REGULATORY EVALUATION,

REGULATORY FLEXIBILITY DETERMINATION, TRADE 

IMPACT ASSESSMENT, AND UNFUNDED MANDATES 

DETERMINATION

FINAL RULE

RE-REGISTRATION AND RENEWAL OF AIRCRAFT 

REGISTRATION

(14 CFR 47)

RIN 2120-AI89

OFFICE OF AVIATION POLICY AND PLANS

OPERATIONS REGULATORY ANALYSIS BRANCH

APO-310

Nicole Nance and David F. Teitelbaum

January 2010
TABLE OF CONTENTS

Executive Summary _____________________________________________ i

I. Introduction and Background___________________________________ 1

II. The Final Rule ______________________________________________ 3

III. Cost of Compliance __________________________________________ 4

A. Assumptions and Basic Data.......................................................................4

B. Synopses of Re-registration, Renewal, and Error Rates Calculations ........8

C. Cost of the Current System and Scenarios................................................14

IV. Analysis of Benefits _______________________________________ 19

V. Comparison of Costs and Benefits ____________________________ 21

VI. Comments_______________________________________________ 23

APPENDIX A – Unit Cost Data ___________________________________ 30

APPENDIX B – Explanation of Re-registration and Renewal Calculations__ 34

APPENDIX C – Explanation of Error Rate Calcualtions________________ 50
i

Executive Summary

Summary Of Costs and Benefits in Millions of 2007 Dollars

(over 20 years)

Re-registration and 3-Year Renewal 

(Triennial Eliminated)

Cost Present Value

Of Cost

Benefit:

$29.9 $16.3 Reduction in Error Rate by 31%

The Federal Aviation Administration (FAA) established a rule to correct 

deficiencies in the current registration system, which have led to approximately 

one-third of registered aircraft having a questionable registration status. The 

rule will require all aircraft owners to reregister their aircraft over a three-year 

period, and thereafter renew registration every three years. It will eliminate the 

Triennial Aircraft Registration Report Program. The benefits and costs have 

been calculated for a 20-year period.

The primary benefit of this rulemaking will be the increased accuracy of the 

records within the Aircraft Registry. The FAA has concluded that the level of 

accuracy in the system of records must be significantly improved in order to 

better serve the needs of the users of the system. We expect the rule will reduce 

the current error rate of 36.5% to 5.7%.

The estimated net cost of compliance, after subtracting the current cost of the 

Triennial Program, is $29.9 million ($16.3 million, present value), with an 

expected error rate of 5.7%. The net cost includes cost to aircraft owners, 

processing cost for the Civil Aircraft Registry, and cost savings from the 

elimination of the Triennial Program. These costs cover the 3 initial years 

when all aircraft owners will be required to re-register their aircraft, and the 

subsequent 17 years, when all aircraft owners will be required to renew their 

aircraft registration on a 3-year cycle.

The rule is not expected to have: a significant impact on international trade; a 

significant impact on a substantial number of small firms; or an unfunded 

mandate.
I. Introduction and Background

The Civil Aviation Registry (Registry) is tasked with maintaining the Civil Aircraft 

Register. Entry into this register serves as the initial step toward qualifying an aircraft 

to operate as a U.S. Civil Aircraft within our airspace and internationally. The 

Register contains pertinent information identifying each aircraft and its registered

owner. The information in this database is used to support the delivery of 

airworthiness directives and safety-related information generated by aircraft 

manufacturers, as well as newer proactive programs that provide information for law 

enforcement and homeland security agencies. However, the information within the 

Register is not currently as accurate as the FAA wants it or needs it to be.

From March 1970 through January 1978, aircraft certificate holders were required to 

file an annual report to keep the aircraft register updated and limited to only those 

aircraft eligible for registration. At that time registration data was relied upon for 

traditional safety responsibilities such as creating mailing lists for distributing 

Airworthiness Directives.

The requirement for the annual report was withdrawn in 1978 when the Civil Aircraft 

Register was reasonably current and was expected to remain current through contact 

with aircraft owners over the normal course of business. The amendment 

withdrawing this requirement did indicate that a reporting requirement might need to 

be instituted for aircraft registrants from whom no information was received within a 

reasonable period of time. In 1980, the FAA established such a reporting requirement 

with the Triennial Aircraft Registration Report (Triennial), which prompts aircraft 

owners to report overlooked changes. The Triennial requires the holder of a 

registration certificate to report changes on an aircraft, after three years, unless certain 

aircraft registration activities have taken place during this period.1 The FAA sends out 

about 70,000 reminders yearly. An aircraft registration certificate may be suspended 

or revoked when there is a refusal or failure to submit the report.

The importance of accurate aircraft registration information increased when the 

Congress passed the FAA Drug Enforcement Assistance Act of 1988 (DEA Act) 

 1 The triennial program requirement has required an owner of a registered aircraft that has had no 

activity for the past 36 months to receive a triennial aircraft registration report. The program 

prompts aircraft owner to report overlooked changes in a registered owner’s information, such as 

a change in current name, address, aircraft identification, or citizenship status, the owner is 

required to complete the form and return it to reflect that change. This form has also been used 

to report the sale, destruction, or other disposition of aircraft. This regulation requires the holder 

of a registration certificate to submit a report on an aircraft when three years have passed without 

certain aircraft registration activities having taken place during this period.
2

expanding the FAA’s mission to include providing assistance to law enforcement 

agencies that enforce the laws covering controlled substances. It also identified 

specific shortcomings for the FAA to address so that the aircraft registration system 

will more effectively serve the needs of buyers and sellers of aircraft, law enforcement 

officials, and other users of the system.

Since publication of the DEA Act, the expanded capabilities of desktop and micro 

computing has enabled many of the DEA Act requirements to be met through 

automation and administrative changes rather than rulemaking. Several years ago, the 

FAA handled requests for registration information by telephone, mail, or limited 

access computer terminals, as well as by providing registration lists on microfilm 

updated monthly. Today, aircraft registration data and images of aircraft registration 

documents are increasingly delivered electronically in real-time to agencies 24 hours a 

day allowing for faster and more accurate access to and analysis of the database. 

However, these improvements do not eliminate inaccuracies in raw data.

Currently, to keep its database up to date, the Registry depends on a number of 

regulatory requirements for aircraft owners to report changes in a timely manner as 

well as on the Triennial Program, which prompts overlooked changes to be reported. 

Unfortunately, of the almost 357,000 aircraft registered, about 31.5%, or an estimated 

112,400 have questionable registration status, leaving about 244,600 active aircraft. 

That almost 31.5% of registered aircraft are no longer active is due to many aircraft 

that have left service, been sold, or the owners have moved without the change of 

status or address information being reported. Removing ineligible aircraft from the 

database will eliminate a large pool of U.S. registrations (N-Numbers) that can 

facilitate drug, terrorist, or other illegal activities.2

Moreover, the Registry also lacks accurate information on a portion of the estimated 

244,600 active aircraft:

• At any point in time, a portion of these active aircraft on the register will reflect 

inaccurate registration information. This is based on experience from the triennial 

report notices sent annually to registration holders that result in:

o Approximately 9,000 overlooked address changes being reported;

o Approximately 5,000 aircraft with undeliverable addresses identified; and

o An undetermined number of notices that reach registered owners who choose 

not to report their aircraft’s sale or destruction.

 2 As described in the Background portion of the Preamble, the FAA, in concert with TSA, is 

evaluating flight plan filings to determine if an aircraft has the proper profile for operation in the 

National Air Space (NAS). This makes it more difficult for drug dealers or terrorists to use an 

aircraft because they will need to use one with a valid N-number to avoid increased scrutiny. For 

more information, see 70 FR 73323, 12/9/2005.
3

• The FAA estimates additional registration inaccuracies due to the aircraft that are 

annually reported as sold but operated by their purchasers without registration or 

temporary ‘pink copy’ authority, as well as aircraft for which an incomplete 

application for registration has been made but never completed.3

Given these registration problems, it is clear that the required level of accuracy and 

currency for aircraft registration data can not be met with the present system of 

indefinite duration registration certificates that relies primarily on self-reporting by 

aircraft owners. To achieve the required level of registration and data reliability, the 

FAA believes that modifications to the aircraft registration system must be made to 

ensure that aircraft registration changes are reported within set intervals.

II. The Final Rule

The Registry seeks to meet current and future needs with the least burden and cost to 

both the aviation community and the government. Based on this final rule, the 

following will take place:

• The expiration of all certificates of aircraft registration for currently registered 

aircraft. The rule outlines the re-registration requirements for those aircraft that 

remain eligible for registration. All aircraft owners will have to re-register their 

aircraft during a 3-year period under guidelines to be published; 

• The periodic expiration of all aircraft registrations issued after the effective date of 

the rule. The rule outlines the registration renewal process and then includes a 

3-year renewal cycle; 

• The elimination of the current Triennial Program in its entirety.4

• The establishment of a time limit where an aircraft may remain in sale reported 

status (without an application being made for registration) before its N-Number

assignment is canceled. 

 

 3 These aircraft will include situations such as: 

• aircraft purchasers who fly their new aircraft using the (left behind) registration 

certificate of the former owner;

• sellers who report their aircraft sold, the 'Sale Reported' group, but the purchaser operates 

the aircraft without making an application for registration;

• purchasers who apply for registration to whom we respond seeking clarification of their 

application package, who never reply; and

• purchasers, whose aircraft is damaged past repair shortly after purchase, who drop the 

registration paper work and fail to report that the aircraft is out of service.

4 As mentioned above, while this program provides for the suspension or revocation of an 

aircraft registration certificate when there is a refusal or failure to submit the Triennial Program 

report, it does not appear that this revocation has been effective in causing all aircraft owners to 

fill out and submit the reports.
4

• The establishment of twelve months as the time limit an aircraft may be authorized 

to operate under “Pink Copy” temporary operation authority while the applicant 

or successive applicants complete the registration process. The rule outlines 

the process for reserving the aircraft’s N-Number if the aircraft is not registered 

at the end of this time. 

• The provision of the timely cancellation of N-number assignments from aircraft 

that are no longer registered, including aircraft registered under an expired 

Dealer’s Aircraft Registration Certificate.

This rule also includes several housekeeping items to establish consistency and to 

conform to statute or current registry practices.

III. Cost of Compliance

In this analysis, the FAA estimates future costs for a 20-year period, from 2010 

through 2029. As required by the Office of Management and Budget, the present 

value of this stream of costs was calculated using a discount factor of 7 percent. All 

costs in this analysis are in 2007 dollars.

A. Assumptions and Basic Data

The FAA will use the following unit costs; the bases of the information for b) through 

f) can be found in Appendix A:

a) $5 – fee per aircraft for both re-registration and renewal

b) $37.20 – hourly rate of an aircraft owner’s time

c) $9.10 – FAA processing costs for re-registration per applicant

d) $5.82 – FAA processing costs for renewal per applicant

e) $1.63 – FAA processing costs for the Triennial Program for each notice sent

f) $12.11 – FAA processing costs for the Triennial Program per reply

Transfer Payments

OMB Circular A-4 defines transfer payments as “monetary payments from one group 

to another that does not affect total resources available to society.” The $5 fee for reregistrations and renewals is a transfer payment from aircraft owners to the FAA and 

as such does not increase or decrease the cost to society of this rulemaking. Therefore 

this fee is not included as a cost of the rule. Although this fee is not considered a cost 

of the rule, it is a cost to aircraft owners. As such, the FAA has estimated the cost to 

aircraft owners and these numbers are provided below: 
5

Table 1. Transfer Payments

(over 20 years)

Actions Costs

Present 

value

Current System Normal Course of Business 

Registration Fees ($5 per Action) 917,800 $4,588,800 $2,327,100

Re-registration followed 

by 3-Year Renewal 

(Triennial Eliminated)

Normal Course of Business 

Registration Fees ($5 per Action) 917,800 $4,588,800 $2,327,100

Re-registration & Renewal Fees 

($5 per Action) 1,308,900 $6,544,400 $3,425,600

Total $11,133,200 $5,752,700

Re-registration followed 

by 5-Year Renewal 

(Triennial Eliminated)

Normal Course of Business 

Registration Fees ($5 per Action) 917,800 $4,588,800 $2,327,100 

Re-registration & Renewal Fees 

($5 per Action) 699,600 $3,498,300 $1,962,300 

Total $8,087,100 $4,289,400

Re-registration followed 

by 7-Year Renewal 

(Triennial Eliminated)

Normal Course of Business 

Registration Fees ($5 per Action) 917,800 $4,588,800 $2,327,100 

Re-registration & Renewal Fees 

($5 per Action) 461,500 $2,307,600 $1,405,700 

Total $6,896,400 $3,732,800

Normal Aircraft Course of Business Registration 

These costs are common to all 4 scenarios and are not a result of the rule. They are 

certificates that would be issued with or without the re-registration and renewal 

requirements, and include:

- Newly built aircraft;

- Aircraft imported from another country;

- An already registered aircraft, which is sold and a new certificate is issued to 

the new owner/applicant; and

- Non-registered aircraft that have been restored and applied for registration

In year 1, the FAA estimates that there will be almost 35,600 aircraft registrations, 

which is the sum of the 2007’s normal aircraft registrations, roughly 32,200, plus the 

annual average growth of aircraft. The FAA estimates that this value will increase 

annually by about 3,400, reflecting the long term average growth for used aircraft 

registration changes.5

 Over 20 years, about 917,800 U.S. registered aircraft will 

register through NCB. This number is multiplied by the $5 registration fee to 

determine the costs to aircraft owners over 20 years, $4.6 million ($2.3 million present 

value).

 5 This is calculated by multiplying the annual average growth of aircraft (3,400) by 15.76%.
6

Re-registration & Renewal Fees 

The total number of re-registration and renewal actions, as a result of this rule, are

expected to occur during the 3 years of re-registration and the 17 years of renewal for 

the 3-year renewal cycle and the 5 and 7-year alternatives. These actions are 

multiplied by the re-registration/renewal fee of $5 to get the additional registration 

fees paid by aircraft owners over 20 years. For the rule and the alternatives, the FAA 

expects approximately 1.31 million, 699,600, and 461,500 new re-registrations and 

renewals for the 3-year, 5-year, and 7-year renewal cycles, respectively. These 

actions result in fees of $6.5 million ($3.4 million present value) for the 3-year 

renewal cycle, $3.5 million ($2.0 million present value) for the 5-years cycle, and $2.3 

million ($1.4 million present value) for the 7-year cycle.

