Regulatory Briefing: FAA's Final Rule for Re-Registration and Renewal of Aircraft Registration.

Read Re-Registration Details in AOPA's Subject Report

Regulatory Briefing: FAA’s Final Rule for Re-Registration and Renewal of Aircraft Registration

The issue

On July 20, 2010 the FAA issued a Final Rule for Re-Registration and Renewal of Aircraft Registration.  This final rule amends the FAA’s regulations concerning aircraft registration. Over a 3-year period, this rule will terminate the registration of all aircraft registered before October 1, 2010, and will require the re-registration of each aircraft to retain U.S. civil aircraft status. These amendments also establish a system for a 3-year recurrent expiration and renewal of registration for all aircraft issued registration certificates on or after October 1, 2010. This final rule amends the FAA’s regulations to provide standards for the timely cancellation of registration numbers (N-numbers) for unregistered aircraft. These amendments will improve the accuracy of the Civil Aviation Registry database and will ensure that aircraft owners provide information to maintain accurate registration records. These amendments respond to the concerns of law enforcement and other government agencies to provide more accurate, up-to-date aircraft registration information.

Background

In an effort to create a more accurate aircraft registration database, the Federal Aviation Administration (FAA) is requiring re-registration of all civil aircraft over the next three years and renewal every three years after that.  The FAA estimates that approximately one-third of the 357,000 registered aircraft records it maintains are inaccurate and that many aircraft associated with those records are likely ineligible for United States registration. The inaccuracies result from failures in the voluntary compliance based system. Although aircraft owners are required to report the sale of an aircraft, death of an owner, scrapping or destruction of an aircraft, and changes in mailing address; many have not. Without owner initiated action, there has been no means to correct those records. The FAA has been asked by government and law enforcement agencies to provide more accurate and up-to-date aircraft registration information. This rule is intended to support the needs of our system users. Re-registration of all U.S. civil aircraft by Dec. 31, 2013 will enhance the database with current data derived from recent contact with aircraft owners. The new regulations also will ensure that aircraft owners give the FAA fresh information at least once every three years when they renew their registration. The FAA will cancel the N-numbers of aircraft that are not re-registered or renewed. 

Re-registration and Registration for Existing Aircraft

AOPA’s position

AOPA is disappointed in the FAA’s decision to move forward with the expiring registration format in the final rule.  AOPA had put forward in our comments a model that would have allowed the FAA a method to achieve the same goals without the expense of reissuing aircraft registrations.  While AOPA supports bringing the aircraft registry up to date, we are concerned that the method put forward by the FAA in this final rule is a considerable undertaking which could lead to significant issues for aircraft owners.   In our comments to the NPRM, AOPA highlighted the need for flexibility in the timing of re-registrations and the need to include incentives  such as longer renewal cycles for controlling the timing of aircraft registrations instead of mandating a rigid schedule.  The final rule includes neither.  AOPA has been and will continue to be in direct communications with the Registry Management highlighting our concerns and addressing issues as they arise.

The rule does leverage an online system for aircraft re-registration and renewal that AOPA proposed in its comments.

Key Points:

• FAA final rule becomes effective October 1, 2010
• Over 3 year period, rule will terminate the registration of all aircraft registered before October 1, 2010
• All existing aircraft will need to re-register over next 3 years and renew every 3 years there after
• FAA providing 3 month window for existing registered aircraft to be re-registered based upon month aircraft was originally registered (see chart below)
• FAA will notify owner via mail, 180 days prior to expiration date and at the end of the re-registration window if not re-registered
• Aircraft failing to re-register or renew will ultimately be deregistered
• Re-registration and renewal utilizes online system if no changes are to be made
• Changes must be made utilizing a new form and submitted to FAA
• All  aircraft applying for new registrations will be issued an expiring registration and required to renew every 3 years
• Current registration fee is $5.00 which would be extended to re-registrations and renewals as well
• Reauthorization Bill, if enacted as passed by the House provides authority to increase fees
• H.R. 915 proposed $130 for new aircraft registrations, and $45 for re-registration and renewal
• Elimination of the Triennial Aircraft Registration Report
• 6 month limit on the time an aircraft may remain in the sale reported category

Links

Final Rule

AOPA’s Comments to NPRM

NPRM

Additional information:

Current statistics about existing registry information (from the notice of proposed rulemaking [NPRM]):

• 343,000 aircraft are currently on the registry;
• The FAA estimates 104,000, or about one third, are possibly invalid for one reason or another;
• 17,000 aircraft have been reported as sold by their former owners without the purchasers making application for registration (with about 15,900 being in the “sale reported” category for more than six months);
• 4,700 have started registration without completing the requirements (with about 2,100 being in the “registration pending” category for more than 12 months);
• About 30,100 aircraft are known to have bad addresses well beyond the 30 days allowed for reporting changes;
• Almost 14,700 aircraft have had their certificates revoked due to bad addresses but remain in the system to prevent reassignment of their U.S. registration number (N number) until the FAA is positive the aircraft is no longer operating with that N number; and
• Up to 41,000 additional unidentified aircraft are estimated to be inactive or possibly no longer eligible for registration.

Updated July 29, 2010