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Certificate in the Restricted Category may be issued to the aircraft in accordance with 14 CFR
section 21.25.
Title 14 CFR section 21.25(b)(6) and (7) states aerial advertising includes skywriting, banner
towing, airborne signs, and public address systems; and any other operation specified by the
Administrator.
It is possible for an aircraft that is used for banner tow operations to have multiple airworthiness
certificates. The aircraft may have a Standard Airworthiness Certificate that is displayed when the
aircraft is operated as it was originally certificated, and a Special Airworthiness Certificate in the
Restricted Category to be displayed during banner tow operations.
If an operator wishes to have multiple airworthiness certificates for the aircraft he or she must meet
the requirements of 14 CFR section 21.187(5). Title 14 CFR section 21.187 (a)(1), requires the
operator to demonstrate compliance with the requirements for each category when the aircraft is in
the configuration for that category. Title 14 CFR section 21.187(a)(2) requires demonstration that
the aircraft can be converted from one category to another by removing or adding equipment by
simple mechanical means.
It is not uncommon for a banner tow operator to configure aircraft for banner tow operations in a
manner and to such an extent that the aircraft no longer meets the requirements of 14 CFR
section 21.187. After proper application, these aircraft can be issued a special airworthiness
certificate in the restricted category, and limited to banner tow operations only.
5-2
5-3 (and 5-4)
Aircraft that are modified and certificated under 14 CFR section 21.25 for special purpose
operations will be issued operating limitations with the certificate of waiver. The operating
limitations specify the type and scope of operations for which the aircraft may be used, and the
aircraft must be operated as prescribed in 14 CFR section 91.313.
No person may operate a civil aircraft unless an appropriate airworthiness certificate and effective
U.S. Registration Certificate are displayed in the aircraft at the cabin or cockpit entrance, so that it
is legible to the passengers or crew as prescribed in 14 CFR part 203.
AC 20-65, U.S. Airworthiness Certificates and Authorizations for Operation of Domestic and
Foreign Aircraft, provides guidance and general information regarding the issuance of
Airworthiness Certificates for U.S. Registered aircraft.
II. Maintenance Requirements.
Aircraft with a special airworthiness certificate in the restricted category issued under 14 CFR
section 21.25 are subject to the same maintenance and record keeping requirement as aircraft
operated with a Standard Airworthiness Certificate, 14 CFR section 43.1(a)(1).
All maintenance, repairs, and alterations must be performed by and recorded in a form and the
maintenance, repairs, and alterations must be recorded in a manner as prescribed by 14 CFR
section 91.407.
All major repairs and alterations to the aircraft and appliances as defined in 14 CFR part 1, may be
returned to service as long as the person approving the return to service is a person specified in
14 CFR section 43.7 or 43.17 and the approval for the return to service of the aircraft conforms to
all regulatory requirements as prescribed in 14 CFR part 43, appendix B.
Title 14 CFR section 65.95(a)(1), states that the holder of an inspection authorization may return an
aircraft to service after major repair or major alteration if the work was done in accordance with
technical data approved by the Administrator. The owner or operator as prescribed in 14 CFR
section 91.417(a)(b)(c) must maintain these records.
Aircraft that are used for a special purpose like banner towing must be inspected annually as
required by 14 CFR section 91.409.
Banner tow aircraft that are operated with a special airworthiness certificate in the restricted
category under 14 CFR section 21.25 must also be marked in accordance with 14 CFR
section 45.23(a) and (b). Aircraft operated in the restricted category must display the word
RESTRICTED near each entrance to the cabin or cockpit on that aircraft, in letters not less than
2 inches, or more than 6 inches in height.
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Banner Tow Operations(10)