The $5 fee is the agency’s current charging authority. A provision in the FAA

Reauthorization bill, if enacted, may authorize the FAA to set the re-registration and 

renewal fee at an amount that recovers both the direct and indirect unit costs of the 

FAA Registry’s Aircraft Registration Branch. The re-registration and renewal fee 

based on full cost recovery is estimated at $45. The FAA currently charges $5 for 

aircraft registration certificates, a fee which is codified in CFR Part 47, preventing the 

Agency from recouping most of the costs involved with aircraft registration. 

As discussed earlier these $5 fees are transfers from aircraft owners to the FAA. 

While the FAA estimated the amount of these fees, as transfers these fees are not 

societal costs and are excluded from the costs of the rule.

Costs of the Rule

The FAA estimates that in addition to the fees the owners will also have the following 

additional costs per aircraft:

- Half an hour to fill out the form – this will be performed by the equivalent of a 

first line supervisor, being paid at a loaded wage of $28.26 per hour.6

- A quarter of an hour for legal review by the owner. They will be paid at $70.21 

per hour.7

 6 Source: http://www.bls.gov/oes/current/oes_nat.htm#b43-0000. The FAA took the mean 

hourly salary of a first line supervisor under Office and Administrative Support Occupations and 

multiplied by 1.2345 to account for fringe benefits. All hourly wage rates were increased by 

23.45% to account for all fringe benefits in the private sector. This fringe benefits factor was 

derived from Table 4-5, page 4-22, Economic Analysis of Investment and Regulatory Decision--

A Guide, FAA APO-98-4, January 1998. 
7

- Half an hour for when the owner gets the certificate and sends it to the aircraft 

operator. These will also be paid at $28.26 per hour. This breaks down as:

o 10 minutes to check the schedule;

o 10 minutes to send; and

o 10 minutes of communication between the owner and the lessee for 

every certificate.

- Half an hour for the operator to receive and install new registration on the 

aircraft. This will be done by a mechanic at an hourly rate of $36.51.8

In addition, there will be initial costs, for each owner, of: 

- 24 hours to document the re-registration and renewal procedures. This will be 

done by a supervisor who will be paid $48.65 per hour.9

- 8 hours of training for a primary and a backup employee, to support the 

supervisor. These employees will be trained by the supervisor. The primary 

and backup employees will be paid $28.26 per hour and the supervisor will be 

paid $48.65 per hour.

The FAA based projections on a 1.4% annual growth rate for aircraft, which is based 

on the FAA annual forecast.10

As discussed above in part II, this final rule mandates:

• that all eligible aircraft will be reregistered during a 3 year period under guidelines 

to be published;

• that thereafter all aircraft registrations will need to be renewed every 3 years; and

• the elimination of the present Triennial Program in its entirety.

Based on the NPRM, which proposed a 3-Year Renewal, the available data, and the 

public’s calls for alternative options, the FAA will cost out the final rule:

 7 Source: http://www.bls.gov/oes/current/oes_nat.htm#b23-0000. The FAA took the mean 

hourly salary of a lawyer and multiplied by 1.2345 to account for all fringe benefits.

8 Searles, Robert, “Operations Planning Guide: Salary Survey,” The McGraw-Hill Companies, 

Inc., 1999. The FAA used the salary of maintenance technician from the Summary Table, and 

then increased these salaries by 1.2345 to account for all fringe benefits and then divided by 

2,080 to obtain the employee’s hourly wage. This wage was increased by the Gross Domestic 

Product deflator.

9 Source: http://www.bls.gov/oes/current/oes_nat.htm#b11-0000. The FAA took the mean salary 

of a transportation manager and multiplied by 1.2345 to account for fringe benefits.

10 1.4% represents an average growth of all aircraft calculated from Tables 20, 21, 26, 27 in 

“FAA Aerospace Forecasts Fiscal Years 2008 – 2019, U. S. Department of Transportation 

Federal Aviation Administration, Office of Policy & Plans.”
8

I. Re-registration followed by 3-Year Renewal with the Triennial Program 

Eliminated 

And two alternatives:

II. Re-registration followed by 5-Year Renewal with the Triennial Program 

Eliminated 

III. Re-registration followed by 7-Year Renewal with the Triennial Program 

Eliminated

B. Synopses of Re-registration, Renewal, and Error Rates Calculations

To determine the costs and the expected error rates for these scenarios, the FAA first 

calculated the expected number of re-registration and renewal certificate actions. A 

synopsis of these calculations will be presented below. A full explanation for reregistration and renewal calculations can be found in Appendix B, while the write-up 

explaining the error rates can be found in Appendix C. 

1. Re-registration

The FAA estimates that the approximately 244,600 active aircraft will go through the 

re-registration process, and so will be issued new registration certificates, each with an 

expiration date, over the first three years of this rule; it is this expiration date, with the 

subsequent renewals, that is at the heart of this rulemaking and will help to improve 

the Registry’s records. Each aircraft will be scheduled to receive its new certificate 

during a 90-day period based on the month the current certificate was issued. An 

aircraft could also receive a new certificate through the normal course of business 

(NCB) process;11 these are certificates that would be issued to the owner even if this 

rule didn’t exist. In such a case, its 3-year renewal cycle will start anew. For 

instance, if an aircraft was reregistered according to the schedule and was then sold at 

a later date, the certificate issued after the sale will be an NCB transaction and not a 

transaction from the re-registration schedule. These NCB transactions are not 

included among the number of aircraft that will receive their registrations via the 

schedule and therefore are not included in calculating the costs of this rule.

 11 These certificates would be issued to the owner even if the re-registration and renewal 

requirements never existed. These include:

- Newly built aircraft;

- Aircraft imported from another country;

- An already registered aircraft, which is sold and a new certificate is issued to the new 

owner/applicant; and

- Non-registered aircraft that have been restored and applied for registration.
9

Tables B-2 through B-4 in Appendix B show how the FAA estimated the number of 

aircraft that will get their registration certificates due to NCB and the number of 

aircraft that will get their registration certificates due to the re-registration 

requirement. During the first year of the rule, the FAA estimates that about 107,300

aircraft will receive a registration certificate with an expiration date. Of these aircraft, 

about 75,100 aircraft will reregister via the re-registration schedule and about 32,200 

aircraft will register via NCB. 

During the second year of the rule, the FAA estimates that about 79,400 aircraft will 

receive a registration certificate with an expiration date. Of these aircraft, about 

63,300 aircraft will reregister via the re-registration schedule and approximately 

16,200 aircraft will register via NCB. In the third year, the FAA estimates that about 

57,900 aircraft will receive a registration certificate, with an expiration date. Of these 

57,900 aircraft, 53,300 aircraft will reregister via the schedule and 4,600 aircraft will 

register via NCB.

Over this three-year period, approximately 191,700 of the 244,600 active aircraft will 

receive registration certificates due to the re-registration requirement and 52,900 will 

receive their registration certificate during NCB. However, as will be described in the 

next section, there will be additional registration activity during this time period.

2. Renewal

The calculations for renewal pick up where the three-year re-registration period ends; 

as this analysis examines costs over 20 years, there will be 17 years of calculations of 

renewal costs. As with the re-registration calculations, in the renewal years, the FAA 

counts the number of aircraft transactions that result in a new certificate due both to a 

NCB action as well as the number of aircraft certificates issued due to the rulemakingmandated renewal program. In terms of calculations, while an aircraft that registers 

due to NCB affects and moves back a future renewal certificate, an aircraft that 

renews due to its 3-year renewal schedule does not affect the occurrence of a future 

NCB action.

The calculations during the renewal period depend on the number of aircraft that need 

to renew by their renewal date. Some of the aircraft operators will renew before their 

renewal date due to NCB, and others will not need to renew until their rulemakingmandated renewal date. Distinguishing between these two activities and identifying 

these events in the calculations is important. The bases of the calculations during all 

of the ‘renewal’ years are the number of aircraft registered in each of the three reregistration years.
10

The ending numbers of registration certificates, as explained in the ‘Re-registration’ 

section above, need to be modified for the renewals calculations in several ways 

(Table B-6 in Appendix B shows these calculations):

 For each of the three re-registration years, an additional number of aircraft will 

come on line. These additional aircraft represent the average annual growth in 

the number of active aircraft; the FAA estimates this annual growth to be 

3,400.12

 In year 2, the FAA estimates that about 12,800 aircraft reregistered during year 

1 will change registration in NCB and will now have year 2 re-registration 

dates, and in year 3, the same number of aircraft from both years 1 and 2 will 

change registration in NCB, and each of these will now have year 3 reregistration dates.

 These additional aircraft will be issued registration certificates as they 

enter into the registration system through NCB; these are not counted as part of 

the re-registration process.

 A portion of the aforementioned 3,400 aircraft that registered in years 1 and 2 

will change registration in years 2 and/or 3 due to NCB. 

At the end of year 3, the total number of aircraft that will be processed by the Registry 

will total about 254,800, made up of the approximately 244,600 active aircraft, and an 

additional 3,400 aircraft coming into the system each year. Approximately 75%, or 

about 191,700, of these 254,800 aircraft will be reregistered due to the re-registration 

requirement, and 25%, or 63,200, will receive their certificate during NCB. These 

63,200 can be divided between 52,900 from existing aircraft (discussed in the ‘Reregistration’ section above), and 10,300 from the average annual growth in the 

number of active aircraft.

Assuming a 3-year re-registration cycle, with the three sets of changes described 

above, in year 4, there will be approximately 83,900 aircraft that originally registered 

in year 1 that will need to renew in year 4, about 82,900 aircraft that originally 

registered in year 2 that will need to renew in year 5, and about 88,100 aircraft that 

originally registered in year 3 that will need to renew in year 6. 

In years 4 through 20, two scenarios will take place; NCB registrations and renewals 

due to this rulemaking (as a result of their registration expiring). The following 

explanation describes these two scenarios for year 4: 

(1) NCB-related renewals:

a) The FAA assumes that each year 15.76% of active aircraft will register due to 

NCB.13

 12 The derivation of the actual number, 3,400, is explained in Appendix B. 

 These aircraft will be issued new registrations separate from the 

13 This is based on the estimated number of normal aircraft registrations in 2007, 38,600, divided 

by the sum of aircrafts expected to register or reregister, 244,600. Dividing the former by the 
11

registrations issued in years 1, 2, and 3. At the start of year 4, the FAA expects 

there to be about 254,900 active aircraft; 15.76% of these aircraft, or about 

40,200, will be the number of aircraft registered due to NCB.

b) There will be the additional 3,400 aircraft, due to the annual average growth in 

the number of active aircraft, which will be required to register. Thus, in year 

4, total Registry activity due to NCB sums to about 43,600.

(2) Rulemaking-related renewals:

a) Subtracting out for aircraft changing registration in NCB (as shown in (1) a) 

above) leaves aircraft that are required to renew as part of the rule. As 

discussed above, there will be approximately 83,900 aircraft that originally 

registered in year 1 that will need to renew in year 4. With about 13,200 of 

these aircraft renewing due to NCB (calculation: 15.76% times 83,900), about 

70,700 aircraft will need to be renewed in year 6.

The FAA repeated these sets of calculation for years 5 through 20 to calculate the 

total number of renewals due both to NCB and to the rulemaking in order to calculate 

the total cost of this rule. The same type of calculations was also performed for the 5-

year and 7-year renewal cycles. The results can be seen in Tables B-7 through B-9 in 

Appendix B.

3. Error Rate

This rulemaking will increase the Registry’s accuracy. The FAA looked at how 

current and accurate the Registry is today and what improvements can be expected 

after implementing this rule. 

FAA records show, at the end of 2007, almost 357,000 registered aircraft; the FAA 

considers that about 241,100 of these aircraft are active aircraft.13

 

latter equals 15.76%; the FAA uses this percentage throughout this analysis to compute the share 

of aircraft registering via NCB annually.

 The FAA Registry 

estimates that about 3% of the inactive aircraft will be reregistered. This will leave 

about 244,600 as the estimated number of active aircraft; the FAA considers 

approximately 112,400 aircraft, or 31.5% of registered aircraft, inactive with out-ofdate records. This group of inactive aircraft has accumulated since December 1977, 

when a long-term program of annually validating aircraft status and registration 

addresses ended. Dividing 31.5% by 30 years implies that this group of inactive 

aircraft has accumulated at an annual rate of approximately 1%. This can also be 

13 FAA Administrator’s Fact Book. April 2006, 

http://www.faa.gov/about/office_org/headquarters_offices/aba/admin_factbook/media/200604.pdf
12

thought of as the error rate within the Registry’s records. Thus, the current error rate

is 31.5% or approximately 1% annually.

There are a number of aircraft, 15,600, that have been revoked under the current and 

past programs but have been retained in the records for safety reasons. These aircraft 

are well documented, very unlikely to re-register, and can be separated from the 

number of in-question registered aircraft. This leaves 96,900 registered aircraft with 

inactive or out-of-date records. Dividing 96,900 by 30 years gives an average of 3,230

active aircraft entering the error group annually. Since aircraft can only enter the error 

group from the active group, 1.3% (calculation: 3,230 divided by 244,600) of active 

aircraft enter the error group annually. The FAA refers to this error as the Long Term 

Error Rate.

The FAA has also calculated a Projected Long Term Error14 (PLTE). The Registry 

reports 30,100 aircraft with known bad addresses, roughly 17,000 aircraft in sales

reported status for over six months, and almost 2,200 aircraft in registration pending 

status for over one year. These four categories sum to 49,300 inactive aircraft with 

known errors expected to expire and be canceled under the provisions of this rule. 

Isolating these 49,300 aircraft from the aforementioned 96,900 registered inactive 

aircraft or out-of-date records leaves about 47,600 unidentified aircraft that are out-ofdate for unknown reasons. These unidentified inactive aircraft have accumulated at 

an annual rate of 0.65% over this 30 year period. The FAA expects that these aircraft 

registrations will continue to go bad annually even after this rulemaking is 

implemented. This error is known as the Projected Long Term Error (PLTE). The 

PLTE rate will be 2% for a 3-year renewal cycle, which is the final rule, and 3.3%, 

and 4.6% in the 5 and 7-year renewal cycles, respectively.

There is another group of out-of-date aircraft that the Registry acknowledges through 

its experience with the Triennial Program. These are the aircraft with address or 

status changes that have not been reported by the owner, but the FAA has found are 

reported when prompted. For the following set of calculations, based on the threeyear triennial cycle, the FAA is assuming three distinct groups of aircraft – those in 

the first, second, and third years of this cycle. During each year approximately 9,000 

changes are reported, which have collected during the previous three years. 

