Several Washington, D.C.-based general aviation associations last week expressed reservations about the FAA´s proposed major changes to the Aircraft Registry (BA, March 3/96). Citing a need to increase and maintain the accuracy of data in the Civil Aviation Registry, FAA said it wants to institute new procedures, including reregistration of all current active aircraft and renewal of all registration certificates every three years. FAA, which would require aircraft operators to update their registrations even if ownership of an aircraft does not change, claims that the extra paperwork would not impose significant costs on owners.
The Aircraft Owners and Pilots Association disagrees, saying that the agency´s plan could increase the cost of registering an aircraft to $ 130 from the current $ 5. "While the FAA wants to bring the Aircraft Registry up to date for a number of reasons, including some security related, the move shouldn´t be linked to a dramatic increase in registration fees or the implementation of user fees," said Andy Cebula, AOPA´s executive vice president of government affairs. "Aircraft owners also shouldn´t be expected to bear the burden of immediately correcting a system that has deteriorated over time."
National Air Transportation Association officials also are concerned about the impact of higher registration fees. Stan Mackiewicz, the association´s government and industry affairs representative, said that NATA has been working with the FAA to continually improve the accuracy, completeness and availability of GA data. However, he is concerned that a large registration fee increase would affect the affordability of flying, especially for smaller operators. "Anything that will raise the price of operation in a flight training department will adversely impact our ability to attract new talent [to the industry]."
National Aircraft Resale Association President Susan Sheets has numerous concerns with the proposed rule. "NARA wants a registry that is up to date. That would benefit everybody, but this rule is not the way to do it." She called provisions of the regulation that would cancel registrations if owners did not respond accurately and promptly to FAA registration renewal requests "heavy handed."
"We also are particularly concerned about ´pink slip´ authority, which is critical to aircraft sales transactions," added Sheets. Under the FAA proposal, aircraft operators could only fly an aircraft for up to 12 months using a duplicate copy of the registration application (the so-called "pink slip"), together with an approved registration extension from the FAA.
Finally, Sheets said that how the new FAA rules would work in conjunction with the latest international regulations, as embodied in the Cape Town Treaty, "are not even addressed."
Mike Nichols, the National Business Aviation Association´s vice president of operations, education and economics, said, "We understand and appreciate the FAA´s desire to increase the accuracy of the Aircraft Registry, but we want to ensure that any changes are implemented in a sensible way that minimizes the impact on operators. We plan to develop some options that we will propose to the agency."
For example, Nichols suggested that the FAA consider exempting fractional aircraft from the reregistration requirements since ownership of aircraft shares tends to change hands every three to five years anyway. "That would help reduce the Registry´s workload," he said.
The General Aviation Manufacturers Association´s vice president of operations, Jens Hennig, supports the concept of reregistering all U.S. aircraft. Citing the need for an accurate Aircraft Registry so manufacturers can ensure that critical operational information reaches all owners, Hennig said, "We applaud the process improvements done by the Registry people over the last decade. With all those improvements recognized, the only thing that can really take it [the Registry] from being pretty darn good to being perfect is to have this reregistration process take place."
All of the associations plan to submit more detailed comments on the proposed rule by the May 28 comment deadline.