Federal Aviation Administration issues Final, Comprehensive Changes to Aircraft Registration Requirements

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Introduction

On July 20, 2010, the Federal Aviation Administration (“FAA”) issued a final rule, Re-Registration and Renewal of Aircraft Registration, http://edocket.access.gpo.gov/2010/ pdf/2010-17572.pdf (“Final Rule”), that will require the re-registration of all aircraft registered prior to October 1, 2010. In addition, the Final Rule states that all aircraft registrations issued after October 1, 2010 will expire and, therefore, need to be re-registered every three (3) years. These changes will have a significant impact on many and will likely result in numerous unanticipated adverse consequences.

Summary of New Rules

Prior to the issuance of the Final Rule, aircraft registrations did not expire and were effective until the aircraft was either sold, deregistered, or otherwise disposed of. The Final Rule changes this longstanding law. The FAA, in its Executive Summary portion of the Final Rule, states that the Final Rule is necessary for numerous reasons. The FAA estimates that approximately one-third (1/3) of the 357,000 registered aircraft records it maintains are inaccurate and that many aircraft associated with those records are likely ineligible for registration.

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