Regulatory and Certification Policy
Regulatory Brief: FAA’s Proposal for Re-Registration and Renewal of Aircraft Registration
The issue
On February 28, 2008, the FAA released a proposal to amend the requirements for aircraft registration. Based on the need to increase and maintain the accuracy of aircraft registration information in the Civil Aviation Registry, the FAA is proposing to replace the existing one-time non-expiring aircraft registration. The proposed new re-registration would be good for three years and have an expiration date and a renewal requirement. The proposal will require the re-registration of all existing aircraft over a three-year period on a schedule determined by the FAA. Aircraft not re-registered within the specific time frame would have their current registration expire and N number administratively canceled.
Currently, the one-time aircraft registration fee is $5. While the re-registration proposal applies the $5 fee to its initial registration and re-registration and subsequent renewals, the agency also makes it clear that it wants to increase the fees. According to the proposal, “one of the FAA’s goals for its pending reauthorization is to match FAA funding more closely with the costs of providing services.” The President’s proposal for FAA reauthorization included language that would provide for a charge of $130 for initial registration and re-registration of aircraft and a $45 renewal fee every three years after that.
According to the FAA, this change would ensure aircraft owners periodically provide information regarding changes in registration. The proposed rule is in response to the concerns of law enforcement and other government agencies and would provide more accurate, up-to-date aircraft registration information to all users of the Civil Aviation Registry database.
The comment period closes May 28, 2008.
AOPA’s position
AOPA supports enhancing the validity of the aircraft registry but wants to ensure that any new requirements and fees do not impose unnecessary burdens on pilots. 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. Aircraft owners shouldn’t be expected to bear the burden of immediately correcting a system that has deteriorated over time. Pilots should also be allowed flexibility in determining in which month their registration and subsequent renewals occur. The FAA should consider using incentives such as longer renewal cycles for controlling the timing of aircraft registrations instead of mandating a rigid schedule.
FAA’s proposal for re-registration and subsequent renewal of currently registered aircraft:
In order to transition from the current non-expiring aircraft registration to one with a three-year expiration date printed on the certificate, the FAA is proposing that all existing aircraft be re-registered. To manage the registry’s workload, the FAA is proposing to spread the re-registration over a three-year period beginning October 2008 and ending September 2011. Owners would be given one three-month window within this three-year period to re-register their aircraft. The window for re-registration would be based upon the month of current registration of the aircraft.
Below is 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 (REGARDLESS OF YEAR) | 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 |
Under the proposal, owners will not be allowed to re-register early or late. If an aircraft is not re-registered during the FAA-assigned three-month window, the registration would expire and the N number would be administratively canceled, which could lead to denied access to the National Airspace System.
Aircraft will then have to renew their registrations every three years after the initial registration or re-registration.
FAA’s proposal for new aircraft registrations and subsequent renewals:
All new aircraft registrations after issuance of the rule would be issued with a three-year expiration date. Before expiration, the owner will need to renew the aircraft registration. The FAA proposes that if there are no changes, the owner will be able to renew their registration and pay the subsequent fee online.
Current aircraft registration requirements:
Registration for each aircraft is required prior to the aircraft being flown and is issued with no expiration date. Current cost of aircraft registration is $5. The FAA attempts to update the aircraft registry with the use of its triennial aircraft registration report. Triennial aircraft registration reports are sent to the registered owners of aircraft as a means to monitor, among other things, fleet size. Recipients are usually those holders who have not submitted any type of paperwork to the FAA aircraft registry, such as change of address, within the preceding 36 months. Recipients are supposed to return the completed form within 60 days of receipt.
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.
Posted Friday, April 18, 2008
