Exem ption No. 10424

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC 20591

In the matter of the petition of

MARYLAND STATE POLICE Regulatory Docket No. FAA-2011-1029

AVIATION COMMAND

for an exemption from § 47.15(b) of Title 14, Code of Federal Aviation Regulations

DENIAL OF EXEMPTION

By letter dated Septem ber 12, 2011, Mr. Williams S. Bernard, Director-Flight Operations, Maryland State Police Aviation Command (MSPAC), 3023 Strawberry Point Rd., Baltimore, Maryland 21220, petitioned the Federal Aviation Administration (FAA) on behalf of the MSPAC for an exemption from § 47.15(b) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption, if granted, would allow it to obtain special registration

numbers for their new fleet of AW139 aircraft.

The petitioner requests relief from the following regulation:

Section 47.15(b) prescribes that “A U.S. registration number may not exceed five symbols in addition to the prefix letter “N.” These symbols may be all numbers (N10000), one to four numbers and one suffix letter (N1000A), or one to three numbers and two suffix letters (N100AB). The letters “I” and “O” may not be used. The first zero in a number must always be preceded by at least one of the numbers 1 through 9.”

The petitioner supports its request with the following information:

The petitioner states it would like to use the registration numbers “N1MSP” through “N11MSP” for its new AW139 fleet. The petitioner notes that MSPAC has gone to great lengths in the design and appearance of the new aircraft, which will visibly be marked with “Maryland State Police.” The requested registration numbers will enhance the appearance and make it obvious as to the identity of the aircraft operator.

AFS-11-463-E2

In addition, the Maryland citizens fund the medevac program through a transportation surcharge added to their registration fees. If these numbers are allowed to be used, when the citizens see these helicopters “they will identify with their support and an understanding of the multi mission profile of over 140,000 medevacs in the programs history.” Use of these registration numbers would also make it easier to track aircraft

and maintenance.

The petitioner feels that since its request deals strictly with the aircraft registration and not how the aircraft are operated, this exem ption would not adversely affect safety.

A summary of the petition was published in the Federal Register on October 24, 2011 (76 FR 65772). No comments were received.

The FAA’s analysis is as follows:

Section 47.15(b) defines the configuration of a United States aircraft registration number. It provides notice worldwide to the format of a valid United States aircraft registration number. This information is reproduced in countless publications and the parameters are part of computer systems worldwide.

The FAA, Civil Aviation Registry, Aircraft Registration Branch (Registry), has five components to their computer system: 1) Ai rcraft Registration Database, 2) Document Control System, 3) Registration Moderniza tion System, 4) Electronic Data Retrieval System, and 5) The FAA Aircraft Registrati on Website. The system infrastructure is designed to accept the configuration of the registration number as defined in § 47.15(b).

All aircraft records on the United States Civil Aircraft Register are maintained through the Aircraft Registration Database, Do cument Control System, Registration Modernization System, and Electronic Data Retrieval System components of the Registry computer system. Records are stored as digital images. All aircraft records are public records and copies are available to anyone upon request.

Controls have been programmed into the Registry’s computer system to prevent accepting data and the creation of an aircraft record for registration numbers that do not meet the criteria in § 47.15(b). MSPAC states that it has made N-number inquiries for both “N1MSP” and “N11MSP” in the FAA Civil Aviation Registry website. The responses were “Not Assigned/Reserved” and did not indicate “incorrect or impossible elements.” An N-Number inquiry is a query for a registration number. If the system finds the registration number is reserved, assigned, or a cancelled record, it will display pertinent information, e.g., last registered owner’s name and address, etc. This is not to be confused with the acceptance of data which includes document images, actions taken with these documents, and a multitude of other components. The correct response to the queries in the website should have been “N-number Not Valid.” The3

Registry was not aware of this and has forwarded this information to the office responsible for the website.

To allow assignment of these numbers would first require reprogramming of all components of the computer system to accept registration numbers with three suffix letters. It would also configure the computer system to accept registration numbers that do not comply with § 47.15(b). It would be a far-reaching, labor-intensive, monetarily costly, time-consuming modification. The Registry’s computer system is also interconnected to many other FAA systems, including Air Traffic Control, and other law enforcement and international programs, all of which would require program modifications and funding for the accommodation. If this exemption is granted, these registration numbers could not be used until all modifications to all FAA computer systems are accomplished and all FAA personnel are notified of this exemption. A

definite date would be difficult to determine.

The International Civil Aviation Organization (ICAO) sets the standards and regulations necessary for international aviation safety, security, and environmental protection on a global basis. It serves as the primary forum for cooperation in all fields of civil aviation among its Member States. The United States of America is a Member State. The primary obstacle to the grant of this exemption involves the ICAO aircraft

addresses. It is not a coincidence that the total number of N-Numbers available for assignment to U.S. aircraft is exactly the same as the total number of ICAO addresses allocated to the Registry. ICAO provides an allocation of 24-bit aircraft addresses to the Member States. These 24-bit address patterns represent the most significant bit (MSB) of the address. There is a complex algorithm that defines the correspondence between the ICAO address, the Mode ‘S’ address, and the N-number. Each N-number has a specific ICAO address associated with it. Modifying the length and composition of the current N-number structure would obstruct compliance with the world-wide scheme for allocation, assignment, and application of aircraft addresses.

MSPAC has not demonstrated how the use of 11 “special” registration numbers would make the aircraft operator more obvious to Maryland citizens, has not shown how it would benefit the public in general, and did not explain how it would make it easier to track the aircraft and maintenance. If the exemption was granted, the cost in time, money, and personnel, to the FAA and all the other government agencies affected, would be a burden to the taxpaying public. The allowance to use these numbers would also cause confusion to many of the aviation community who see these aircraft, which would lead to multiple inquiries to FAA offices, airports, and law enforcement agencies, regarding the validity of the registration numbers and aircraft ownership.4

The FAA’s Decision:

In consideration of the foregoing, I find that a grant of exem ption would not be in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. §§ 40113 and 44701, delegated to me by the Administrator, the petition of Maryland State Police Aviation Command for an exemption from 14 CFR § 47.15(b) is hereby denied.

Issued in Washington, D.C., on January 6, 2012.

/s/

John W. McGraw Acting Director, Flight Standards

Service