The Rule

In an effort to reduce the number of improperly-registered aircraft on the FAA Civil Aviation Registry, 14 CFR �47.40 (Part 47.40) has been amended to provide that every FAA AC Form 8050-3 Certificate of Aircraft Registration issued on or after October 1, 2010, will expire three years after the date of issuance. The expiration date will appear on the Certificate of Aircraft Registration.

For those aircraft with Certificates of Aircraft Registration issued prior to October 1, 2010, the FAA has assigned expiration dates. The expiration date of a Certificate of Aircraft Registration issued before October 1, 2010, depends on the month during which the Certificate of Aircraft Registration was issued, regardless of the year, as illustrated in the table below. The issue date can be found on the bottom, left-hand corner, in the box labeled, "ISSUE DATE".

As illustrated above, a Certificate of Aircraft Registration issued during the month of March (of any year, including 2010), expires on March 31, 2011. A Certificate of Aircraft Registration issued during the month of September (of any year, including 2010) expires on September 30, 2012.

The Action

Aircraft owners, operators and flight crew must determine the expiration date of the Certificate of Aircraft Registration corresponding to your aircraft. The FAA Civil Aviation Registry should send out a notice to the registrant's address (as it appears in the FAA database � which should be identical to the address on the Certificate of Aircraft Registration) six (6) months before the expiration of the Certificate of Aircraft Registration. This initial notice will contain a unique code that will allow the registrant to renew aircraft registration on-line (using a new feature of the FAA website, which is not yet accessible), presuming no changes are necessary.

If the registrant does not receive or discards the initial notice, or if one or more changes (e.g., an address change) are necessary, the registrant will have no choice but to submit a FAA AC Form 8050-1B Application for Aircraft Registration Renewal (and the requisite fee) during the "Registration Window", shown in the table above, which corresponds to the expiration of the Certificate of Aircraft Registration. The FAA Civil Aviation Registry will not reward proactive efforts; you cannot submit your Application for Aircraft Registration Renewal until the "Registration Window" opens!

You should expect that the FAA Civil Aviation Registry will require more than six weeks to process re-registration applications. The FAA Civil Aviation Registry has indicated that its personnel will try to process re-registrations on a timely basis. However, there is no "safe harbor" for registrants who apply for re-registration on a timely basis.

The Consequence

Unless re-registration is complete and the replacement FAA AC Form 8050-3 Certificate of Aircraft Registration is placed aboard the subject aircraft before the applicable expiration date, the aircraft will be grounded. The fact that the registrant never received notice of the expiration is NOT a defense, nor is the failure of the FAA Civil Aircraft Registry to issue a replacement Certificate of Aircraft Registration before expiration of the original, regardless of when the registrant re-applied.

Operation without a current and valid Certificate of Aircraft Registration aboard an aircraft violates the Federal Aviation Regulations. Operating an aircraft that is not legally registered (e.g., an aircraft which registration has expired) constitutes a crime in many states (including Florida), a violation of the Federal Aviation Regulations, and can result in civil penalties levied against the owner and operator, seizure of the aircraft, and may void any otherwise applicable insurance coverage.

If an aircraft is not re-registered within 30 days following expiration of the Certificate of Aircraft Registration, the FAA will send a letter intended to notify the registrant of the impending cancellation. If there is no response within 90 days (or 60 days, if the warning letter is returned as "undeliverable"), the FAA will cancel the registration and the aircraft will be deregistered. Further, for a period of 5 years following cancellation, the registration mark will be unavailable for assignment (to anyone, including the former registrant). In such an event, the aircraft cannot be operated until a new registration number is assigned and painted on the aircraft, the transponder is re-strapped, a new Certificate of Airworthiness is issued (reflecting the new registration mark), and the FAA AC Form 8050-1 Aircraft Registration Application is processed, among other things.

Conclusion

Monitor your re-registration deadlines, and help your customers do it, too! If you have regular customers, you can access the expiration date of their respective Certificate of Aircraft Registrations on the FAA website (http://registry.faa.gov/aircraftinquiry/NNum_Inquiry.aspx). Pilots who fly airplanes that belong to others should add a checklist item to ensure the Certificate of Aircraft Registration has not expired. Warn your valued clients and customers in advance of expiration. By doing so, you can build loyalty and save them untold aggravation and expense!