This accumulation also happens in the first and second years of the cycle. Those in 

the second year will have completed two of the three years with no Registry-related 

activity. Thus, there will be 3,000 (first year) plus 3,000 (second year) changes 

unreported, for a total of 6,000 changes. And, there is a third group that is in the first 

 14 See “APPENDIX C” for details on the Projected Long Term Error.
13

year of this cycle and has accumulated 3,000 changes. Adding these 9,000, 6,000 and 

3,000 aircraft changes from these three groups sums to 18,000 aircraft with out-ofdate registrations. Since these changes and eventual reports occur continuously, the 

FAA concludes that at any point in time 18,000 aircraft have experienced a reportable 

change that will continue to be unreported until the registered owner is prompted to 

complete and return a triennial report form. The FAA calls this error the Standing 

Error (SE), and it equals 7.4% of active aircraft15 and 5.0% of registered aircraft.16

The 3-year renewal cycle carries an SE of 7.4% that the FAA believes is the same as 

the SE generated from the Triennial, while the 5-year renewal cycle carries an SE of

18.4%, which is an extrapolation of the 3-year renewal cycle. Similar calculations can 

be made to estimate the SE for the 7-year renewal cycle; the FAA estimates this cycle 

carries an SE of 34.3%. 

In calculating the 3-year renewal cycle and the 5 and 7-year alternatives, the FAA is 

extrapolating from its experience with the 3-year Triennial Program. Given that 

people are more likely to change addresses as time passes, the likelihood of aircraft 

owners with multiple address changes will be greater for a 5-year period than a 3-year 

period and for a 7-year period than a 5-year period. Similarly, there is a greater 

likelihood of other reportable status changes happening over longer periods of time. 

The Agency acknowledges, therefore, that these error rates for the 5 and 7-year 

renewal cycles are probably high, as these error rates will include aircraft owners who 

have moved more than one time or had other status changes during the course of these 

cycles. In particular, the FAA recognizes that the error rate for the 7-year cycle is 

probably more in error than the corresponding rate for the 5-year cycle.

Adding the current LTE (31.5%) rate to the current SE (5.0%) rate of registered 

aircraft shows that 36.5% of registered aircraft information is currently incorrect. 

Even if the information on these aircraft were all current, the FAA expects that the 

error rate for the current registration system (which is based on the three-year 

Triennial Program) will be the standing error rate of active aircraft, 7.4%, plus the 

projected long term error of 0.65% per year, for each year that passes after the 

correction of the database. Adding the anticipated PLTE rate to the SE rate, the 

combined error rate will be 9.4% for 3-years, followed by 21.7%, and 38.9% under 

the 5, and 7-year renewal cycles, respectively. However, the Registry believes that 

both recent and anticipated administrative efforts could reduce the Standing Error by 

 15 This is calculated by dividing 18,000 aircraft with out-of-date registrations by 244,600, the 

estimated number of aircraft expected to reregister.

16 This is calculated by dividing 18,000 aircraft with out-of-date registrations by 357,000, the 

number of currently registered aircraft.
14

half.17 This will reduce the projected combined error rates to 5.7%, 12.5%, and 

21.7% under the 3, 5, and 7-year renewal cycles, respectively.

C. Cost of the Current System and Scenarios

The final rule will replace the current system with a 3-year re-registration program, 

followed by a 3-year renewal cycle. In the current system, all registration activity is 

NCB registration. Given the rulemaking, the Registry will have different types of 

certificated actions, which, for this analysis, are labeled as NCB aircraft registration, 

as well as re-registration and renewal of registration certificates. 

In the discussion below, the FAA will present the costs of the rule, Scenario I, as well 

as the alternatives in Scenarios II and III. The FAA will also show the costs of the 

current system so that they can be contrasted against the final rule and the other 

alternatives.

1. Cost of the Current System

The current system is the Triennial Program. Under the current program, the cost 

over 20 years is estimated to be $8.4 million ($4.4 million, present value). The costs 

are operating costs as listed in the chart below:

Table 2. – Cost of the Current System

Actions Costs Present Value

Triennial Program operating costs 1,790,000 $8,361,100 $4,428,900

Triennial Program Operating Costs

As noted above, if three years pass without certain registration actions taking place

that will confirm the status of aircraft, a Triennial Aircraft Registration Report is 

mailed to the registered owner of the aircraft. FAA records show that approximately 

70,000 of these reports are sent out annually, of which approximately 9,000 are 

returned annually with status updates, while about 5,000 are returned as undeliverable. 

Over a 20 year period, this equates to 1.4 million reports sent to aircraft owners, 

180,000 update replies, and 100,000 bad address returns. 

The FAA multiplied these numbers by its aforementioned processing costs to send the 

forms and process bad address returns ($1.63), as well as to process the updates 

 17 The Registry believes that the awareness created by the change of an expiring certificate, 

efforts made by the Registry to maintain that new awareness, and the expiry date on the 

certificate act as a reminder to help owner/operators remember to send in updates will cut error 

rates in half.
15

($12.11). The number of update replies can also be multiplied by the time value 

expended by aircraft owners to complete and return the report form.19 These items 

summed up gives us the operating costs of the Triennial Notification Program. Over 

20 years, the FAA estimates costs of this program to be $8.4 million ($4.4 million, 

present value).18

2. Costs of the Different Scenarios

Based on the numbers of re-registration and renewal transactions as well as projected 

error rates, the following are the 20-year costs for the 3 scenarios:19

I. The Final Rule: Re-registration followed by 3-Year Renewal with the Triennial 

Program Eliminated - $29.9 million ($16.3 million, present value), which 

includes $38.3 million ($20.7 million, present value) as the cost of the new 

program minus $8.4 million ($4.4 million, present value) in cost savings for 

components of the current system being eliminated, with an expected error rate 

of 5.7%;

II. Alternative I: Re-registration followed by 5-Year Renewal with the Triennial 

Program Eliminated - $13.8 million ($8.5 million, present value), which 

includes $22.2 million ($12.9 million, present value) as the cost of the new 

program minus $8.4 million ($4.4 million, present value) in cost savings for 

components of the current system being eliminated, with an expected error rate 

of 12.5%;

III. Alternative II: Re-registration followed by 7-Year Renewal with the Triennial 

Program Eliminated - $7.5 million ($5.6 million, present value), which includes 

$15.9 million ($10 million, present value) as the cost of the new program minus 

$8.4 million ($4.4 million, present value) in cost savings for components of the 

current system being eliminated, with an expected error rate of 21.7%;

Tables 3, 4, and 5 show the cost components of Scenarios I, II, and III, respectively:

Table 3. Re-registration followed by 3 -Year Renewal - Triennial Program Eliminated

Actions Cost Present value

 19 The FAA estimates that 15% of these forms are returned and is using aforementioned $20.82 

as the cost for aircraft owners to complete and return these forms. Fifteen percent of 1.4 million 

reports equal 210,000 forms returned. Of these 210,000 forms, the FAA has found that 180,000 

result in an update that has to be processed, while the remaining 30,000 are returns indicating 

that there has been no change.

18 This is the sum of 1,400,000 forms send out ($1.63 per form), 180,000 forms processed 

($12.11 per form), and 210,000 airmen completing and returning these forms ($18.60 per form).

19 All these scenarios assume error rates with a 50% improvement in the compliance rate of 

aircraft owners who don’t comply with the current program until prompted (Source: AFS-750, 

Aircraft Certification Branch, Civil Aviation Registry). 
16

1 New Time Value Cost to Complete Registration & Renewal 

Forms 1,308,900 $24,345,000 $12,743,200

2 New Start-Up Costs $1,103,100 $1,031,000

3 New Aircraft Owner & Operator Costs 100,500 $4,612,700 $2,383,300

4 New FAA Re-registration & Renewal Form Processing Cost 1,308,900 $8,246,300 $4,536,300

5 Cost of New Program $38,307,100 $20,693,800

6 Eliminate Triennial Operating costs -1,790,000 -$8,361,100 -$4,428,900

7 Net Cost of Rule $29,946,000 $16,264,900

Alternatives:

Table 4. Re-registration followed by 5 -Year Renewal - Triennial Program Eliminated

Actions Cost Present value

1 New Time Value Cost to Complete Re-registration & 

Renewal Forms 699,600 $13,013,400 $7,299,600 

2 New Start-Up Costs $1,103,100 $1,031,000 

3 New Aircraft Owner & Operator Costs 73,000 $3,350,600 $1,777,000 

4 New FAA Re-registration & Renewal Form Processing Cost 699,600 $4,700,600 $2,834,000 

5 Cost of New Program $22,167,700 $12,941,600

6 Eliminate Triennial Operating costs -1,790,000 -$8,361,100 -$4,428,900

7 Net Cost of Rule $13,806,600 $8,512,700

Table 5. Re-registration followed by 7 -Year Renewal - Triennial Program Eliminated

Actions Cost Present value

1 New Time Value Cost to Complete Re-registration & 

Renewal Forms 461,500 $8,584,200 $5,229,100 

2 New Start-Up Costs $1,103,100 $1,031,000 

3 New Aircraft Owner & Operator Costs 62,300 $2,857,300 $1,546,500 

4 New FAA Re-registration & Renewal Form Processing Cost 461,500 $3,314,600 $2,186,600 

5 Cost of New Program $15,859,200 $9,993,200

6 Eliminate Triennial Operating costs -1,790,000 -$8,361,100 -$4,428,900

7 Net Cost of Rule $7,498,100 $5,564,300

Tables 3 through 5 have the same format and each table is comprised of 7 lines; the 

following explains the cost components contained in each of these lines:

Line 1 - Time Value Cost to Complete Re-registration and Renewal Forms 

This represents the value in dollars of the time spent by aircraft owners or their 

employees to fill out the new forms required to reregister and renew their aircraft 

registrations. The FAA estimates that it will take aircraft owners half an hour to 

complete these forms. To estimate the wage rate for aircraft owners, as described in 

Appendix A, the FAA used the value of air travel time, so half an hour will equate to 

$18.60 per owner per form.

For calculations in the tables above, for the 3, 5 and 7-year renewal cycles, the 

approximately 1.31 million, 699,600, and 461,500 new re-registrations and renewals, 
17

respectively, will sum to $24.3 million ($12.7 million, present value), $13.0 million 

($7.3 million, present value), and $8.6 million ($5.2 million, present value), 

respectively.

The costs shown for Lines 4 and 5 represent the fact that in certain cases, as noted 

above, the owner and the operator are two different entities. Many commercial and 

corporate aircraft are either owned by lessors or are subject to mortgages by lenders 

who financed the purchase of the aircraft. The owner will get the notice for renewal 

and re-registration as well as the new aircraft certificate and has the responsibility of 

getting the new certificate to the operator. The FAA does not know the number of 

aircraft that are owned versus leased among the air carriers and other large 

corporations. It would be especially difficult to figure this out for the part 135 

operators as the aircraft are bought and sold frequently and some operators operate a 

single aircraft alternately under part 135 and other parts. Out of the approximately 

241,100 active aircraft, about 11,500 are listed with 121 or 135 U.S. air carriers. To 

be conservative and so as not to underestimate costs, the FAA will assume that this is 

the number of aircraft that are owned and operated by different entities. In addition, 

as noted above, the FAA does not know the number of owners; there are 460 air 

carrier operators, and so the FAA will use this number as a proxy for the number of 

aircraft owners.

Line 2 - New Start-Up Costs

This represents the costs that aircraft owners will face in documenting and 

establishing procedures for preparing the new application. These costs include 

training employees to handle this system. The FAA assumes that setting up the 

documentation procedures will take a supervisor, being paid $48.65 an hour, 24 hours. 

The FAA further assumes that this supervisor will train two first-line supervisors, still 

at a rate of $48.65 an hour, for 8 hours each, totaling 16 hours. Finally, each first-line 

supervisor is paid $28.26 an hour for 8 hours of training. Thus, total costs per owner 

sums to about $2,400. Assuming 460 owners, total start-up costs sum to $1.1 million 

($1.0 million, present value).

Line 3 - Air Carrier Aircraft owner and operator costs 

This represents the costs that owners will have for each aircraft and is computed by 

recognizing the following tasks:

- Filling out the renewal/re-registration form;22

 22 Given an hourly wage of $28.26, the half hour will cost $14.13. In line 3, however, the FAA 

assumed the value of air travel time for the average owner, or $37.20, so that the half hour to fill 

out the form will cost $18.60. The aircraft that are being considered here are a subset of the total 

number of aircraft that are being renewed and reregistered. So, to avoid double counting, the 

analysis needs to subtract $18.60 from $14.13, so the analysis cost is -$4.47.
18

- Legal review of the renewal/re-registration form;20

- The owner gets the new certificate and sends it to the operator;21

- The operator installs the new certificate.

and

22

The cost per aircraft is about $46.00. 23 For the 3, 5 and 7-year cycles, the additional 

certificate actions, due to NCB, renewal, and re-registration, sum to approximately 

100,500, 73,000, and 62,300, respectively, and will cost $4.6 million ($2.4 million, 

present value), $3.4 million ($1.8 million), and $2.9 million ($1.5 million, present 

value), respectively.

Line 4 - FAA Re-registration & Renewal Form Processing Costs

This represents the expected costs for the FAA to process the additional re-registration 

and renewal forms. The Registry will provide and process re-registration and renewal 

forms as required under the requirement during the 20-year evaluation period.

In the initial regulatory evaluation, the FAA assumed that half of the renewals would 

be filed electronically through the web site and would reduce the estimated costs of 

processing renewals accordingly. Several commenters contended that online reregistration and renewal could cut processing time and costs. The final rule permits 

online applications for re-registration in addition to online applications for renewal 

when no registration changes are made. These comments plus the Registry's 

experience with registrations led the FAA to change the assumption to 80% online 

applications for renewal and to assume 60% online applications for re-registration. 

The convenience of an online process for re-registration and renewal will entice 

owners with no registration changes to take advantage of this process.

Line 5 - Cost of the New Program

The costs for the new registration program, for the rule (3-years renewal) and the 

alternatives (5 and 7-year renewal cycle, respectively), sum to $49.4 million ($26.4 

million, present value), $30.3 million ($17.2 million, present value), and $22.8 million 

($13.7 million, present value). 

Line 6 - Eliminate Triennial Operating Costs. 

This was described above in the narrative explaining Table 1 and describes the 

program where, if three years pass without certain registration actions taking place 

that will confirm the status of aircraft, a Triennial Aircraft Registration Report is 

mailed to the registered owner of the aircraft. Over a 20 year period, the FAA, absent 

 20 Given an hourly wage of $70.21, the quarter hour of legal review costs $17.55.

21 Given an hourly wage of $28.26, the half hour will cost $14.13. Given $0.42 for mailing, the 

total cost of this line item is $14.55. 

