Narrative:

Thinking that the operation would be covered under the waiver listing myself and my airplane that is filed at another FSDO in the south, I towed a banner on sep/sun/95 using my 1970 piper supercub. I have at least 600 hours towing banners in other areas. The airplane had a recent (less than 100 hours) major overhaul of the engine, was in annual and 100 hour inspection. The airframe was recovered 2 yrs ago. The banner equipment, and flying tackle, is in very good shape, much better than other operations I have seen. The ground crew consisted of a banner pilot with over 4000 hours banner towing. The pickup and drop area is miles from the nearest airport and has been previously approved by the local FSDO. Local ATC was called and informed of the upcoming flight. Harrisburg approach had no problems with the flight and were very accommodating and professional. During the flight all FARS were adhered to and due consideration was given to avoiding the quieter neighborhoods and concentrating on high volume traffic areas and football games. The flight was timed to avoid operations after sunset. No civil complaints were received. In short the whole operation was done with care and with an eye toward safety by experienced people using superior equipment, all previously given FAA approval (in other districts). The point of this report is through unofficial channels (inside information) I found out that an FAA FSDO employee, perhaps an operations inspector, saw the airplane towing the banner and expressed interest in finding out who that was flying the banner. My informant told me the inspector suspected the flight wasn't 'approved' and wanted to catch someone in the act. I believe that on that day myself and my plane were added to another waiver in the philadelphia district office. Was the flight in violation of some rule or regulation? At the time I didn't think so, but after hearing about the FSDO employee I started checking and now it seems possible there was some sort of procedural shortcoming, paperwork wise, on my part. Still, one can see I'm no outlaw. I had no intention of circumventing any rules and did everything I could think of to ensure a safe and legal flight. I just didn't know there was a need to contact the local FSDO.

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Original NASA ASRS Text

Title: BANNER TOWING PLT FAILS TO NOTIFY THE LCL FSDO OFFICE IN WHOSE AREA HE IS OPERATING.

Narrative: THINKING THAT THE OP WOULD BE COVERED UNDER THE WAIVER LISTING MYSELF AND MY AIRPLANE THAT IS FILED AT ANOTHER FSDO IN THE S, I TOWED A BANNER ON SEP/SUN/95 USING MY 1970 PIPER SUPERCUB. I HAVE AT LEAST 600 HRS TOWING BANNERS IN OTHER AREAS. THE AIRPLANE HAD A RECENT (LESS THAN 100 HRS) MAJOR OVERHAUL OF THE ENG, WAS IN ANNUAL AND 100 HR INSPECTION. THE AIRFRAME WAS RECOVERED 2 YRS AGO. THE BANNER EQUIP, AND FLYING TACKLE, IS IN VERY GOOD SHAPE, MUCH BETTER THAN OTHER OPS I HAVE SEEN. THE GND CREW CONSISTED OF A BANNER PLT WITH OVER 4000 HRS BANNER TOWING. THE PICKUP AND DROP AREA IS MILES FROM THE NEAREST ARPT AND HAS BEEN PREVIOUSLY APPROVED BY THE LCL FSDO. LCL ATC WAS CALLED AND INFORMED OF THE UPCOMING FLT. HARRISBURG APCH HAD NO PROBS WITH THE FLT AND WERE VERY ACCOMMODATING AND PROFESSIONAL. DURING THE FLT ALL FARS WERE ADHERED TO AND DUE CONSIDERATION WAS GIVEN TO AVOIDING THE QUIETER NEIGHBORHOODS AND CONCENTRATING ON HIGH VOLUME TFC AREAS AND FOOTBALL GAMES. THE FLT WAS TIMED TO AVOID OPS AFTER SUNSET. NO CIVIL COMPLAINTS WERE RECEIVED. IN SHORT THE WHOLE OP WAS DONE WITH CARE AND WITH AN EYE TOWARD SAFETY BY EXPERIENCED PEOPLE USING SUPERIOR EQUIP, ALL PREVIOUSLY GIVEN FAA APPROVAL (IN OTHER DISTRICTS). THE POINT OF THIS RPT IS THROUGH UNOFFICIAL CHANNELS (INSIDE INFO) I FOUND OUT THAT AN FAA FSDO EMPLOYEE, PERHAPS AN OPS INSPECTOR, SAW THE AIRPLANE TOWING THE BANNER AND EXPRESSED INTEREST IN FINDING OUT WHO THAT WAS FLYING THE BANNER. MY INFORMANT TOLD ME THE INSPECTOR SUSPECTED THE FLT WASN'T 'APPROVED' AND WANTED TO CATCH SOMEONE IN THE ACT. I BELIEVE THAT ON THAT DAY MYSELF AND MY PLANE WERE ADDED TO ANOTHER WAIVER IN THE PHILADELPHIA DISTRICT OFFICE. WAS THE FLT IN VIOLATION OF SOME RULE OR REG? AT THE TIME I DIDN'T THINK SO, BUT AFTER HEARING ABOUT THE FSDO EMPLOYEE I STARTED CHKING AND NOW IT SEEMS POSSIBLE THERE WAS SOME SORT OF PROCEDURAL SHORTCOMING, PAPERWORK WISE, ON MY PART. STILL, ONE CAN SEE I'M NO OUTLAW. I HAD NO INTENTION OF CIRCUMVENTING ANY RULES AND DID EVERYTHING I COULD THINK OF TO ENSURE A SAFE AND LEGAL FLT. I JUST DIDN'T KNOW THERE WAS A NEED TO CONTACT THE LCL FSDO.

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.