within the last six months prior to applying for the rating.
Furthermore, the LuftPersV generally requires participation in five winch launches in a towed aircraft of the relevant type, unless the applicant already holds the corresponding licence themselves.
This is to ensure that the future tug pilot does not know towing operations exclusively from the perspective of the tug aircraft.
An existing PPL does not replace the 30 UL hours
The regulation is particularly relevant for pilots who already have extensive experience on aeroplanes.
For example, a pilot may have logged several hundred hours on SEP aircraft and already possess experience as a tow pilot. Nevertheless, under the current wording of Section 84 of the German Aviation Personnel Ordinance (LuftPersV), these hours do not help them fulfil the 30-hour requirement for obtaining a towing rating on an microlight.
He requires the required 30 hours as the pilot-in-command of a powered microlight aircraft.
This may appear contradictory at first glance. Under aviation law, however, the categories are kept separate, and the granting of a rating depends not solely on actual flying experience, but on the expressly prescribed experience within the respective aircraft category.
Five hours must also have been flown on the towing pattern
Another prerequisite should not be overlooked when planning the training.
Of the at least 30 required UL hours, five hours must have been completed on the exact variant on which the tow rating is to be acquired.
For example, anyone who has gained their microlight experience predominantly on a different type and subsequently switches to a microlight used for glider towing must therefore check whether the required type experience has already been acquired.
Only when these prerequisites are met can training and subsequent entry of the towing rating take place in accordance with the specifications of the LuftPersV.
Even after training, experience requirements still apply
With the registration of the towing authorisation, the issue of experience is also not permanently resolved.
Section 84 LuftPersV also contains requirements for the continued exercise of the privileges. Within the preceding 24 months, the holder must have performed at least ten towing flights in the entered towing method.
If this experience has not been attained, corresponding tow flights must be completed again under the guidance and supervision of a suitably qualified flight instructor before the privileges can be exercised again.
The regulation thus distinguishes between the conditions for initial acquisition and the necessary ongoing experience for the subsequent exercise of the qualification.
DAeC campaigns for a change to the regulation
While this current regulation is certainly unambiguous, it is viewed quite critically within air sports.
Particularly in the case of experienced aircraft pilots, the question arises as to why extensive flight experience as pilot-in-command of an aircraft is to be completely disregarded for the 30-hour requirement.
The DAeC is therefore working to achieve a change to this requirement. The aim is to also be able to count corresponding flight hours on aeroplanes towards the required minimum experience in future.
However, until such a change is actually incorporated into the applicable rules, the current legal situation remains decisive.
What flight schools and applicants should consider
It is therefore important for flight schools, flight instructors and pilots to distinguish between a desired future amendment and the currently applicable regulation.
Anyone applying for a microlight towing rating today should not rely on older announcements or previous credit transfer options. The governing regulation is Section 84 of the German Ordinance on Aviation Personnel (LuftPersV) in its current version.
The practical consequence can therefore be simply summarised: for the currently prescribed 30 hours, flight hours as pilot in command of powered microlight aircraft count. Flight hours on aeroplanes cannot currently replace this requirement.
Should the change sought by the DAeC be implemented, this could change again in future. Until then, applicants should plan their training accordingly and take care, in particular, to complete the required microlight flight time—including the five hours on the designated towing aircraft—in good time.
Source references:
DAEC
