FAA Proposes Three Year Term for Aircraft Registrations, But Does Not Address Major Underlying Issue.

In February, the FAA issued a Notice of Proposed Rulemaking that would change the current system of registration of aircraft for an indefinite period of time to one that would have a three-year term for each registration (73 Fed. Reg. 10701, February 28, 2008). FAA's rationale for the change appears reasonable -- the current system does not work well, with the result that an enormous number of listings in the registration database contained incorrect information. As the FAA stated:

How accurate are the records today?

Since the annual registration eligibility
requirement ended in 1978, many
aircraft have left service, been sold, or
had owners who moved without
reporting their change of status or
address. Of the more than 343,000
aircraft registered, an estimated 104,000,
or about one-third, are possibly no
longer eligible for registration. Over the
last several years:

• 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 6 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.

Comments were filed last week, primarily by scheduled carriers who argued that they were not causing the problem, and therefore should not have to change the three-year system. The Air Transportation Association filed a seven page, single-spaced, Comment (aren't DOT pleadings still required to be double space?) claiming that the new system would be a substantial administrative burden, primarily because it would be so difficult for the new registration certificate to catch up with the aircraft. This is important because it is an FAA requirement that the registration certificate be physically maintained in the equipment. This really does seem like a makeweight argument -- there is no doubt that airlines can establish administrative procedures for handling registrations.

ATA seems to missed its main argument -- rather than complaining about the burden of processing paper, it should have suggested that the paper itself be eliminated. In this Internet age, why do we need to keep paper copies of registration documents anywhere? Or at least, why do we need registration documents anywhere except in one central location at each carrier. Elevators have inspection certificates, but they are never on the elevator -- they are kept in the office and available for inspection. Why not the same procedure for aircraft registration certificates?

The simple procedure would be for the FAA to maintain an aircraft registration database, available on the Internet, so that anyone who sees an aircraft number on a plane can input it into the database, and get complete registration information. There is simply no need in this Internet age for a piece of paper to be carried on the aircraft.

It would be nice if the FAA were to create an Internet-based registration system. There would be no more need for paper forms -- the registrant would simply fill out the form on the Internet, and the data would go directly into the FAA database. There, it would be available to all FAA personnel and to anyone who inquired in the database without a particular aircraft. Perhaps FAA can create a next-generation registration statement instead of patching the current system.