22 Given an hourly wage of $36.51, the half hour will cost $18.26.

23 The sum of -$4.47 + $17.55 + $14.55 + $18.26 = $45.89.
19

this rule, estimates that 1.8 million reports would be sent to aircraft owners, including 

180,000 update replies and 100,000 bad address returns. Over 20 years, the FAA 

estimates cost savings from eliminating this program to be $8.4 million ($4.4 million, 

present value).

Line 7 - Net Cost

As noted above, the net total cost for the 3, 5 and 7-year renewal cycles (with the 3-

year renewal cycle being the rule), derived by subtracting line 6 from line 5, sum to 

$29.9 million ($16.3 million, present value), $13.8 million ($8.5 million, present 

value), and $7.5 million ($5.6 million, present value), respectively.

The tables above describe the costs associated with the current program, the 3-year 

renewal, and two alternatives, the 5 and 7-year renewal cycles without the Triennial 

Program. Costs for these Scenarios range from $29.9 million for a 3-year renewal, to 

$7.5 million for a 7-year renewal cycle. The Final Rule is Scenario I, which is the 3-

Year Re-registration, followed by the 3-Year Renewal with the Triennial Program 

eliminated ($29.9 million).

IV. Analysis of Benefits

Table. 6 Estimated Inaccurately Registered Aircraft

Options Inaccurately 

Registered Aircraft

Current Program 132,100

Re-registration and 7-Year Renewal (Triennial Eliminated) 68,900

Re-registration and 5-Year Renewal (Triennial Eliminated) 37,600

Re-registration and 3-Year Renewal (Triennial Eliminated) 18,800
20

The primary benefit of this rulemaking will be benefits gathered from increased 

accuracy of the records within the Aircraft Registry. As discussed in the Cost section, 

roughly one third of registered aircraft information is questionable. Inaccurate records 

have many negative consequences. For example, FAA uses aircraft records to 

identify owners of specific aircraft so safety-related information, such as emergency 

airworthiness directives (ADs), can be delivered to those owners but because of data 

inaccuracies, many safety-related mailings are undeliverable. Between 2005 and 2009 

the FAA mailed 21,000 emergency ADs (roughly 4,000 emergency ADs a year). The 

FAA estimates that 5% to 10% (an estimated 200 to 400 letters) of those 4,000 ADs 

are returned undeliverable each year. Although there are alternative methods for 

aircraft owners to gather information on emergency ADs, mail is the primary method 

used by the FAA to initially alert owners. Emergency ADs are also time sensitive, and 

the alternative methods require additional time to accomplish notification to owners 

who were not properly contacted by mail. Aircraft manufacturers also use registration 

records to mail safety-related information. Law enforcement and security agencies 

rely on FAA’s registration records to accomplish their missions. 

The FAA has concluded that the level of accuracy in the system of records must be 

significantly improved in order to better serve the needs of the users of the system as 

well as streamline its own operations. Specifically, benefits will accrue from 

improving the database as well as improving the data collection process.

The FAA has identified three areas that will benefit based on an overall improvement 

to the Registry database:

1. Cost savings – Given a more accurate database, the FAA will realize cost 

savings when mailing ADs, conducting surveys of aircraft owners, and accomplishing 

other necessary contacts with aircraft owners, as there will be fewer returned mailings, 

fewer follow-up mailings, and less employee time needed to process both of these. 

Aircraft manufacturers will realize similar cost savings when mailing safety notices. 

Vendors that send out useful information regarding aircraft products will benefit from 

more accurate aircraft registration information.

2. Better service for aircraft owners - This improved service will be 

accomplished through improved databases that will expedite ownership transfers and 

the reissuance, re-registration, and renewals of certificates. In addition, there will be 

increased ease in notifying aircraft owners of enforcement, compliance, and other 

notice actions. The aforementioned mailings will potentially reach more aircraft 

owners and eliminate mailings sent to inactive aircraft that will no longer be carried 

on the Registry. With more owners receiving this information, as well as information 
21

from aircraft manufacturers, fewer will be at risk due to delayed or undelivered safety 

notices.

3. Help with law enforcement - As mentioned above, the FAA, in concert with 

TSA, is evaluating flight plan filings to determine if an aircraft has the proper profile 

for operation in the National Air Space (NAS). This makes it more difficult for a drug 

dealer or a terrorist to use an aircraft since they will need to use an aircraft with a 

valid N-number to avoid increased scrutiny. Removing ineligible aircraft from the 

Civil Aircraft Registry will eliminate a large pool of questionable N-Numbers; with 

the regulatory changes in the aircraft registration process in place, criminals and 

terrorists will find it more difficult to use registered aircraft for illicit operations. 

Aircraft owners will be more likely to have current registration information on file 

and operators will be less likely to experience delays when authorities verify an 

aircraft for operation in the national airspace.

V. Comparison of Costs and Benefits

The FAA, as well as other users in both the private and public sectors, depends on the 

Registry’s information for a myriad of purposes, including mailing safety-related 

information to aircraft owners and supporting law enforcement. The FAA has 

concluded that the level of accuracy in the system of records must be significantly 

improved in order to better serve the needs of the users of the system as well as 

streamline its own operations.

The final rule will replace the current system, and will include a system in which all 

currently registered aircraft owners must reregister their aircraft over a 3-year time 

frame, and then renew these registrations on a regular 3-year basis. The FAA also 

examined other scenarios including 5 and 7-year renewal cycles without the Triennial 

Program.

The table below gives an overview of the error rates and costs associated with the 

current program and a few alternatives; the 3, 5 and 7-year renewal cycles without the 

Triennial Program. The cost of the current program is moderate at $8.4 million, but 

has the highest error rate (36.5%). As the renewal intervals shorten, the costs increase 

while the error rates decrease. Re-registration with a 7-year renewal costs 

approximately $7.5 million with an error rate of about 21.7% compared to reregistration with a 3-year renewal that costs approximately $29.9 million, and has an 

error rate of about 5.7%. These processing costs do not include the transfer fees of 

$11 million for 3 years, $8 million for 5 years, and $7 million for 7 years.
22

Table. 7 Estimated Costs and Error Rates for Re-registration and Renewal

(over 20 years)

Options Cost

Present 

value Cost Error Rate

Inaccurately 

Registered Aircraft 

Current Program $8,361,100 $4,428,900 36.5% 132,100

Re-registration and 7-Year 

Renewal (Triennial Eliminated) $7,498,100 $5,564,300 21.7% 68,900

Re-registration and 5-Year 

Renewal (Triennial Eliminated) $13,806,600 $8,512,700 12.5% 37,600

Re-registration and 3-Year 

Renewal (Triennial Eliminated) $29,946,000 $16,264,900 5.7% 18,800

The major goal of this rule is to improve data quality to a level that meets the needs of

the FAA and other users of the system. The rule replaces the current system with a 3-

year re-registration program and a 3-year renewal cycle. 

The Agency concludes, given the rule’s relatively low cost over 20 years of $29.9

million ($16.3 million, present value), and the ability to achieve the goal of reducing 

the current 36.5% error rate to 5.7%, that the final rule gives the best balance between 

costs and benefits of the different scenarios examined.
23

VI. Comments

Of the 92 commenters, 25 submitted comments on the regulatory evaluation for the 

NPRM. These included 4 individuals, 1 flight school, 2 from a University, 8 aviationrelated companies, and 10 associations (ELFA, Aviation Working Group, NAFA, 

GAMA, NBAA, AOPA, ATA, HAI, IHST, and NARA).

COMMENT:

While several commenters agree that the $5 current registration fee is too low and 

could see the need for a higher fee, they believe that the Congressionally-proposed 

$45 and $130 fees are too high, feeling that an equitable fee would be lower than 

these proposed fees. Some believe that the $130 would apply every three years, 

claiming that is too high a burden for them. One commenter saw it as a penalty for 

those who are late in meeting the deadline for re-registration 

FAA RESPONSE:

It is important to note that the $5 fee is what can be charged under the FAA’s current 

structure, even though it is less than the actual cost of processing the replies. A 

proposed provision in the FAA Reauthorization bill would allow aircraft registration 

fees to increase based on direct and allocable indirect unit costs of the FAA Registry’s 

Aircraft Registration Branch plus an allowance for FAA overhead. Example fees of 

$45 replacement certificate and $130 for registering a new aircraft were used in the 

bill. . However, any increase in fees would simply recoup to the FAA the cost of 

service. The $130 registration fee would not apply every three years for reregistration and renewal.

COMMENT:

Two comments were from a University. One thought that the passed-on costs of $130 

per aircraft every 3 years might push the cost of learning to fly out of reach for some 

students. The other sees this registration fee as a tax and that it will push interested 

individuals who want to learn to fly and obtain their license away.

FAA RESPONSE:

The FAA notes that the amount in question currently is $5. There is legislation 

pending before Congress that, if enacted as introduced, would provide the authority to 

increase registration-related fees. The projected fee of $130 is only for initially 

registering an aircraft, which is a one-time fee, and thus would not occur every 3 

years. The projected fee for re-registration and renewal is $45, which would occur 

every 3 years under this final rule. However, the FAA does not believe that these 

higher fees would cause students not to be able to learn to fly. Because this fee would 
24

be paid by aircraft owners, the costs could be prorated among flight instruction 

sessions. Costs for each student pilot would then be negligible. In addition, the 

registration and renewal fees are not taxes, but are fees to recover the processing costs 

to the FAA.

COMMENT:

One commenter proposed a sliding scale for people who have more than one aircraft. 

Another mentioned that these fees would affect general aviation proportionately 

harder than the airlines; this same commenter notes that the registration fee for cars is 

reduced as the car ages. Another asks if the registration fee could be tied to the 

aircraft certificated gross weight and/or type certification, or operation.

FAA RESPONSE:

The fees discussed are the fees that the FAA would need per airplane registration, reregistration, or renewal. These fees are not based on the number of aircraft, or the 

aircraft type, but are the cost associated with processing and recording registration

applications and supporting documents that are the same for all aircraft. Therefore, 

the use of sliding scales, weight age or value of an aircraft to calculate these fees

would not be appropriate.

COMMENT:

Several commenters believed that electronic or on-line registration or renewal by 

owners as well as electronic processing by the FAA could cut time and costs. One 

commenter believed that the time to fill out the forms electronically could be reduced 

from 30 minutes to 5 minutes.

FAA RESPONSE:

The FAA agrees that electronic on-line Re-Registration does save the Registry 

processing time and therefore costs when there are no changes. Accordingly, the rule 

provides for both online re-registration and renewal when no changes are required. 

Generally, on-line change reporting would be convenient for owners, but the FAA 

currently is not set up to process such information. Also, address or other changes 

require review and action by an examiner, so costs savings would be very small if 

any. 

The FAA used 30 minutes as the estimate that owners would need to complete reregistration or renewal forms in its calculations in the NPRM analysis. While it 

clearly would take less than that for a form when there are no changes, the FAA used 

30 minutes to be conservative and to potentially overstate costs rather than understate 

them.
25

COMMENT:

Several commenters believe that the FAA underestimated the costs to the aircraft 

owner:

- The Aviation Working Group stated that “The NPRM underestimates the costs 

associated with the proposed rule because aircraft registration involves multiple 

parties and the costs will greatly exceed NPRM estimates: The NPRM seems 

to assume that each registered owner of an aircraft is the operator of that 

aircraft and that no other entities are involved. In reality, a high percentage of 

commercial and corporate aircraft, and presumably a large number of general 

aviation aircraft, are either owned by lessors or are subject to mortgages or 

security interests in favor of lenders who financed the purchase of the aircraft.” 

- National Aircraft Resale Association “believes the FAA greatly understates the 

impact the proposed rule will have on aircraft owners who own multiple 

aircraft as part of complex financing transactions with third parties.” “If the 

NPRM were adopted as written, such aircraft owners will need to implement 

internal systems to track and monitor the status of aircraft registrations for reregistration and renewal purposes or, alternatively, hire a third party to track 

and monitor the registration activity. In addition, such aircraft owners will

need to hire additional employees to oversee this process regardless of whether 

it is conducted internally or externally. The costs of developing, implementing 

and maintaining such systems and providing appropriate personnel will be 

significant and will increase annually.”

- Federal Express (FedEx) submitted information including start-up costs, 

including the time to develop a system to track the expiration dates of their 

aircraft, and follow-on costs for each re-registration, including the time to fill 

out the form, updating the tracking system, preparing the shipping documents, 

and confirm the registration has been installed. The former exceeded 100 hours 

while the latter summed to 120 minutes. In addition to these, FedEx estimates 

an additional 30 minutes for communication with the lessor. 

- National Aircraft Finance Association (NAFA) says that “it is fair to say that 

most loan and lease companies do not have IT systems or other processes in 

place with the functionality to monitor the expiration/renewal of aircraft 

registration for their owned fleets or for the aircraft of their borrowers. Such 

systems will be necessary so that financiers can take remedial action in the 

event of non-compliance. System modifications establishing work flow 

consume both time and capital to implement.”

- The National Business Aviation Association says “If an aviation professional is 

involved with the filing of the re-registration application or renewal forms 

under the proposed regulations, the aircraft owner will likely incur several 

hundred dollars in additional fees (for advice, monitoring, preparation and the 
26

filing of registration documents) in addition to the fees discussed in the 

NPRM.”

- The Equipment Leasing and Finance Association (ELFA) says that “the 

substantial costs for owners and financiers are unaccounted for in the NPRM. 

Although the NPRM briefly addresses the impact on owners, it does not 

mention the significant increase in the cost and administrative burdens that 

financing parties will incur in connection with the proposed changes.”

- The National Business of Aviation Associates (NBAA) “believes the FAA’s 

analysis drastically underestimates the cost per aircraft owner for re-registration

and renewal. The cost analysis in the NPRM does not account for any time or 

fees associated with an aviation consultant or professional reviewing the new 

regulations on behalf of an aircraft owner, the costs associated with taking the 

steps necessary to comply with the regulations, and the costs to implement a 

monitoring system to maintain compliance with the regulations. A significant 

number of aircraft owners use title companies, consultants or law firms to assist 

with the preparation, review and filing of registration documents.” 

“Additionally, owners with large fleets and financial institutions with large 

portfolios will be required to create fairly sophisticated monitoring and 

reporting systems to ensure that each aircraft in its fleet or portfolio remains 

valid at all times.” 

