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porate aircraft, and a large number of general avi- ation aircraft, are leased to third parties and subject to financing agreements. According to the com- menters, the FAA failed to account for the need by such owners to implement monitoring systems for re-registration purposes, and the cost that would accompany the development and mainte- nance of such systems. The commercial com- menters contended the costs associated with tak- ing the actions necessary to comply with the reg- ulations would be substantial for owners, operators, and financial institutions dealing with large aircraft fleets and should have been included in the reg- ulatory evaluation. While the FAA agreed with many of these


comments, it pointed out in the Final Rule that many operations already have a tracking system for maintenance or scheduling aircraft, and it pointed out that


these systems could be modified or


adapted to help maintain aircraft registration by those who choose to use this method. The FAA stated in the Final Rule issued last


July that the change was prompted by requests from a number of federal and law enforcement agencies, which use the FAA Registry Aircraft Database to obtain information. The FAA also admitted that the current aircraft registry database may contain inaccurate information on up to


Current Certificate Issued In


March of any year April of any year May of any year June of any year July of any year August of any year Now Expires on . . . March 31, 2011 June 30, 2011 September 30, 2011 December 31, 2011 March 31, 2010 June 30, 2012 September of any year September 30, 2012 October of any year December 31, 2012 November of any year March 31, 2013 December of any year June 30, 2013 January of any year February of any year September 30, 2013 December 31, 2013


36.5% of the registered aircraft. Under the new rules, that error rate is expected to decrease to about 5.7%. And as a direct result of the new registration requirements, the FAA contends, law enforcement and security agencies will have access to more accurate registration records. According to the FAA, more reliable notification regarding safe- ty issues should improve aviation safety. However, the new registration requirement


creates a process that is a potential quagmire for those who do not take the time to become com- pletely familiar with it.


In short, be proactive and


make sure you are aware of the re-registration date of all aircraft in your inventory, and then make sure you mark your calendar at least 60 days before the expiration of the new registration. Failing to make yourself completely familiar with these new requirements could leave you with a grounded and unprotected aircraft.. ◆


Hunter Old represents aviation businesses, pilots and mechanics as a partner with the law firm of Kaufman & Canoles, P.C. in Williamsburg, Virginia. He also is licensed as a commercial helicopter pilot, and flew both UH-1s and CH-47s for the Army Reserves. He can be reached at whold@kaufcan.com, or on (757) 259-3870.


Owner Must Apply for Re‐Registration Between These Dates to Allow Timely Delivery of New Certificate . . .


November 1, 2010 to January 31, 2011 February 1, 2011 to April 30, 2011 May 1, 2011 to July 31, 2011 August 1, 2011 and October 31, 2011 November 1, 2011 to January 31, 2012 February 1, 2012 to April 30, 2012 May 1, 2012, to July 31, 2012 August 1, 2012 to October 31, 2012 November 1, 2012 to January 31, 2013 February 1, 2013 to April 30, 2013 May 1, 2013 to July 2013 August 1, 2013 to October 31, 2013 39


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