Aircraft Re-Registration Rule May be Published Soon
July 8, 2010 —A rule proposed in 2008 by the FAA to update the national aircraft registry in part out of security concerns may soon be finalized. The FAA would require all aircraft to be re-registered with the new registrations valid for three years. Both EAA and AOPA have come out against the proposal saying that there are simpler ways to clean up the registry without requiring owners to pay an additional fee.
EAA recommends the FAA crosscheck its Civil Aircraft Registry database with the various state registration databases to further reduce the number of “possibly no longer eligible” aircraft to around 17,000. Owners in many states are forced to pay high annual registration fees, so it makes sense for the FAA to use these other existing databases to help manage their system, without creating any additional financial burden on aircraft owners.
In comments submitted in 2008 to the Federal Register, EAA called the plan “an unwarranted user fee proposal” designed to place the aircraft registration burden on the backs of the public. In effect, it replaces two existing regulations that have been highly successful in managing the aircraft registration process.
“The FAA has failed to provide sufficient evidence that revising the aircraft registration and re-registration requirements is warranted,” wrote Randy Hansen, EAA’s director of government relations and author of EAA’s comments. “Within the NPRM [notice of proposed rule making] the FAA even questions itself when it answers its own question: How accurate are the records today? The answer: about one-third of them are possibly no longer eligible for registration.” That’s about 104,000 aircraft of the approximate 343,000 total fleet.
“The FAA has failed to prove that there is a reason to cancel all aircraft registration certificates or to mandate that aircraft owners re-register every three years,” Hansen said. “This is a very costly burden on the public that the FAA can accomplish using other means. The FAA’s own data would indicate that the issue is much smaller than presented, and that a major change in the FAA registration system is not warranted.”
EAA encourages the FAA to use the existing FAR 13 legal authority to manage those aircraft owners who do not report as required by the FAR 47.51 Triennial Aircraft Registration Reporting program. To support that process, the FAA could simply issue a public legal notice in the Federal Register (at no cost to the public), with help from aviation groups like EAA in getting the word out.
The rule has yet to be finalized, but AirVenture attendees can ask questions about registering their aircraft at a forum presented by Walter Binkley, Manager of the FAA Aircraft Registration Branch, Friday July 30, at 11:30 a.m. in Forum Building #4. Binkley will discuss the upcoming FAA Final Rule that modifies 14 CFR Part 47 to allow for expiration of all certificates of aircraft registration.