AircraftOwner Online

The FAA has been working for two years to try to implement a rule which would require all registrations on the US Civil Aircraft Registry to be updated and renewed every three years. The Final Rule will become effective on October 1, 2010.

For those of us who have aircraft registrations which do not show an “expiration date” (virtually everyone to date), our renewal date will now be determined based on the MONTH in which our registration was issued, sometime in the years between March of 2011 and December of 2013, in accordance with a schedule included in the Rule. So, if your registration was issued in March of 1990, 1995, 2000, etc., it will now expire on March 31, 2011, and you will need to renew it to stay legal. If your registration was issued in February of any year, your registration will expire on December 31, 2013.           

The Final Rule provides that the FAA will send notice to the Registrant –AT THE ADDRESS ON FILE WITH THE FAA – on or about six months prior to the expiration date.  You will be advised that your registration will expire on the date on the schedule, and that you must send in your new application for re-registration (on a new form that the FAA is now producing) between five months and three months prior to the expiration in order to give the FAA two months to process and issue your re-registration before your old registration expires.

In the case of registrations that were issued in March of any year, you will be told that you must apply for re-registration between November of 2010 and the last day of January of 2011. This will then give the FAA two months to process your re-registration. You will be warned that, if you apply after the last day of January, 2011, you will be at risk if the FAA doesn’t renew your registration before your old registration expires at the end of March.

As usual, there is a NEW FEE attached to this process. After much wrangling, however, the fee for re-registration has been kept at the same as the fee for initial registration when the aircraft is transferred: $5.00.  Considering some of the fees that were being suggested, this is a gift to the aircraft owning community. Our cost of aircraft ownership has just gone up by less than two dollars a year because of this new FAA paperwork.

One of the key elements of this new Rule is an attempt to address registrations that are incorrect in some way that just stay on the Registry anyway because the FAA has no way to purge them. In some cases, the former owner forgets to send back the old “hard-card” registration certificate. In others, the aircraft is scrapped without being de-registered, or the aircraft owner dies and no one tells the FAA. More commonly, there are errors made when registrants do not meet all of the legal requirements for registering as a corporation, partnership, trust or other entity. The new Rule attempts to correct this situation by putting such registrations, as well as registrations which do not renew as required under the new Rule, in a special category, and, after a period of time, purging those registrations for the Civil Aircraft Registry.

LESSON NUMBER ONE:

MAKE SURE YOUR CORRECT ADDRESS IS ON FILE WITH THE FAA

REGISTRY FOR THE PERSON OR ENTITY THAT IS THE

REGISTRANT OF YOUR AIRCRAFT.

LESSON NUMBER TWO:

MAKE SURE THAT YOU DON’T MISS THE DEADLINE FOR RE-REGISTERING. THE FAA IS GIVING YOU A THREE-MONTH WINDOW, AND IT IS DOUBTFUL THAT THEY WILL HAVE MUCH SYMPATHY FOR YOU IF YOU DON’T GIVE THEM THE TWO MONTHS THEY WANT TO PROCESS YOUR RENEWAL.

LESSON NUMBER THREE:

CHECK THE REGISTRATION STATUS OF YOUR

AIRCRAFT ON-LINE AT www.faa.gov.
IF THERE ARE ANY NOTES THERE THAT YOU DIDN’T

EXPECT, YOU NEED TO STRAIGHTEN IT OUT
– RIGHT NOW!

NOTE: If you want to have a really exciting afternoon, try flying an aircraft without a valid registration on file back into the US from overseas. You will get an up close glimpse of our Customs agents, TSA folks, and all of the other arms of Homeland Security in action.  Your view may be a bit impaired by the asphalt of the ramp to which your face will be pinned by a boot, but it will still make quite an impression.

Mandatory Re-registration And It’s Consequences

I have always had a great deal of respect for the FAA’s aircraft and pilot registration branch in Oklahoma City.  Perhaps it’s where they are located or the task they are assigned to do, but in my book those folks have always been very courteous and responsive.  However, the new aircraft registration rules may give us all a reason to fret.

It’s not the people working at the office I am concerned about, it’s the new aircraft “re-registration” rule they will soon be enforcing.  It basically requires that every aircraft be re-registered, every three years.  The reason is sound enough: To keep the registration data base up-to-date. It is the unintended consequences that I am most concerned about.

Re-Register – Or Else

As it is now, the FAA Registration Office sends out a triennial survey asking if there are any changes to the information on your aircraft record. If there are none, then you don’t have to do anything; if there are changes, you make them on the form and mail it back. In the new system, you MUST go on-line and confirm that the information is correct. If you don’t do that, in 90 days your n-number will be canceled. Canceled N-numbers will be put in a pool, held for five years then released for reassignment to another aircraft.

Your Newly Invalid Airworthiness “Is Not Our Problem”

There are several points of concern in this process. One is: When an aircraft registration is canceled, the Airworthiness becomes invalid [see: Title 14, Part 21, § 21.181, (3) (iv)].  If you re-instate the aircraft registration later, do you also re-instate the Airworthiness? Apparently not. What if the n-number is reassigned (remember the Airworthiness has the N-number on it)?  The attitude of the Registration Branch seems to be: “That’s your problem, not ours.”

Not Re-Registered? You Start From Scratch

Another issue: What happens to the proverbial “plane in a barn” (or anywhere else) whose owner has not re-registered?  For example: I am always on the lookout for vintage aircraft that have been parked in a barn for years. I have found and purchased just such aircraft in the past. I do what is necessary to return them to service, send in the Bill of Sale and change in Registration and I’m ready to fly. Under the new rules, I may well have to apply for a different n-number (changing n-numbers is something we cringe at doing) and apply for a completely new Airworthiness with the appropriate FSDO – not the Aircraft Registration Branch whose new rule led to the invalidation of my original Airworthiness to begin with.

Expired Registration?

Call me cynical but I believe that there is a sub-current in the FAA that does not really want vintage aircraft flying in the Standard Category. If you must apply for a new airworthiness, my bet is they will try to tell you to make the aircraft Experimental. This is just one more way to get older aircraft out of the Standard Category.

Then there is the issue of companies, or individuals, owning multiple aircraft. You would think that there would be a method to consolidate your fleet registrations so that you could renew all of them at once, but there is not.  It will be like Chinese Water Torture. Multiple aircraft owners will need to be filling out forms on the Internet as often as their aircraft come up for renewal. It would be far easier if those registrations could be consolidated into one time period.  The FAA’s argument against this is that there would be too many processing peaks in data being submitted.  But then again, they argue that the entire process has been simplified and sped up by the new all-electronic method.  Sure, some will need individual attention in special cases, but corporate and other multiple aircraft owners are more likely to have clean, easily processed data to begin.

To be sure, a good clean aircraft registration database is in everyone’s best interest. The problems are the unintended consequences, or perhaps convenient consequences furthering more subtle – and less desirable – agendas.  

We have reproduced the FAA brochure that was being handed out at Oshkosh explaining this program. Just click here to see it: FAA New Re-Registration and Renewal Procedures.