An aircraft that is in full compliance with its type design and has an FAA-approved banner tow installation may be operated under a standard airworthiness certificate for banner towing purposes. An aircraft that has a standard airworthiness certificate and is modified for a special purpose operation may have a multiple airworthiness certificate (standard/restricted) when the following conditions occur:

The special purpose modification does not meet the type design.

The special purpose modification is not approved for standard category use.

The aircraft will be operated outside the normal category operating limitations. (Order 8130.2D, dated 9/30/99.)

I. Airworthiness Certificates.

When aircraft are used for special purposes such as Aerial Advertising, a Special Airworthiness 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.

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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