Re-registration and Renewal of Aircraft Registration

EAA would like to submit these additional comments to the EAA comments for FAA-2008-0188-0085. EAA would like to offer a no cost alternative to the very costly 3-year aircraft registration renewal proposal in NPRM FAA-2008-0188. 14 CFR part 47.45 (Aircraft Registry) and 61.60 (Airmen Registry) both require the holders of these certificates to submit address changes within 30 days of the change. The owners of a large percentage of the 340,000 aircraft in the aircraft registry database also hold pilot certificates. From the NPRM, EAA could not determine of the Aircraft Registry Branch coordinates received change of addresses with the Airmen Certification Branch. Reviewing the FAA web site it is clear that these two address change processes are kept totally separate. EAA recommends the change of address notification process be all enclusive - changing one will result in the change of the other database. To do this, we recommend using this web site - http://www.faa.gov/licenses_certificates/airmen_certification/airmen_services/ - and add an addition function to the follow-on on-line change of address form *Change your Aircraft Registration address Then on the follow-on form add a block to enter the aircraft N-number. Then when submitted both the Aircraft Registry Branch and the Airmen Certification Branches would be notified of the change of address. Randy Hansen EAA Government Relations Director

Filed on regulations.gov — full text not in the inline record.

NPRM, FAA-2008-0188, proposes to change Sec. 47.33 to read: Sec. 47.33(a)(2) "Submits with his Aircraft Registration Application, AC Form 8050-1, an Aircraft Bill of Sale, AC Form 8050-2, signed by the seller, an equivalent bill of sale, or other evidence of ownership authorized by Sec. 47.11." EAA recommends this proposed section be changed to read: "Submits with his Aircraft Registration Application, AC Form 8050-1, an Aircraft Bill of Sale, AC Form 8050-2, signed by the seller, an equivalent bill of sale, an invoice from the manufacturer of an aircraft kit, or other evidence of ownership authorized by Sec. 47.11." Reason: On May 20, 2004 EAA submitted comments to DOT Docket No. FAA- 2004-17168(-0016) stating that the lack of the wording an invoice from the manufacturer of an aircraft kit, causes an adverse administrative burden on the FAA and the aircraft builder. This concern still exists today within the experimental amateur-built, experimental light-sport aircraft, and ultralight vehicles (seeking certification as E-LSA) aviation communities. EAA urges the FAA to review the issues as stated in FAA-2004-17168-0016, and make the change as part of this NPRM. Since this NPRM makes a change to Sec 47.33(a)(2) this request is within the scope of this rulemaking action. Randy Hansen EAA Government Relations Director