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EAA Critical of FAA Re-Registration Proposal

June 3, 2008 — EAA is opposing increased costs and mandates that would be placed on the flying public by an FAA plan to require a fleet-wide re-registration and subsequent three-year renewal process for aircraft owners. Notice of proposed rulemaking (NPRM) FAA-2008-0188 is the agency’s response to an agency-perceived need to tighten up aircraft registration in the interest of national security. But EAA contends it’s an unneeded and expensive proposal that will add significant costs to already overburdened aircraft owners.

In comments submitted this week to the Federal Register, EAA calls the plan “an unwarranted user fee proposal” designed to place the aircraft registration burden on the backs of the public. In effect, it replaces two existing regulations that have been highly successful in managing the aircraft registration process.

“The FAA has failed to provide sufficient evidence that revising the aircraft registration and re-registration requirements is warranted,” wrote Randy Hansen, EAA’s director of government relations and author of EAA’s comments. “Within the NPRM the FAA even questions itself when it answers its own question: How accurate are the records today? The answer: about one-third of them are possibly no longer eligible for registration.” That’s about 104,00 aircraft of the approximate 343,000 total fleet.

However, after conducting an in-depth review of the NPRM, EAA found that the number of “possibly no longer eligible” aircraft could be much smaller. Subtract 4,700 aircraft the FAA reports whose registrations are pending; 14,700 aircraft with revoked certification; and 17,000 aircraft sold to buyers who have failed to register the aircraft, that number is closer to 67,700 aircraft – less than 20 percent of the fleet.

EAA recommends the FAA crosscheck its Civil Aircraft Registry database with the various state registration databases to further reduce the number of “possibly no longer eligible” aircraft to around 17,000 aircraft. Owners in many states are also forced to pay high annual registration fees, so it makes sense for the FAA to use these other existing databases to help manage their system, without creating any additional financial burden on the public.

“The FAA has failed to prove that there is a reason to cancel all aircraft registration certificates or to mandate that aircraft owners re-register every three years,” Hansen said. “This is a very costly burden on the public that the FAA can accomplish using other means. The FAA’s own data would indicate that the issue is much smaller than presented, and that a major change in the FAA registration system is not warranted.”

EAA encourages the FAA to use the existing FAR 13 legal authority to manage those aircraft owners who do not report as required by the FAR 47.51 Triennial Aircraft Registration Reporting program. To support that process, the FAA could simply issue a public legal notice in the Federal Register (at no cost to the public), with help from aviation groups like EAA in getting the word out.

“EAA understands the need to maintain an accurate Civil Aircraft Registry; however, we are opposed to the method proposed within (the NPRM) FAA-2008-0188 to accomplish this,” Hansen said. “With fuel prices and costs for just about everything else at all-time highs, GA pilots are flying less. Why would the FAA want to add yet another expense that we believe is clearly not necessary?”

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