- The Air Transport Association (ATA) writes, “This estimate does not include 

time spent by aircraft owners communicating with other parties such as 

airplane operators, outside legal counsel, and the FAA. In order to develop a 

true cost analysis, the FAA will have to determine how many aircraft have 

separate owners and operators. Once that figure is determined FAA will have to 

determine how much time each owner and operator will spend communicating 

with each other and the FAA. Many Part 121 operators hire outside legal 

counsel to assist with aircraft purchase, leasing, and registration transactions. 

Any cost estimate will have to include outside legal counsel costs. In contrast 

to the FAA’s estimate, we estimate each renewal to be one half-hour for filling 

out the form, one hour for communicating with the aircraft operator and one 

half hour communicating with the FAA to complete the process, based on 

information provided by our members. Therefore, any cost analysis, at a 

minimum, should assign a two hour burden for aircraft owners and one hour 

burden for aircraft operators. The one hour burden for Part 121 operators, and 

probably many other commercial aircraft operators, should include the cost of

outside counsel, a minimum of $350 per hour. These estimates will be for each 

renewal, estimating between six and seven renewals per twenty-year period. 

The FAA also failed to include any cost for actually placing the registration on 

the airplane. As FAA is aware any change like a new registration must be 
27

documented and accomplished by an appropriate employee, such as a 

mechanic. FAA should account for this time and cost.”

FAA REPONSE:

The FAA agrees that for certain aircraft owners, the cost has been underestimated. As 

described in the Costs section above, for the aircraft owner and operators, the FAA 

agrees to the following costs and has included them in the analysis:

- A half an hour to fill out the form – this will be performed by the equivalent of 

a first line supervisor.

- A half an hour for when the owner gets the certificate and sends it to the 

aircraft operator.

- A quarter of an hour for legal review for the owner. This rule does establish an 

event where the owner is required to certify 'no change' to the citizenship 

status, and it is the legal office that does this type of checking. The FAA does 

not accept the $350 per hour that the ATA submitted, as the Agency believes 

that is what a consulting attorney gets paid; instead the FAA will use the cost of 

a staff attorney at a trust company, at $70 per hour. The operators will not need 

to do a similar legal check for each new certificate since they only have to 

receive the new certificate from the owner and place it in the aircraft. If owners 

are in compliance with existing regulations to keep addresses up to date and 

keep tabs on their citizenship status and address any change within the 

prescribed time, there is no reason for lawyers to do research on each 

registration certificate. If they are not in compliance with these other rules then 

their need for any legal review is because of these other existing regulations, 

not the re-registration and renewal. 

- A half an hour for the operator to receive and install new registration on the 

aircraft. This will be done by a mechanic.

- One time start up costs, for each operator, of: 

o 24 hours to document the re-registration and renewal procedures. 

o 8 hours of training for a primary and a backup by the supervisor.

The FAA does not agree with the following costs:

- No additional time will be needed for an aviation consultant or professional 

reviewing the new regulations on behalf of an aircraft owner or the costs 

associated with taking the steps necessary to comply with the regulations. The 

FAA issues regulations on a regular basis and air carriers employ professionals 

to interpret and make sure that these regulations are complied with.

- No additional time or costs for implementing or modifying a monitoring system 

to maintain compliance with the regulations. Re-registration is a one time 

event for each aircraft under this rule, and renewal of that registration will be 
28

required only once every three years on a known schedule. The rule does not 

require airline operators to program the renewal or re-registration date into a 

computerized tracking system; they will do so only at their own convenience. 

In addition, many commercial aircraft owners, operators and financiers already 

have tracking systems for monthly payments, scheduled maintenance, 

airworthiness directives, or flight schedules. If they so choose, adding reregistration and renewal to them should be a relatively nominal task. The FAA 

has moved the initial reminder from 120 days to 180 days prior to expiration. 

This allows the designated three month filing window to move forward 

establishing 60 days between the last assigned filing date and certificate 

expiration for the processing and delivery of certificates. A courtesy reminder 

notice will also be sent 60 days before expiry to owners whose aircraft have not 

yet been reregistered.

- No additional communication is needed between the owner and the FAA. It is 

not necessary for airlines to contact the Registry regarding registration for reregistration and renewal of aircraft. They are welcome to check if they think 

there is an issue, or to change a delivery instruction, but it is not needed for 

each application, or certificate issuance, so it is not a cost of the rule.

COMMENT:

The ATA stated that “it is not clear how this proposal would create a net time savings 

for any party, as the cost/benefit analysis claims.”

FAA RESPONSE:

The cost/benefit analysis does not claim that there would be a net time savings for any 

party.

COMMENT:

The ATA wrote that “the NPRM states this proposal would only have a domestic

impact and therefore would have no affect on any trade-sensitive activity. That 

statement does not appear to be correct given that the Registry website indicates over 

45 pages of foreign registrants, not including registrants from Puerto Rico and the US 

Virgin Islands. With many foreign registrants, the FAA must review this proposal and 

provide an analysis of it in light of its impact on foreign airlines and for conformity 

with other registration requirements and commitments, such as the Cape Town 

Convention on International Interests in Mobile Equipment.”

FAA RESPONSE:

The FAA agrees that all U.S. registered aircraft have to comply with FAA operational 

as well as foreign operational standards when operated in a foreign jurisdiction. With 
29

the exception of aircraft registered by and to resident aliens and corporations whose 

aircraft are “based and primarily used” in the United States, foreign owned aircraft are 

not eligible on the United States civil aircraft registry. Those aircraft ATA refers to 

may be aircraft owned by U.S. citizens with foreign mailing addresses. Otherwise, 

those aircraft may have invalid registration certificates under 14 CFR 47.43. This rule 

has no effect on the Cape Town Convention.
30

APPENDIX A – UNIT COST DATA
31

The derivation of the costs shown in the Assumptions and Basic Data section

• $37.20 – hourly rate of an aircraft owner’s time:

To estimate the wage rate for aircraft owners, the FAA used the value of air 

travel time, as discussed in Economic Values for Evaluation of Federal Aviation 

Administration Investments and Regulatory Programs (Values), FAA.24

Table 1-1 in Values discusses and calculates the time value for three types of 

activities for both air carriers and general aviation passengers – these three types of 

activities are personal, business, and all purposes. Since the majority of aircraft 

owners are general aviation rather than air carrier pilots and since the ‘all purposes’ 

category constitutes the broadest measure of passenger time in calculating costs for 

this analysis, the FAA will use this hourly rate to calculate the time needed to fill out 

this form. The hourly rate is $37.20 per hour.

 This 

measures the value that an individual places on their time spent traveling. Time is a 

valuable economic resource, which may be devoted to work or leisure activities, and 

is measured as an opportunity cost equal to the amount of foregone activity. 

Economic theory postulates that individuals will adjust the amount of time they 

devote to work and leisure such that the value of an additional small increment of 

either will be valued at the wage rate.

• $9.10 – FAA processing costs for re-registration per applicant:

Aircraft owners wanting to re-register their aircraft may use either an online or paper 

version of the Aircraft Re-Registration Application, AC Form 8050-1A. The FAA 

anticipates that 40% of the applicants are likely to submit the paper form. The 

remaining 60% of applicants may submit online and as such will incur very low direct 

labor or material costs. These online applicants lower the average direct processing 

cost per applicant. The average cost components per applicant for re-registration are 

listed below:

Unit Cost

Supplies and Materials $0.28

Computer Time $2.01

Remittance Processing $0.46

Postage $1.37

Labor25 $4.98

TOTAL $9.10

Source: AFS-750, Aircraft Re-registration Branch, Civil Aviation Registry.

 24 This Final Report is dated October 3, 2007.

25 Labor costs are calculated using a combination of an FAA employee, FG-10, step 5 and 

contract employees.
32

• $5.82 – FAA processing costs for renewal per applicant:

Registration Renewal will be accomplished by returning a renewal form with fee by 

mail or on-line through the Registry’s web page. The form should be no more 

complicated than an application for registration or a triennial form. The Registry 

predicts that the 60% of applicants that re-registered online will also renew online. 

Plus an additional 20% of the applicants that submitted via paper under re-registration 

will elect to renew online as the online process improves. Moreover, the direct cost to 

online filing is relatively low which is reflected in the low average cost for renewal 

per applicant. The average cost components for renewal per applicant listed below:

Unit Cost

Supplies and Materials $0.22

Computer Time $0.80

Remittance Processing $0.22

Postage $0.94

Labor26 $3.64

TOTAL $5.82

Source: AFS-750, Aircraft Re-registration Branch, Civil Aviation Registry.

• $1.63 – FAA processing costs for the Triennial Program to send notices per 

applicant:

Unit Cost

Supplies and Materials $0.09

Computer Time $0.67

Remittance Processing $0.00

Postage $0.53

Labor $0.33

TOTAL $1.62

Source: AFS-750, Aircraft Re-registration Branch, Civil Aviation Registry.

 26 The labor rates have been adjusted to account for FAA’s expectations that 80% of all renewals 

will not report changed registration information and be filed electronically through the Registry 

web site. These electronically filed no-change renewals incur very low direct processing costs 

which lowers the average cost processing all renewal applications. Labor costs are calculated 

using a combination of an FAA employee, FG-10, step 5 and contract employees.
33

• $12.11 – FAA processing costs for the Triennial Program to process replies per 

applicant:

Unit Cost

Supplies and Materials $0.27

Computer Time $0.62

Remittance Processing $0.00

Postage $0.42

Labor27 $10.80

TOTAL $12.11

Source: AFS-750, Aircraft Re-registration Branch, Civil Aviation Registry.

 27 Labor costs are calculated using a combination of an FAA employee, FG-10, step 5 and 

contract employees. The triennial report forms are supposed to be returned when a change in 

ownership, address, etc., occurs and these forms must be fully processed. This process includes 

an FAA Legal Instrument Examiner reviewing the report and the aircraft record. The examiner 

then updates the aircraft record and the registration database, or sends a letter outlining 

additional requirements that the owner must make. The numbers shown here reflect that process. 

Given this process, and the cost to fully process paper forms, the average cost of the Triennial is 

higher than re-registration and renewal. Moreover, with re-registration and renewal the cost to 

process the paper form is averaged in with the much lower direct costs of a larger number of 

forms filed on-line which report no changes and incur very low direct processing costs.
34

APPENDIX B – EXPLANATION OF RE-REGISTRATION AND RENEWAL 

CALCULATIONS
35

Re-registration

As of December 31, 2007, the total number of registered aircraft, according to the 

Aircraft Registry28 was 357,020, which includes both active and inactive registered 

aircraft. The Administrator’s Fact Book29 and the GAAT Survey shows that there are 

241,100 30 active aircraft, leaving 112,442 31 inactive aircraft. Therefore, the FAA 

estimates that 244,578 aircraft (357,020 – 112,442) will be expected to register either 

through the re-registration established via this rule or through their normal course of 

business (NCB),32

 28 Department of Transportation, Federal Aviation Administration, Flight Standards Service, 

Civil Aviation Registry, Aircraft Registration Branch, AFS-750

which typically occurs through transfers of ownership. For the 

purpose of the regulatory evaluation, this calculation was developed on a standard 

January through December year. See section 47.40 in the final rule for the actual 

schedule. Table B-1 displays an example re-registration schedule for these 244,578 

aircraft. 

29 “Administrator’s Fact Book,” Federal Aviation Administration, November, 2008, pp. 18-19.

30 241,100 = 222,100 General Aviation + 9,500 Air Taxi + 7,500 Air Carriers + 2,000 Commuter 

Aircraft 

31 112,442 = .97 x (357,020 – 241,100). The FAA assumes that 3% of the total inactive aircraft 

will reregister as a result of this proposal (Source: AFS-750, Aircraft Re-registration Branch, 

Civil Aviation Registry). All numbers in this analysis have been rounded to the nearest whole 

number.

32 As mentioned in the main text of this analysis, these are certificates issued that will have been 

borne by the owner even if the re-registration and renewal requirements never existed. These 

will include:

- Newly built aircraft;

- Aircraft imported from another country;

- If an already registered aircraft is sold and a new certificate is issued to the new 

owner/applicant; and

- Non-registered aircraft that have been restored and applied for registration.
36

The FAA estimates that 81,526 (244,578/3) aircraft will reregister during the first year 

of the three-year schedule detailed in Figure 1. The Registry estimates that 38,547 

aircraft33 will register annually through the NCB, typically due to a transfer of 

ownership; this estimate is based on 2007 fiscal year data. This number of NCB 

registrations is 15.76% of the number of active aircraft (calculation: 38,547 divided by 

244,578); the FAA uses this percentage throughout this analysis to compute the share 

of aircraft annually applying for a new registration via NCB.

For calculation purposes, the FAA allocated the 38,547 aircraft that will be registered 

via NCB to each of the 144 eligible working months,34

 33 This was the number of aircraft reported by the Registry to have registered after transfers 

between US owners. 

or 268 (38,547/144) 

34 All of the matrices are 12 by 12 matrices and have 144 eligible work months for when an 

aircraft can be registered. For example, if an aircraft was previously registered in January, 

theoretically, it can apply for a new registration in any other month, in any year. This gives each 

aircraft registered in January, twelve other months during which it could be registered again. 

This is also true for any aircraft registered in any other calendar month. 

If Aircraft Was Registered 

In...

If Aircraft Was Registered 

In...

Year 3

Then It Can Be ReRegistered 

During...

Then It Can Be ReRegistered 

During...(horizontal months in 

Tables B2 - B4)

If Aircraft Was Registered 

In...(vertical months in 

Tables B2 - B4)

Then It Can Be ReRegistered 

During...

Year 2

September

October

November

December

May

June

July

August

January 

February

March 

April

May - July

August - October

November - January

Year 1

May - July

August - October

November - January

February - April

February - April

May - July

August - October

November - January

February - April

Table B-1. Example Re-registration Schedule
37

registrations per eligible work month through NCB, which is shown in Table B-2 

below, in accordance with the schedule displayed above in Table B-1. The boxes 

marked with an “X” are for aircraft that have been registered in the previous months.

