AircraftOwner Online

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.