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an aircraft and it was registered for good as long as you continued to operate it. However, the days of a permanent registration for all aircraft are gone, causing a new headache for corporate flight departments everywhere. Under new FAA rules that took effect last fall, for all aircraft (including helicopters) that were registered before October 1, 2010, the registration expires according a table of rolling dates based on the month the current reg- istration was issued. For example, if your current aircraft registration was issued between March and July of any year, its registration expires some time in 2011. Once re-registered, each aircraft registra- tion then will have to be renewed every three years.

Until the new rule took effect last October,

aircraft registrations did not automatically expire. Once registered, an aircraft remained that way until it was sold, the owner died or changed addresses or the aircraft itself was scrapped or destroyed. Since 1980, the FAA has utilized the Triennial Reporting Program, which involved sending owners a report every 3 years and asking them to return the

report only if there were any changes.

Unfortunately, this policy led to a large number of inaccurate registrations: in its published notice, the FAA estimated that fully one-third of the more than 350,000 aircraft registrations contain inaccu- racies, and the agency laid the blame squarely upon “failures in the voluntary compliance based system.” In other words, according to the FAA, many own-


ers simply did not report a change, or the informa- tion reported ended up being inaccurate. Additionally, the FAA claimed the number of

unopened reports returned to it as “undeliverable” has increased over the years, resulting in unneces- sary expenditures by the agency and by manufac- turers who mail out emergency airworthiness direc- tives, safety notices, and surveys to aircraft owners. Many orders revoking the registration also were returned as undeliverable.

However, because the

FAA had no way of knowing where the aircraft was, whether it had been sold or whether it was still operating, it kept the aircraft in the system to prevent reassignment of the N-number to a sec- ond active aircraft. New registration certificates, whether for

newly registered aircraft or aircraft being re-regis- tered, will have expiration dates three years after they are issued. The expiration will be printed on registration, and also will be listed on the agency’s registry website. Additionally, the FAA will issue two reminder notices to an owner before


scheduled expiration date of an aircraft’s registration. The first will come out 180 days before the regis- tration expires, 60 days earlier than had first been proposed, and will provide the date upon which the registration application must be returned.

expiration date. Should an owner fail to re-register his aircraft,

or fail to renew his registration in time, the penal- ties can be severe.

An aircraft that does not

receive a renewed registration before the old one expires is considered unairworthy. Operating an aircraft without a valid registration could result in civil penalties and certificate actions against both the owner and operator. Allowing a registration to expire may also invalidate some insurance policies or result in a default of leases or loan agreements. Finally, the FAA will cancel registration numbers 90 days after the expiration of a registration, and will make that number unavailable for five years follow- ing the cancelation. To help aircraft owners navigate this proce-

dural headache, the Aircraft Registry database now will post lists on its website showing aircraft as they move through the various stages of re-registration and renewal. According to the FAA, these changes will help owners keep the aircraft continuously reg- istered, and will help keep other interested parties, such as lenders and insurers informed about the registration status of the aircraft. During the rulemaking process, the FAA


filing window for an aircraft registration will close two months prior to the expiration date, and while the FAA still will process registrations received less than 60 days prior to the expiration date, it will not guarantee the issuance of a renewal prior to the


received almost 100 comments from all segments of the aviation community.

The comments from

the commercial side focused on the cost of com- pliance with the new reporting requirement. Commercial commenters contended the FAA underestimated the costs to some aircraft owners because a high percentage of commercial and cor-

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