Apr. 21, 2004 - AOPA on Monday told the FAA to reject a petition from a group called Stop the Noise, asking for mandatory under-wing display of two-foot-high N numbers so aircraft could be more easily identified. AOPA told the FAA that requiring aircraft owners to put large N numbers on the undersides of their wings would serve no purpose and that the FAA has its own studies that already prove the point.
"The Stop the Noise petition is an argument that's already been made and lost," said AOPA President Phil Boyer. "It's a transparent attempt by this group to have the FAA make it easier for Stop the Noise to sue pilots, something we strongly oppose."
"Our opposition to this proposal is based on a number of factors but focuses on the FAA's previous determination that larger registration numbers would not assist those on the ground in the identification of aircraft, as stated in the Stop the Noise proposal," wrote AOPA Director of Regulatory and Certification Policy Luis Gutierrez in formal comments on the petition.
Gutierrez also poked holes in the Stop the Noise argument that under-wing N numbers would aid in national security. Gutierrez reminded the FAA that the current requirement for 12-inch registration numbers is at the request of the Department of Defense. AOPA's comments also note that the under-wing ID would be "irrelevant" to military aircraft trying to intercept and identify a general aviation aircraft because "procedures outlined in the Aeronautical Information Manual do not provide for interception and identification from below."
Gutierrez also noted that the issue of the size of aircraft registration numbers has been around for at least 50 years. But he pointed out that as early as 1960, the FAA determined that "'unless the aircraft is flying at an appropriate altitude, attitude, and speed; the observer is located directly below the flight path; it is during daylight; and weather conditions are favorable, these marks are of little value in effecting positive ground-to-air identification.'"
Again in 1977, in response to another petition for under-wing N numbers, Gutierrez notes, the FAA said that the markings are useful for identification "only under ideal conditions."
"Nothing in their petition alters the FAA's earlier findings, so the agency should reject this request."