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

1st Year Jan 134 134 134 X X X X X X X X X

Feb 268 268 268 134 134 134 X X X X X X

 Re-Reg Mar 268 268 268 268 268 268 134 134 134 X X X

Schedule Apr 268 268 268 268 268 268 268 268 268 134 134 134

May 268 268 268 268 268 268 268 268 268 268 268 268

Jun 268 268 268 268 268 268 268 268 268 268 268 268

Jul 268 268 268 268 268 268 268 268 268 268 268 268

Aug 268 268 268 268 268 268 268 268 268 268 268 268

Sep 268 268 268 268 268 268 268 268 268 268 268 268

Oct 268 268 268 268 268 268 268 268 268 268 268 268

Nov 268 268 268 268 268 268 268 268 268 268 268 268

Dec 268 268 268 268 268 268 268 268 268 268 268 268

Table B-2. Year 1 Registrations Via NCB

The FAA assumes that in each working month of the first year of the registration 

schedule, shown in Table B-1 above, 50% of these 268 aircraft, or 134 aircraft, will 

register through the re-registration schedule and the remaining 50% will register 

through NCB. Therefore, 32,160 (calculation: (268 x 114) + (134 x 12)) aircraft will 

obtain a registration certificate, with an expiration date, through NCB, of which, 6,432 

(calculation: (12 x 134) + (18 x 268)) of these certificates will be issued during the 

twelve working months of the re-registration schedule and are subtracted from the 

number of scheduled re-registrations. 

As noted above, the FAA estimates that 81,526 aircraft will be scheduled to be 

reregistered in the year 1 and receive a certificate with an expiration date. After 

subtracting out the 6,432 aircraft that were issued certificates with expiration dates 

during NCB, there will be 75,094 (calculation: 81,526 – 6,432) aircraft reregistered 

through the schedule during year 1. In total, 107,254 (calculation: 75,094 + 32,160) 

aircraft will receive, in year 1, a certificate with an expiration date. 

This leaves 137,324 (calculation: 244,578 – 107,254) aircraft scheduled for reregistration in years 2 and 3. For simplicity, the FAA assumes that one-half, or 

68,662, of these aircraft will be scheduled for re-registration in year 2 of the schedule 

in Table B-1. 

Also, the FAA estimates that 21,642 (calculation: 137,324 x 15.76%) aircraft will 

register via NCB during the second year of the schedule. These 21,642 aircraft will 
38

be distributed throughout the 96 (calculation: 144 – 48)35 eligible work months, which 

equals 225 (calculation: 21,642 ÷ 96) aircraft per month. The distribution of these 

21,642 aircraft through NCB during year 2 is shown in Table B-3. 

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Jan U U U U U U U U U U U U

Feb U U U U U U U U U U U U

Mar U U U U U U U U U U U U

Apr U U U U U U U U U U U U

2nd Year May 113 113 113 X X X X X X X X X

Jun 225 225 225 113 113 113 X X X X X X

 Re-Reg Jul 225 225 225 225 225 225 113 113 113 X X X

Schedule Aug 225 225 225 225 225 225 225 225 225 113 113 113

Sep 225 225 225 225 225 225 225 225 225 225 225 225

Oct 225 225 225 225 225 225 225 225 225 225 225 225

Nov 225 225 225 225 225 225 225 225 225 225 225 225

Dec 225 225 225 225 225 225 225 225 225 225 225 225

Table B-3. Year 2 Registrations Via NCB

Again, the FAA assumes that in each working month of the second year of the reregistration schedule, shown in Table B-1 above, 50% of these 225 aircraft, or 113 

aircraft, will be reregistered through the re-registration schedule and the remaining 

50% will be registered through NCB. In total, 16,206 (calculation: (225 x 66) + (113 

x 12)) aircraft will obtain a registration certificate, with an expiration date, through 

NCB in year 2. Of these 16,206 certificates, 5,406 (calculation: (12 x 113) + (18 x 

225)) will be issued during the twelve working months of the re-registration schedule 

and need to be subtracted from the number of scheduled re-registrations.

As noted above, the FAA estimated that 68,662 aircraft will be scheduled to be 

reregistered in the year 2 and receive a certificate with an expiration date. After 

subtracting out the 5,406 aircraft that will be issued certificates with expiration dates 

because of NCB, there will be 63,256 (calculation: 68,662 – 5,406) aircraft 

reregistered through the schedule during year 2. Therefore, a total of 79,462 

(calculation: 63,256 + 16,206) aircraft will be issued, in year 2, a new certificate with 

an expiration date.

Through years 1 and 2, a total of 186,716 (calculation: 107,254 + 79,462) aircraft will 

have received registration certificates with expiration dates. This leaves 57,862 

(calculation: 244,578 – 186,716) aircraft that have not yet received a certificate with 

an expiration date to be reregistered during year 3. As in years 1 and 2, the FAA 

assumes that 15.76%, or 9,119 (calculation: 57,862 x 15.76%), of these 57,862 

 35 48 represents the ineligible work months for year 2 because they were used in estimating the 

affected population in year 1 and are denoted by a “U” in table B-3 and needs to be subtracted 

from the 144 total available work months. This leaves 96 eligible work months for year 2.
39

aircraft will be registered because of NCB. The distribution of these 9,119 aircraft 

among the working months of year 3 is shown in table B-4.

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Jan U U U U U U U U U U U U

Feb U U U U U U U U U U U U

Mar U U U U U U U U U U U U

Apr U U U U U U U U U U U U

May U U U U U U U U U U U U

Jun U U U U U U U U U U U U

Jul U U U U U U U U U U U U

Aug U U U U U U U U U U U U

3rd Year Sep 95 95 95 X X X X X X X X X

Oct 190 190 190 95 95 95 X X X X X X

 Re-Reg Nov 190 190 190 190 190 190 95 95 95 X X X

Schedule Dec 190 190 190 190 190 190 190 190 190 95 95 95

Table B-4. Year 3 Registrations Via NCB

The FAA estimates that 190 (calculation: 9,119/48) 36 aircraft will be registered 

because of NCB in each working month of year 3. The FAA also assumes that in each 

working month of the third year of the re-registration schedule, shown in Table B-4, 

50% of these 190 aircraft, or 95 aircraft, will be reregistered through the reregistration schedule and the remaining 50% will be registered through NCB. In 

summary, the FAA estimates that 4,560 (calculation: (190 x 18) + (12 x 95)) aircraft 

will receive a certificate with an expiration date in year 3 through NCB.

As noted above, the FAA estimates that 57,862 aircraft will be scheduled to be 

reregistered in year 3 and receive a certificate with an expiration date. After 

subtracting out the 4,560 aircraft that will be issued certificates with expiration dates 

during NCB, there will be 53,302 (calculation: 57,862 – 4,560) aircraft reregistered 

through the schedule during year 3. Therefore, a total of 57,862 (calculation: 53,302 

+ 4,560) aircraft will be issued, in year 3, a new certificate with an expiration date. 

In total, 244,578 (calculation: 107,254 + 79,462 + 57,862) active aircraft will receive 

certificates with expiration dates in years 1, 2 and 3. Of these 244,578 reregistrations, 191,652 (calculation: 75,094 + 63,256 +53,302) will be from the reregistration schedule and the remaining 52,296 (calculation: 32,160 +16,206 + 4,560) 

will be issued through NCB. 

Renewal

Renewal begins with the end of re-registration. All aircraft that are registered at the 

end of the re-registration period will be required to renew their registrations, as per 

 36 48 represents the remaining eligible work months, of the original 144, as all of the other 96 

eligible work months, denoted with a “U,” have been used in previous years.
40

this rulemaking, on a 3-year cycle; the FAA also examined 5- and 7-year renewal 

cycles. However some of these aircraft will be sold and issued new registrations 

before their next renewal is due, and, thus will renew due to NCB. As noted in the 

write-up for Re-registration above, the number of normal aircraft registrations in 2007 

was 38,547, while the number of NCB registrations is 15.76% of the number of active

aircraft.

The FAA added the following factors to get the number of aircraft issued registrations 

in each of the three re-registration years:

- the number of aircraft registering under NCB, 

- the number of aircraft issued certificates in each of the three re-registration 

years, and 

- an additional 3,424 aircraft each year to adjust for average annual projected 

growth.37

These calculations and the resultant number of aircraft that will be issued registrations 

in the three re-registration years can be seen in Table B-5; the numbers in lines 1 

through 3 correspond with the numbers described in the Re-registration section above.

Table B-5

1st Year 2nd Year 3rd Year

1 Aircraft issued certificates with 

expiration date by normal registration –

NCB 32,160 16,206 4,560

2 Aircraft reregistered as scheduled 75,094 63,256 53,302

3 Total aircraft issued certificates with 

expiration dates 107,254 79,462 57,862

4 Average annual projected growth 3,424 3,424 3,424

5 Number of aircraft issued registrations 

in the three re-registration years

110,678 82,886 61,286

The total number of registrations for the first three years of this rulemaking is 

254,850, the sum of the numbers in line 5. This is the estimated number of active 

aircraft at the start of year four, the renewal starts at the end of the 3-year cycle. 

Renewal activity for the 3-year cycle will be described first, given the detail involved 

 37 As noted in the main text, the FAA based projections on the annual growth rate for aircraft –

1.4%. Given 244,578 active aircraft, an annual increase of 1.4% would mean that the projected 

long-term annual growth is 3,424 (calculation: 244,578 x 1.4%). Given the number of variables 

involved in this analysis, the FAA decided, 3,424, for each year in this analysis, rather than 

multiply the increasing number of active aircraft each year by 1.4%.
41

in this cycle from additional renewals, and will be followed by calculations for the 5-

and 7-year cycles, respectively.

3-year cycle

A 3-year renewal cycle means that certificates issued in year 1 come due in year 4, 

those issued in year 2 come due in year 5, etc. Because the calculations for years 1 

through 3 are based on re-registration and the calculations for years 4 through 20 are 

based on renewal, this analysis will show both renewal calculations for years 4 

through 6, which are based on aircraft registered under the re-registration years (years 

1 through 3) as well as renewal calculations for year 7, which are based on aircraft 

registered in a renewal year (year 4). Calculations for year 8 through 20, which are 

based on aircraft registered in renewal years, will be similar to those for year 7.

Activity for each year can be broken into two categories – (1) NCB-related 

registrations and (2) rulemaking-related renewals. In each case, as will be discussed 

below, there are two sources for both of these categories. 

A. For year 4:

(1) NCB-related registrations:

a) NCB registrations on existing airplanes:

As noted above, the FAA estimated that each year 15.76% of all aircraft will register 

through NCB. Given that there will be 254,850 registered aircraft at the end of year 3, 

40,164 aircraft will register through NCB (calculation: 254,850 times 15.76%) in year 

4. These aircraft completed re-registration during years 1 through 3. 

b) New aircraft:

As noted above, the FAA assumes 3,424 additional new aircraft each year. Since one 

of the components of NCB registration is new aircraft, these 3,424 aircraft will 

register under NCB.

Thus, the FAA estimates that 43,588 aircraft will register under NCB in year 4 

(calculation: 40,164 plus 3,424).

(2) Rulemaking-related renewals:

a) Normal registration

Subtracting the number of NCB aircraft for year 4 from the total number of aircraft

registered in years 1 through 3 equals the number of registered aircraft remaining that 

were originally reregistered in years 1, 2, or 3. Since aircraft that had reregistered in 

year 1 have registrations that are three years old, those that don’t register through 
42

NCB by their renewal date will have to renew their certificates and are counted as 

renewals due to this rulemaking.

As shown in Table B-5, 110,678 will register in year 1. By year 4, however, a smaller 

number will need to renew, as a certain amount have registered due to NCB. These 

adjustments can be seen in Table B-6.

Table B-6

1st Year 2nd Year 3rd Year

1Totals from Table B-5 110,678 82,866 61,286

2

Year 2 adjustment are the aircraft from year 1 

that register due to NCB after the initial reregistration -12,849 12,849

3 Adjusted Total 97,823 95,735 61,286

4

Year 3 adjustment are the aircraft, from years 1 

and 2 that register due to NCB after the initial reregistration38 -12,283 -12,283 25,689

5Adjusted Total 84,980 82,886 86,984

6

Adjustment, from year 1, of annual growth by 

share of NCB transfer (15.76% x 3,424) -540 540

7Adjusted Total 84,440 83,426

8

Adjustment, from years 1 and 2, of annual 

growth by share of NCB transfer -540 -540 1,080

9Adjusted Total 83,900 82,886 88,064

As noted above, the number of registrations in 2007 was 38,547. Over the course of 

years 2 and 3, the FAA assumes that the same number of aircraft, 38,547, will not go 

through the normal re-registration, but will get new certificates through NCB. These 

are the NCB actions that will take place after initial conversion of the aircraft to new 

registrations during years 2 and 3, respectively, and they correspond to the blocks 

marked as 'U' in Tables B-2 and B-3. The FAA estimates that 1/3 will happen in year 

2, when 12,849 (1/3 of 38,547) that renewed in the year 1 will register due to NCB in 

year 2 (as shown on line 2 of Table B-6), and 2/3 will happen in year 3, when 12,849 

that renewed in year 1 will register due to NCB in year 3 and when 12,849 that 

renewed in year 2 will register due to NCB in year 3 (as shown on line 4 of Table B6). These NCB registrations can be seen in lines 2 and 4 of Table B-6, while line 5 

shows the adjusted totals, of 84,980, 82,886, and 86,984 aircraft in years 1, 2, and 3, 

respectively.

 38 The numbers in this line have been adjusted to account for rounding.
43

As discussed above, the FAA assumes 3,424 new aircraft will register each year. 

Since these are new aircraft and not subject to the years 1 through 3 re-registration 

process, 15.76% of these new aircraft will register through NCB rather than the 

renewal cycle. These adjustments can be seen on lines 6 through 9 of Table B-6. 

Multiplying 15.76% times 3,424 new aircraft equals 540 aircraft; this is the amount 

that will register under NCB. Line 6 shows the amount that registered in year 1 and 

will register due to NCB in year 2; these will be counted as part of the number of 

aircraft whose renewal cycles will start in year 2.39 Line 8 shows the amount that 

originally registered in years 1 and 2 and will register due to NCB in year 3; these will 

be counted as part of the number of aircraft whose renewal cycles will start in year 3. 

Thus, after all the adjustments shown in Tables B-5 and B-6, the 254,580 aircraft40

will have registered and/or renewed (in the case of NCB registration) will total 

83,900, 82,886, and 88,064 in years 1, 2, and 3, respectively.

In a 3-year renewal cycle, the aforementioned 83,900 aircraft in year 1 will need to 

renew in year 4. However, 15.76% of these 83,900 aircraft, or 13,222, will be the 

number of aircraft registering due to NCB during year 4 and these need to be 

subtracted from 83,900, leaving 70,677 aircraft; this is the number of aircraft that 

must be renewed in year 4.

In year 4, there will be 114,265 aircraft registration actions – 43,588 (40,164 + 3,424) 

through NCB and 70,677 through rulemaking renewals. 

