NBAA requests clarification on FAA registration deadline extension

On Nov. 16, the FAA signed a final rule to extend the duration of aircraft registration certificates from three to seven years. The rule will become effective on Jan. 15, 2023. The NBAA initially expressed support for the extension and on Wednesday called on the FAA to provide clarification on some of the elements of the new process.

The change was required by the 2018 FAA Reauthorization Act and will relieve some of the burden the agency has faced by lowering the number of ownership renewal applications. This will also allow the FAA to expedite the approval of renewals.

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The rule extends the period an aircraft may be operated on temporary registration certificates, which are issued while the full registration is being processed. These last anywhere from 90 days to 12 months.

The NBAA welcomed the ruling in November and still feels the new rule would “provide clarity and peace of mind to aircraft owners waiting on their permanent certificate of aircraft registration.”

The NBAA also notes that the current writing implies that operators will not receive their amended registration certificates with revised expiration dates. This could lead to issues for any international operator that presents registrations with expired dates while undergoing a foreign ramp inspection.

In the revision, aircraft owners are restricted from applying for renewal until six months before the expiration date. A possible policy change noted by the NBAA suggested allowing operators that travel abroad to apply early or clarify that the FAA will provide new certificates with revised expiration dates to prevent complications while traveling abroad with people who will be unaware of the regulation changes.

“A pathway is needed that allows operators traveling to a foreign destination to renew their certificate early so that they do not need to travel abroad with a certificate that appears expired in case of a ramp inspection,” the NBAA said.

The NBAA warns that many foreign inspectors may be unaware of the FAA registration changes and this could cause problems for international operators.

In comments made by the NBAA on specific technical changes that need to be made before the rule takes effect, it states that in one amendment, a comma is misplaced. The sentence should read “until the date the applicant receives the Certificate of Aircraft Registration, or until the date the FAA denies the application,” moving the comma from after the word date to before the word or to provide greater clarity.

Another change requested is that the FAA provides details about what constitutes inaccurate information and clarification on what would be required if a certificate is found to contain such information, how the FAA will determine if a certificate contains inaccurate information, and how long the owner has to submit a corrected or new form to the FAA.

The new rule was set to take effect 60 days after the initial signing. The NBAA still fully supports the extension, adding at the end of the comments made, “with the clarifications requested, the FAA can ensure a smooth implementation process.”