April 19, 2004
U.S. Department of Transportation
Docket Management System
400 7th Street, SW, Room PL-40
Washington, DC 20591-0001
RE: Docket No. FAA-2004-17210 STOP the NOISE, Inc. - Exemption/Rulemaking
The Aircraft Owners and Pilots Association (AOPA), representing over 400,000 general aviation pilots and professionals nationwide submits the following comments to the proposal for larger aircraft registration numbers placed on the underside of aircraft wings. The proposal was submitted by STOP the NOISE, Inc. on February 10, 2004.
AOPA is opposed to any change in regulations requiring aircraft owners to alter the current location of their aircraft registration. 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.
The issue of the size of the registration numbers on general aviation aircraft is not new. The FAA has adequately addressed this issue in the past resulting in today's existing requirements as stated in 14 CFR Part 45 Identification and Registration Marking.
As early as 1960, the FAA decided that aircraft registration numbers on the underside of aircraft wings were of little benefit. After making an initial proposal to require under-wing registration numbers, the FAA decided that "unless the aircraft is flying at an appropriate altitude, attitude, and speed; the observer is situated 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."
In 1977, the Citizens Task Force on Noise Control of Seattle, Washington, petitioned the FAA to provide for under-wing markings on aircraft. Over 3,000 public comments were received in response to the notice, almost all of the commenters opposed it. The FAA agreed with those commenters who were of the opinion that the proposed under-wing marks would not be an affective means of positive ground-to-air identification. The FAA stated, "...after review of the comments received and all information available on under-wing marks, it is clear that these marks are useful for identification purposes only under ideal conditions."
Mr. William C. Burgonye, President of STOP the NOISE group also addresses the issue of national security in his cover letter. We would remind the FAA that the current requirement for 12" registration numbers on aircraft (with exceptions) was at the request of the Department of Defense (DOD) in 1981. The DOD recommended then that 12" registration numbers would "eliminate the need for military aircraft to closely approach civil aircraft displaying small marks to identify them." This would suggest that the DOD found 12" registration numbers adequate for their purposes.
Registration numbers on the bottom of aircraft would also be of little assistance to the DOD during intercept procedures. Procedures outlined in chapter 5 section 6-2 of the Aeronautical Information Manual do not provide for interception and identification of general aviation aircraft from below. Thus making under-wing numbers of any size irrelevant for this purpose.
AOPA has long advocated pilots taking into account the feelings and sensibilities of airport neighbors, as well as those over whose property they fly. The association produced a video called Flying Friendly, which explains what pilots can do to minimize their noise signature and keep their neighbors happy. The video is available to both individual pilots and pilot clubs. AOPA urges all pilots to watch the video and then be good neighbors.
Director, Regulatory and Certification Policy
Aircraft Owners and Pilots Association