B. Year 5:

(1) NCB-related registrations:

Given that 15.76% of all aircraft registered will register through NCB, with 258,274 

aircraft at the end of year 4 (254,850 from year 3 plus the 3,424 new aircraft 

introduced into the system in year 4), 40,407 aircraft will register through NCB 

(258,274 times 15.76%). These aircraft come from the aircraft reregistered during the 

previous three years. Given 3,424 additional new aircraft coming into the system in 

year 5, the FAA estimates that 44,128 aircraft will register under NCB in year 5 

(calculation: 40,704 plus 3,424).

(2) Rulemaking-related renewals:

As shown in Table B-6, due to registrations from NCB taking place on aircraft 

reregistered in years 1 and 2, as well as registrations from NCB taking place on the 

 39 In year 1, the fleet grew by 3,424 aircraft. During year 2, 516 aircraft (3,424 from year 1 x 

15.76%) will need to renew due to NCB actions, so this 540 is added in year 2’s totals and 

subtracted from year 1’s totals.

40 This is the sum of 244,578, the total number of registered aircraft, plus three years worth of 

growth of 3,424 new aircraft per year.
44

new aircraft added in years 1 and 2, 82,886 aircraft will have registered and/or 

renewed.

These 82,886 aircraft will need to renew no later than year 5. However, not all of 

these will renew in year 5; a percentage will register before their scheduled renewal 

date due to NCB:41

- 15.76% of 82,886, or 13,063, will be the aircraft registrations under NCB during 

year 4; these will be subtracted from 82,886, leaving 69,823 aircraft as the number 

registered in year 2 after year 4 NCB-related calculations.

- 15.76% of 69,823, or 11,004, will be the aircraft registrations under NCB during 

year 5, leaving 58,819 aircraft, the number of aircraft registered in year 2 after year 5 

NCB-related calculations. This is the number of aircraft that must be renewed in year 

5.

In year 5, there will be 102,947 aircraft registration actions – 44,128 through NCB 

and 58,819 through rulemaking renewals.

C. Year 6:

(1) NCB-related registrations:

Given that 15.76% of all aircraft registered will register through NCB, with 261,698 

aircraft at the end of year 5 (258,274 from year 4 plus the 3,424 new aircraft 

introduced into the system in year 5), 41,244 aircraft will register through NCB 

(261,698 times 15.76%). These aircraft come from the aircraft registered during the 

previous three years. Given 3,424 additional new aircraft coming into the system in 

year 6, the FAA estimates that 44,668 aircraft will register under NCB in year 6 

(calculation: 41,244 plus 3,424).

(2) Rulemaking-related renewals:

As shown in Table B-6 due to NCB registrations taking place on aircraft registered in 

years 1 and 2, as well as NCB registrations taking place on the new aircraft in years 1 

and 2, 88,064 aircraft will have renewed and/or reregistered in year 3.

These 88,064 aircraft will need to renew no later than year 6. However, not all of 

these will renew in year 6; as described above, a percentage will register before their 

scheduled renewal date due to NCB: 

- 15.76% of 88,064, or 13,879, will be aircraft registrations under NCB during year 4; 

these will be subtracted from 88,064, leaving 74,185 aircraft as the number registered 

in year 3 after year 4 NCB-related calculations.

 41 All renewals due to NCB in years 1 through 3 are reflected in Table B-6. Thus, the 

calculations for rulemaking-related renewals start with calculations in year 4.
45

- 15.76% of 74,185, or 11,692, will be aircraft registrations under NCB during year 5; 

these will be subtracted from 74,185, leaving 62,493 aircraft as the number registered 

in year 3 after year 5 NCB-related calculations.

- 15.76% of 62,439, or 9,849, will be aircraft registrations under NCB during year 6, 

leaving 52,590 aircraft, the number of aircraft registered in year 3 after year 6 NCBrelated calculations. This is the number of aircraft that must be renewed in year 6.

In year 6, there will be 97,312 aircraft registration actions – 44,668 through NCB and 

52,644 through rulemaking renewals.

D. Year 7:

(1) NCB-related registrations:

Given that 15.76% of all registered aircraft will register through NCB, with 265,122 

aircraft at the end of year 6 (261,698 from year 5 plus the 3,424 new aircraft 

introduced into the system in year 6), 41,783 aircraft will register through NCB 

(265,122 times 15.76%). Given 3,424 additional new aircraft coming into the system 

in year 7, the FAA estimates that 45,207 aircraft will register under NCB in year 7 

(calculation: 41,783 plus 3,424).

(2) Rulemaking-related renewals:

As discussed above in the discussion for Year 4, 114,265 aircraft were registered in 

year 4. However, not all of these will renew in year 7; as described above, a 

percentage will register before their scheduled renewal date due to NCB:

- 15.76% of 114,265, or 18,008, will be aircraft registrations under NCB during year 

5; these will be subtracted from 114,265, leaving 96,258 aircraft as the number 

registered in year 4 after year 5 NCB-related calculations.

- 15.76% of 96,258, or 15,170, will be aircraft registrations under NCB during year 5; 

these will be subtracted from 96,258, leaving 81,088 aircraft as the number registered 

in year 4 after year 6 NCB-related calculations.

- 15.76% of 81,088, or 12,779, will be aircraft registrations under NCB during year 6, 

leaving 68,309 aircraft, the number of aircraft registered in year 4 after year 7 NCBrelated calculations. This is the number of aircraft that must be renewed in year 7.

In year 7, there will be 113,516 aircraft registration actions – 45,207 through NCB 

and 68,309 through rulemaking renewals.

The FAA continued this process, of calculating the number of aircraft registrations 

and renewal in a given year, through NCB registrations and through the 3-year 

renewal cycle. The projected 20 year totals are shown in Table B-7:
46

Table B-7

NCB Program Total

Initial 3 years42 63,198 191,652 254,580

% of total 24.80% 75.20% 100.00%

Subsequent 17 years43 841,391 1,117,221 1,931,612

% of total 42.16% 57.84% 100.00%

20 Year Total 877,589 1,308,873 2,186,462

% of total 40.15% 59.86% 100.00%

The same techniques are used for the 5 and 7-year renewal cycles. The 5 and 7- year 

renewal scenarios have a slight variation. These renewals do not start until the 6th and 

8th years, respectively. So for the years past the initial re-registration and before the 

renewal cycle begins, the only activity will be the posting of NCB registrations for 

that year. When the renewals start, the same algorithms as were used in the 3-year 

renewal cycles, of annually subtracting a percentage of aircraft that had been 

registered in previous years to account for NCB, are used in the 5 and 7-year renewal 

cycles. 

5-year cycle

For the 5-year renewal cycle, renewals will not start until year 6. The only activity in 

years 4 and 5 will be registrations due to NCB. The amount of aircraft registrations 

under NCB will be the same across all cycles, the 3, 5 and 7-year cycle; it is a 

percentage (15.76%) of the total aircraft registered. Since the total number of aircraft 

registered increases by 3,424 aircraft per year regardless of the scenario, the number 

of NCB renewals will be 40,164 and 40,704, for years 4 and 5, respectively.

As in the 3-year renewal cycle, for year 6, there will be registrations due to NCB and 

renewals due to the rulemaking-mandate:

(1) NCB-related registrations:

The calculations for year 6 will be the same as described for year 6 in the 3-year 

renewal cycle, resulting in 41,244 aircraft registering under NCB.

 42 The 254,850 for the initial 3 year period includes the 244,578 current active aircraft that will

need to reregister, plus the additional 10,272 aircraft (3 years times 3,424), reflecting average 

annual projected growth that will need to register.

43 Almost all of these registrations will be renewals, with the remainder being additional new 

aircraft that will need to register for the first time.
47

(2) Rulemaking-related renewals:

a) Normal registrations

As shown in Table B-6 above and as discussed in the discussion for year 4 renewals in 

the 3-year cycle, there will be 83,900 aircraft registered in year 1; this figure takes 

into account all NCB-related registrations in years 2 and 3. However, not all of these 

will renew in year 6 as described above; a percentage will renew before their 

scheduled renewal date due to NCB:

- 15.76% of 83,900, or 13,223, will be the aircraft registrations under NCB during 

year 4; these will be subtracted from 83,900, leaving 70,677 aircraft as the number 

registered in year 1 after year 4 NCB-related calculations.

- 15.76% of 70,677, or 11,139, will be the aircraft registrations under NCB during 

year 5; these will be subtracted from 70,677, leaving 59,538 aircraft as the number 

registered in year 1 after year 5 NCB-related calculations.

- 15.76% of 59,538, or 9,383, will be the aircraft registrations under NCB during year 

6, leaving 50,155 aircraft, the number of aircraft registered in year 1 after year 6 

NCB-related calculations. This is the number of aircraft that must be renewed in year 

6.

In year 6, there will be 94,823 aircraft registration actions – 44,668 through NCB and 

50,155 through rulemaking renewals.

The FAA continued this process of applying these same algorithms to both NCBrelated renewals and rulemaking-related renewals for the remaining years of the 5-

year cycle. The projected 20 year totals are shown in Table B-8:

Table B-8

NCB44 Program Total

Initial 3 years 63,198 191,652 254,850

% of total 24.80% 75.20% 100.00%

Subsequent 17 years 814,391 507,995 1,322,386

% of total 61.58% 38.42% 100.00%

20 Year Total 877,589 699,647 1,577,236

% of total 55.64% 44.36% 100.00%

7-year cycle

 44 As in Table B-7, the ‘Initial 3 years’ includes current active aircraft that will need to reregister 

plus additional new aircraft that will need to register, while the ‘Subsequent 17 years’ is made up 

almost exclusively of renewal registrations, with the balance being additional new aircraft that 

will need to register for the first time.
48

For the 7-year renewal cycle, since renewals will not start until year 8, the only 

activity in years 4 through 7 will be registrations due to NCB. As with the 3 and 5-

year cycles, the amount of aircraft registrations under NCB will be the same as these 

other two cycles. Since the total number of aircraft registered increases by 3,424 

aircraft per year regardless of the scenario, the number of NCB registrations will be 

40,164, 40,704, 41,244, and 41,783 for years 4, 5, 6, and 7, respectively.

As in the 3-year and 5-year renewal cycles, for year 8, there will be registrations due 

to NCB and renewals due to the rulemaking-mandate:

(1) NCB-related registration:

At the beginning of year 8, there will be 268,546 aircraft; 15.76% of 268,546 aircraft 

equals 42,323 aircraft. This will be added to the additional 3,424 new aircraft coming 

into the system in year 8; the FAA estimates that 45,747 aircraft will register under 

NCB in year 8 (calculation: 42,323 plus 3,424). This is the same number of aircraft 

registered under NCB in year 8 in the 3 and 5-year cycles.

(2) Rulemaking-related renewals:

a) Normal registration

As shown in Table B-6 above and as discussed in the discussion for year 4 renewals in 

the 3-year cycle and year 6 renewals in the 5-year cycle, there will be 83,900 aircraft 

registered in year 1; this figure takes into account all NCB-related registrations in 

years 2 and 3. However, not all of these will renew in year 8; as described above, a 

percentage will register before their scheduled renewal date due to NCB:

- 15.76% of 83,900, or 13,223, will be aircraft registrations under NCB during year 4; 

these will be subtracted from 83,900, leaving 70,677 aircraft as the number registered 

in year 1 after year 4 NCB-related calculations.

- 15.76% of 70,677, or 11,139, will be aircraft registrations under NCB during year 5; 

these will be subtracted from 70,677, leaving 59,538 aircraft as the number registered 

in year 1 after year 5 NCB-related calculations.

- 15.76% of 59,538, or 9,383, will be aircraft registrations under NCB during year 6; 

these will be subtracted from 59,538, leaving 50,155 aircraft as the number registered 

in year 1 after year 6 NCB-related calculations.

- 15.76% of 50,155, or 7,904, will be aircraft registrations under NCB during year 7; 

these will be subtracted from 50,155, leaving 42,251 aircraft as the number registered 

in year 1 after year 7 NCB-related calculations.

- 15.76% of 42,251, or 6,659, will be aircraft registrations under NCB during year 8, 

leaving 35,592 aircraft, the number of aircraft registered in year 1 after year 8 NCBrelated calculations. This is the number of aircraft that must be renewed in year 8.
49

In year 8, there will be 81,339 aircraft registration actions – 45,747 through NCB and 

35,592 through rulemaking renewals. 

The FAA continued this process of applying these same algorithms to both NCBrelated renewals and rulemaking-related renewals for the remaining years of the 7-

year cycle. The projected 20 year totals are shown in Table B-9:

Table B-9

NCB45 Program Total

Initial 3 years 63,198 191,652 254,850

% of total 24.80% 75.20% 100.00%

Subsequent 17 years 814,391 269,864 1,084,255

% of total 75.11% 24.89% 100.00%

20 Year Total 877,589 461,516 1,339,105

% of total 65.54% 34.46% 100.00%

It is important to note that for all three Scenarios, as shown in Tables B-7, B-8, and B9:

- the totals for the first three years the same, as all scenarios assume a 3-year reregistration period; 

- the NCB registration numbers are the same for the 17-year renewal period, 

reflecting the fact that the amount of aircraft registrations under NCB are 

always the same percentage of the total aircraft registered; and 

- the only difference is the number of rulemaking-related renewals, occurring in 

years 4 through 20. These numbers can be seen in each of these tables by 

looking at the ‘Program’ total for the 17-years of renewal.

 45 As in Table B-7, the ‘Initial 3 years’ includes current active aircraft that will need to reregister 

plus additional new aircraft that will need to register, while the ‘Subsequent 17 years’ is made up 

almost exclusively of renewal registrations, with the balance being additional new aircraft that 

will need to register for the first time.
50

APPENDIX C – EXPLANATION OF ERROR RATES CALCULATIONS
51

Improving the accuracy of the Civil Aircraft Register is the major reason for this 

rulemaking. Government agencies, including the FAA, those providing national 

defense and security, and those providing law enforcement, as well as the aviation 

industry should be able to determine key information from the registration listing with 

a reasonable certainty that that information is accurate. This key information includes 

the registration status of an aircraft and the name and address of that registered 

aircraft’s owner. However, the current error rate of the Registry casts doubt on the 

principle that this key information is accurate. The discussion below will quantify the 

present accuracy rate and the probable accuracy rates for the scenarios discussed in 

the main text.

A long-term program of annually validating aircraft status and registration addresses 

ended at the end of 1977. Since then, under the Triennial Aircraft Registration 

Report, notices have been sent to aircraft owners when three years have passed 

without these owners fulfilling certain registration actions. Approximately 70,000 

triennial notices are sent annually, and these result in 9,000 registration updates being 

returned to the Registry.

