Safety Recommendation A-01-075

We note that the final rule titled “Re-Registration and Renewal of Aircraft Registration” was published on July 20, 2010, and included revisions to Part 47 that require (1) re-registration of all US civil aircraft over a 3-year period and (2) the periodic renewal of that registration every 3 years thereafter. We also note that notifications are sent to the registered owner’s address of record and that if an owner fails to re-register or renew in a timely manner, the registration expires and, eventually, the aircraft’s assigned N-number is cancelled.

We believe that these systematic improvements, which have resulted in a significant reduction in the numbers of (1) aircraft in “sale reported” and “registration pending” status and (2) registered aircraft in the inventory satisfy Safety Recommendation A-01-75. Accordingly, it is classified CLOSED—ACCEPTABLE ACTION.

The FAA’s only letter concerning Safety Recommendation A-01-75, dated January 22, 2002, stated that the FAA had established a two-person team of legal instruments examiners to improve the currency and accuracy of the data contained in the Civil Aircraft Registry. These examiners were to focus on aircraft in the “sale reported” and “registration pending” status, as well as aircraft with a status code denoting “non-useable addresses.” Based on this information, Safety Recommendation A-01-75 was classified OPEN—ACCEPTABLE RESPONSE on May 2, 2002. In the 12 years since the FAA’s January 2002 letter, we have received no additional information regarding its actions to address the recommendation.

-From Michael P. Huerta, Administrator: In the Federal Aviation Administration's (FAA) January 22, 2002, letter to the Board, we agreed with the intent of this recommendation and implemented a plan to accomplish its stated goals. The implementation of the Registry Modernization System in February 2008 facilitated significant improvements in the availability of updated aircraft owner information.

Changes to aircraft ownership information are available to users of the Civil Aviation Registry essentially overnight rather than after days or even weeks of processing these changes using the previous records storage media.

Many of the deficiencies in aircraft owner contact information were a result of non-compliance with pre-existing regulatory requirements for which there were no immediate consequences (such as§ 47.45, Change of Address). The FAA completed changes to part 47 that required the re-registration of all U.S. civil aircraft over a 3-year period and the periodic renewal of that registration every 3 years thereafter in the Re-Registration and Renewal of Aircraft Registration Final Rule on July 20, 2010 (75 FR 41968). All notifications to owners concerning reregistration and renewal of registration are sent to the registered owner's address of record.

Failure to re-register or renew registration in a timely manner results in expiration of registration and eventually cancellation of N-Number assignment for the aircraft. The introduction of real and serious consequences for failure to maintain current contact information significantly increased the accuracy and currency of aircraft owner contact information since the rule was implemented in October 2010. In addition to the consequences associated with failure to re-register or renew registration, time limits on "sale reported" and "registration pending" records were implemented.

Under the new rule, the registration of an aircraft in "sale reported"

Safety Recommendation A-01-074 and A-01-075 was reiterated in NTSB's May 12, 2005 letter of recommendation to the FAA, issuing recommendations A-05-11 through -13.

The FAA has stated that it agrees that improvements should be made to the General Aviation, Air Taxi and Avionics Survey (GAATAS) and that it is working with a group of industry and government representatives (including Safety Board representatives) to produce a detailed implementation plan to address the issues noted by the safety recommendations. The Safety Board appreciates the FAA's efforts to improve the activity survey form and is committed to working with you to make the improvements.

The FAA has stated that it will meet with the General Services Administration (GSA) to harmonize the definitions of public use aircraft and public use flight operations with GSA data collection activities. The Safety Board would appreciate having the opportunity to review the changes agreed upon by both agencies.

Regarding Safety Recommendation A-01-75, the FAA states that it agrees with the intent of this recommendation and in January 2002 began efforts to establish a two-person team of legal instruments examiners to improve currency and accuracy of the data in the Civil Aircraft Registry. The FAA reports that the legal instruments examiners will focus on the aircraft in "sale reported" and "registration pending" status, as well as aircraft with a status code denoting "non-useable addresses." The Safety Board concurs that these potential improvements are an important undertaking, and looks forward to reviewing the progress of this action.

Accordingly, Safety Recommendations A-01-73 thru -80 are classified OPEN -- ACCEPTABLE RESPONSE pending completion of the recommended actions.

Letter Mail Controlled 01/29/2002 4:07:36 PM MC# 2020092 - From Jane F. Garvey, Administrator: The FAA agrees with the intent of this safety recommendation to improve the currency of information in the Civil Aircraft Registry. The FAA is establishing a team of two legal instruments examiners whose sole duty will be to improve the currency of the data in the Civil Aircraft Registry. The legal instruments examiners will focus on two areas. They will first develop factual data on aircraft in the "sale reported" and "registration pending" categories.

Secondly, they will address the problem of the 30,000 addresses currently shown as undeliverable by the United States Post Office through cross-reference with the airmen database, through internet resources and other means to identify and update aircraft owner status. This effort began in January 2002. The legal instruments examiners program will improve the currency and accuracy of the information in the Civil Aircraft Registry. This, in turn, will allow the FM to measure and track the currency of aircraft owner contact information using the current data as a baseline of progress.

The Civil Aircraft Registry is a sophisticated data system, which tracks the status of more than 348,000 aircraft. The enclosed chart shows the breakdown of all aircraft as of December 11, 2001. The two main categories are the registered aircraft (307,718 or 88.4 percent) and the aircraft in a nonregistered status (40,347 or 11.6 percent). As illustrated in the enclosed chart, all of the nonregistered aircraft are carefully tracked according to the reason for nonregistration. As stated earlier, the legal instruments examiners will focus on the aircraft in "sale reported" and aircraft in "registration pending" status.

A significant issue with the registry data is the 30,533 aircraft that have a status code that denotes an undeliverable address. This group of aircraft is also a priority of the legal instruments examiners. The Civil Aircraft Registry address status chart is provided to the Board to demonstrate that first, the registry data system is more accurate than indicated by the FAA contractor. The FAA is aware of the problems with registry accuracy and has targeted measurable system improvements through the legal instruments examiners program.

It is important to note that there are regulatory requirements as well as proactive FAA programs in place, which are focused on the accuracy of aircraft owner information. These include: §