Aircraft registration proposal hints at cost-based user fees

February 29, 2008

Aircraft registration proposal hints at cost-based user fees

By AOPA ePublishing staff

In an effort to bring the U.S. aircraft registry up to date, the FAA is proposing a three-year aircraft “re-registration” requirement that would replace the current triennial registration report. Seems harmless at the surface. But AOPA has found that the proposal includes a discussion about the FAA’s ill-fated user fee proposal and the potential for large increases in the registration fee.

Right now, the one-time aircraft registration fee is $5. While the re-registration proposal applies the $5 fee to its recurrent renewal, the agency has made it clear that it wants to increase the fee. That could be a $130 initial registration fee and a $130 renewal fee every three years.

“While the FAA wants to bring the aircraft registry up to date for a number of reasons, including some security related, the move shouldn’t be linked to a dramatic increase in registration fees or the implementation of user fees,” said Andy Cebula, AOPA executive vice president of government affairs. “Aircraft owners also shouldn’t be expected to bear the burden of immediately correcting a system that has deteriorated over time.”

Aircraft re-registration hasn’t been required for three decades. From 1970 to 1978, the FAA had an annual aircraft re-registration cycle. Because the registry was up to date at the end of that period, the FAA lifted the mandate and a few years later adopted the triennial report. However, poor triennial completion rates have caused the registry to languish. Now, nearly one third of the 343,000 U.S. aircraft registrations are possibly invalid.

How would it be implemented?

If the proposal became a rule as is, and you purchased a Cessna 172 after it went into effect, you’d need to send in the bill of sale and aircraft registration, along with a fee. Then you’d receive a registration certificate with an expiration date for 36 calendar months later.

The FAA says that it would send you a renewal notice with a three-month window when it’s time for you to re-register the airplane. If your registration information did not change within those three years, you could simply renew it and pay the fee online.

But the compliance process would change if you already owned an aircraft when the rule took effect.

Let’s say you owned a Cirrus SR22 when the rule went into effect. The FAA would assign you a three-month window, based on your initial aircraft registration, in which you could re-register. But you couldn’t do it ahead of time, and if you did it late, you couldn’t fly your airplane until it was re-registered. After your first re-registration, the certificate would have a 36-calendar-month expiration limit.

Here’s a calendar of the FAA’s proposed phase-in plan for those who would already own their aircraft at the time the rule would take effect.

If the certificate was issued in Then, you must re-register between
January 10/1/2008 and 12/31/2008
February 1/1/2009 and 3/31/2009
March 4/1/2009 and 6/30/2009
April 7/1/2009 and 9/30/2009
May 10/1/2009 and 12/31/2009
June 1/1/2010 and 3/31/2010
July 4/1/2010 and 6/30/2010
August 7/1/2010 and 9/30/2010
September 10/1/2010 and 12/31/2010
October 1/1/2011 and 3/31/2011
November 4/1/2011 and 6/30/2011
December 7/1/2011 and 9/30/2011

Possible penalty for failing to comply

According to the proposal, pilots flying an aircraft with expired registration could be denied access to the National Airspace System, under the FAA Strategic Operations Security program.

“An aircraft seeking to operated in U.S. airspace will have its identification checked. If the information found is sufficiently inconsistent with the profile of a properly registered aircraft, a pilot deviation will be filed on the operator, and the operator may be denied access to the national airspace,” according to the re-registration proposal.

The FAA is seeking comments on its proposal by May 28. AOPA will continue to sort through the proposed rule and will solicit member input in the coming months. Right now, members should also take a look at the proposal and think about how it could affect their current or future aircraft ownership plans.

February 29, 2008