March 14, 2008

What's at Issue
The Federal Aviation Administration (FAA) is proposing a three-year aircraft "re-registration" requirement that would replace the current triennial registration reporting requirement.

Why It's Important
Aircraft re-registration hasn't been required since 1978, when the FAA had an annual aircraft re-registration cycle followed by a triennial reporting requirement. However, poor triennial reporting completion rates have caused the registry to become seriously inaccurate.

Major Provisions

Re-registration
The FAA is proposing a three-year aircraft "re-registration" requirement that would replace the current triennial registration reporting requirement. Should re-registration not be accomplished within the specific timeframes, the aircraft Registration Certificate would expire and the N-number assigned to the aircraft would be administratively cancelled.

Treatment of Aircraft in "Transition"
The FAA considers six months in "sale reported" and 12 months in "registration pending" as the maximum reasonable time an aircraft should remain in these transitional categories. When these time limits are exceeded, the FAA may cancel assignment of N-numbers.

Penalties for Non-Compliance
The proposed cancellation of the certificate and assigned N-number stands in contrast to the current situation in which a registered owner's failure to comply with regulatory (registration) requirements generally has no immediate consequences.

Failure to comply with the registration and re-registration requirements of this proposed rule would effectively prevent an aircraft from operating in the National Airspace System almost immediately upon becoming non-compliant.

Costs
The current one-time aircraft registration fee is $5. Although the re-registration notice of proposed rulemaking (NPRM) would apply the $5 fee to each recurrent renewal, the FAA has informed the industry that it wants to increase the fee structure. Initial registration and triennial renewals could carry a $130 fee should the FAA obtain from Congress the necessary authority to raise fees.

NATA Position
NATA supports the continuous improvement in the availability, accuracy and completeness of all general aviation data such as aircraft registration and annual utilization. A three-year aircraft "re-registration" requirement in lieu of the current triennial registration reporting requirement is expected to increase the accuracy of the Civil Aviation Registry and, on its own, should not pose a significant additional burden. However, NATA remains concerned about the potential for ever-increasing fees under the FAA's funding proposals.

Status
The FAA is seeking comments on the NPRM by May 28, 2008. NATA encourages member input on the proposed rule. Members are asked to review the proposal, assess how it might affect their current or future aircraft ownership plans, and provide the staff contact listed below with any pertinent information.

For general press inquiries, contact Shannon Chambers at 703-298-1347 or schambers@nata.aero. 

The National Air Transportation Association (NATA) has been the voice of aviation business for more than 80 years. Representing nearly 3,700 aviation businesses, NATA’s member companies provide a broad range of services to general aviation, the airlines and the military and NATA serves as the public policy group representing the interests of aviation businesses before Congress and the federal agencies.