The record for an aircraft is considered to be in error if:

- it is in a transitional status such as ‘sale reported’ or ‘registration pending’ for 

an excessive period of time (six months and one year, respectively), 

- the associated registration address is incorrect, or 

- the aircraft has left service permanently, but the owner has not requested 

cancellation of registration. This situation is often unreported to the FAA and 

therefore unknown to the Registry.

Long Term Error Rate Calculations

The following table, Table C-1, shows the data that the FAA used to calculate the 

current error rate, the Current Long Term Error (CLTE) rate, and the Projected Long 

Term Error (PLTE) rate:
52

Table C-1

1 Total registered aircraft 357,020

2 Estimated active aircraft46 241,100

3 Difference (line 1 minus line 2) 115,920

4 Aircraft not expected to reregister (line 3 x 97%) 47 112,442

5 Aircraft expected to reregister (line 1 minus line 4) 244,578

6 Aircraft with records in error through 1977 15,563

7 Aircraft with records in error since 1977 (line 4 minus line 6) 96,879

8 Aircraft with known bad addresses 30,090

9 Sale reported aircraft over 6 months old 17,000

10 Registration pending aircraft over 12 months old 2,200

11 Total to be eliminated as a result of rulemaking 

(sum of lines 8 through 10)

49,290

12 Unidentified inactive aircraft (line 7 minus line 11) 47,589

Dividing line 4 by line 1 equals 31.5%, which represents, within the Registry’s 

records, incorrect aircraft information based on the total number of registered aircraft; 

this can also be thought of as the error rate within the Registry’s records. Thus, the 

current error rate is 31.5%.

These errors have collected since at least 1977. Their percentage as a portion of 

registered aircraft is referred to as the CLTE rate. To determine how fast this group of 

aircraft grown, the FAA first subtracted those aircraft that were identified as being in 

error by the end of 1977, 15,563, when the last verification program ended (line 6). 

Subtracting 15,563 from 112,442 leaves 96,879 aircraft whose records have migrated 

to the ‘in error’ group since 1978; 30 years ago (line 7). Dividing 96,879 by 30 years 

gives an average of 3,229 AC entering the error group annually. Since aircraft can 

only enter the error group from the active group, 1.3% (calculation: 3,229 divided by 

244,578) active aircraft enter the error group annually. Given a 3-year renewal cycle, 

4% of active aircraft will enter this error group. Similarly, given 5-year and 7-year 

renewal cycles, 6.6% and 9.2% of active aircraft will enter this error group, 

respectively.

To get the PLTE rate, the FAA first calculated the error group that will be eliminated 

as a result of this rulemaking. As shown in Table C-1, on lines 8 through 10, these 

include aircraft with bad addresses, sale reported aircraft over 6 months old, and 

 46 As explained in Appendix B, this is based on data from the 2008 FAA Administrator’s Fact 

Book. These estimates are compared to the number of registered aircraft (line 1) to determine 

the estimated number of aircraft that are no longer active.

47 Based on experience, the Registry expects 97% of the difference in line 3 not to reregister.
53

registration pending aircraft over one year old. Line 11 shows that the FAA expects 

47,589 aircraft will be eliminated from the error group as a result of this rulemaking.

As shown on line 12 (subtracting 47,589 from 97,742), the FAA expects that there 

will be 49,290 unidentified inactive aircraft; while these aircraft will be eliminated 

during the initial re-registration, they represent a group of aircraft that have 

historically entered the ‘in error’ group without being reported in any way. The FAA 

acknowledges that nothing in this rule will keep this phenomenon from reoccurring in 

the future. So the FAA expects that unidentified inactive aircraft will accumulate at a 

similar rate during each renewal cycle. Dividing 49,290 unidentified inactive aircraft 

by 30 years and then that result by the number of active aircraft (244,578) yields a

PLTE rate of 0.65% per year. Given 3-year, 5-year, and 7-year renewal cycles, 2%, 

3.3%, and 4.6% of active aircraft will enter this error group, respectively.

Standing Error Calculations

There is another group of aircraft with bad registration information that the FAA 

knows about from experience through the Triennial Program. These are the aircraft 

with address or status changes that have not been reported by the owner, but the FAA 

believes will be reported when prompted. For the following set of calculations, for a 

three-year triennial cycle, the FAA is assuming three distinct groups of aircrafts –

those in the first, second, and third years of this cycle.

The FAA sends out 70,000 Triennial Program mailings annually. Over a year’s time, 

about 9,000 notices with record update information are returned to the Registry, which 

have accumulated over a 3-year period because the Triennial Program notices are not 

sent until three years after an aircraft registration action was last processed. Thus, for 

aircraft in the third year of this cycle, there will be about 9,000 with address changes 

The FAA estimates that 3,000 notices accumulate during each of the three years. 

However, this is also happening to aircraft in both the first and second years of this 

cycle. For those in the second year, they will have completed two of the three years 

with no Registry-related activity. Thus, there will be 3,000 (first year) plus 3,000 

(second year) changes unreported, or a total of 6,000, that have not been reported. 

And, there is a third group that is in the first year of this cycle and has accumulated 

3,000 changes. Adding these 9,000, 6,000 and 3,000 aircraft changes from these three 

groups sum to 18,000 aircraft with out-of-date registrations.

Because the Registry operates this program on a continuous basis with monthly 

mailings, the FAA surmises that this level of 18,000 out-of-date aircraft records is 

fairly constant under a three-year notice cycle. Thus, at any time, 7.4% of active 
54

aircraft (calculation: 18,000 divided by 244,578 active aircraft) are in error, and the 

FAA refers to these errors as the Standing Error rate. To the aircraft-owning public, a 

requirement to reregister every three years should have the same effectiveness as a 

Triennial Program notice in prompting reports of registration changes, so the FAA 

assumes that the Standing Error rate will be the same under the three-year renewal 

scenario as it is for the Triennial Program.

Projected Error Calculations 

The FAA added the current error rate with the current standing error rate to equal the 

total current error of 36.5% (calculation: 31.5% plus 5%), thus, the need for this 

rulemaking. The FAA further added the projected long-term error rate and the 

projected standing error rate to yield a projected error 9.4% (calculation: 2% plus 

7.4%). However, the FAA assumes that the rule and two other FAA programs48 will 

elicit a 50% improvement in on-time status change report filings. This gives a 

projected error rate of 5.7% (calculation: 2% plus 7.4%/2) for a 3-year renewal cycle.

The FAA then applied this methodology to estimating the standing errors for the 5-

and 7-year scenarios, by assuming that 3,000 notices are returned each year.

As described above, for the 3-year renewal cycle, there will be three groups with 

notices coming in:

a) one group where 9,000 notices are returned in the Registry, with 3,000 changes 

occurring in the first year of this 3-year cycle, 3,000 during the second year, 

and 3,000 the third year. 

b) a second group, that had completed two years of its 3 year cycle, which will 

have accumulated 6,000 unreported changes, and 

c) a third group, which had completed one year of its 3-year cycle, which will 

have 3,000 unreported changes.

 48 These programs include:

- The registry's ‘general awareness initiative’ for aircraft owners to keep their addresses up to 

date. In May 2004, the FAA put out a press release, which can be referenced at 

http://www.faa.gov/news/press_releases/news_story.cfm?newsId=6402. This press release 

stresses that, starting June 1, 2004, U.S. aircraft owners risk having their aircraft registrations 

cancelled because the addresses they have on file with the FAA are of out-of-date.

- As described in footnote 2, the FAA, in concert with TSA, is evaluating flight plan filings to 

determine if an aircraft has the proper profile for operation in the National Air Space (NAS).
55

This sequence can be seen in Table C-3:

Table C-3

Year of status change not reported 3 2 1

Completed years of the cycle:

3 3,000 3,000 3,000

2 3,000 3,000

1 3,000

Total 9,000 6,000 3,000

For the 5-year renewal cycle, there will be 5 groups, as shown in Table C-4:

Table C-4

Year of status change not reported 5 4 3 2 1

Completed years of the cycle:

5 3,000 3,000 3,000 3,000 3,000

4 3,000 3,000 3,000 3,000

3 3,000 3,000 3,000

2 3,000 3,000

1 3,000

Total 15,000 12,000 9,000 6,000 3,000

Summing the bottom row of Table C-4 equals 45,000 remaining bad addresses; 

dividing 45,000 by 244,578, the number of active aircraft, yields a standing error rate 

of 18.40%.

The FAA added the projected long-term error rate and the projected standing error 

rate to yield a projected error 21.7% (calculation: 3.3% plus 18.4%). However, as 

above, the FAA assumes a 50% improvement in on-time status change report filings, 

yielding a projected error rate of 12.5% (calculation: 3.3% plus 18.4%/2) for a 5-year 

renewal cycle.
56

For the 7-year renewal cycle, there will be 7 groups, as shown in Table C-6:

Table C-5

Year of status change 

not reported 7 6 5 4 3 2 1

Completed years of the 

cycle:

7 3,000 3,000 3,000 3,000 3,000 3,000 3,000

6 3,000 3,000 3,000 3,000 3,000 3,000

5 3,000 3,000 3,000 3,000 3,000

4 3,000 3,000 3,000 3,000

3 3,000 3,000 3,000

2 3,000 3,000

1 3,000

Total 21,000 18,000 15,000 12,000 9,000 6,000 3,000

Summing the bottom row of Table C-5 equals 84,000 remaining bad addresses; 

dividing 84,000 by 244,578, the number of active aircraft, yields a standing error rate 

of 34.3%. This can be contrasted to the 18.4% for the 5-year cycle, again, showing 

the increase in the error rate by extending the renewal cycle by an additional two 

years.

The FAA added the projected long-term error rate and the projected standing error 

rate to yield a projected error 38.9% (calculation: 4.6% plus 34.3%). However, as 

above, the FAA assumes a 50% improvement in on-time status change report filings, 

yielding a projected error rate of 21.7% (calculation: 4.6% plus 34.3%/2) for a 7-year 

renewal cycle.

In these calculations for the 5 and 7-year renewal cycles, the FAA is extrapolating 

from its experience from the 3-year Triennial Program. Given that people are more 

likely to change addresses as time passes, the likelihood of aircraft owners with 

multiple address changes will be greater for a 5-year period than a 3-year period and 

for a 7-year period than a 5-year period. Similarly, there is a greater likelihood of

other reportable status changes happening over longer period of times. The Agency 

acknowledges, therefore, that these error rates for the 5 and 7-year renewal cycles 

maybe too high, as these error rates will include aircraft owners who have moved 

more than one time or had other status changes during the course of these cycles. In 

particular, the FAA recognizes that the error rate for the 7-year cycle is probably more 

in error than the corresponding rate for the 5-year cycle.

In the following tables, Table C-6 summarizes the current error rates, while Tables C7 summarizes the projected error rates for a 50% improvement in compliance.
57

Table C-6 - Projected Error Rate 

Based on the Current System

Table C-7 - Expected Error Rate –

50% Improved Compliance

Yrs Standing Long Term Total-EST Yrs Standing Long Term Total-EST

3 7.4% 2% 9.4% 3 3.7% 2% 5.7%

5 18.4% 3.3% 21.7% 5 9.2% 3.3% 12.5%

7 34.3% 4.6% 38.9% 7 17.2% 4.6% 21.7%
58

Regulatory Evaluation Preamble Summary

Regulatory Evaluation, Regulatory Flexibility Determination, International 

Trade Impact Assessment, and Unfunded Mandates Assessment

Changes to Federal regulations must undergo several economic analyses. First, 

Executive Order 12866 directs that each Federal agency shall propose or adopt a 

regulation only upon a reasoned determination that the benefits of the intended 

regulation justify its costs. Second, the Regulatory Flexibility Act of 1980 (Public 

Law 96-354) requires agencies to analyze the economic impact of regulatory changes 

on small entities. Third, the Trade Agreements Act (Public Law 96-39) prohibits 

agencies from setting standards that create unnecessary obstacles to the foreign 

commerce of the United States. In developing U.S. standards, this Trade Act requires 

agencies to consider international standards and, where appropriate, that they be the 

basis of U.S. standards. Fourth, the Unfunded Mandates Reform Act of 1995 (Public 

Law 104-4) requires agencies to prepare a written assessment of the costs, benefits, 

and other effects of proposed or final rules that include a Federal mandate likely to 

result in the expenditure by State, local, or tribal governments, in the aggregate, or by 

the private sector, of $100 million or more annually (adjusted for inflation with base 

year of 1995). This portion of the preamble summarizes the FAA’s analysis of the 

economic impacts of this final rule. We suggest readers seeking greater detail read 

the full regulatory evaluation, a copy of which we have placed in the docket for this 

rulemaking. 

In conducting these analyses, FAA has determined that this rule: (1) has benefits that 

justify its costs, (2) is not an “economically significant regulatory action” but is a 

“significant regulatory action” for other reasons as defined in section 3(f) of Executive 

Order 12866, (3) is “significant” as defined in DOT's Regulatory Policies and 

Procedures; (4) will not have a significant economic impact on a substantial number 

of small entities; (5) will not create unnecessary obstacles to the foreign commerce of 

the United States; and (6) will not impose an unfunded mandate on state, local, or 

tribal governments, or on the private sector by exceeding the threshold identified 

above. These analyses are summarized below.

Summary

Total Costs and Benefits of this Rulemaking

Summary Of Costs and Benefits in Millions of 2007 Dollars

Re-registration and 3-Year Renewal 

(Triennial Eliminated)

Cost Present Value Benefit:

$29.9 $16.3 Reduction in Error Rate by 31%
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This rule will mandate that all aircraft owners reregister their aircraft over a 3-year 

period, and then renew these registrations on a 3-year basis. Total estimated costs, 

over 20 years is $29.9 million ($16.3 million, present value). These costs include both 

the costs to aircraft owners as well as processing costs for the Civil Aircraft Registry 

and include costs savings from the elimination of the Triennial Program.

The primary benefit of this rulemaking will be the increased accuracy of the records 

within the Aircraft Registry. Currently, approximately one third of registered aircraft 

information is incorrect. The FAA has concluded that the level of accuracy in the 

system of records must be significantly improved in order to better serve the needs of 

the users of the system as well as support its own operations. Benefits will accrue 

from improving the database as well as improving the data collection process.

Who is Potentially Affected by this Rulemaking

Private Sector

There are currently about 357,000 registered aircraft, of which about 241,000 are 

active aircraft. The FAA expects about 245,000 aircraft to reregister and then, every 3 

years, renew their certificate. The FAA also expects between an additional 3,424 new 

aircraft to register each year.

Government

This rule will increase the workload on the Civil Aviation Registry, which will have 

to process an additional 1.3 million renewal and registration certificates over a 20-

year period. However, this additional work will be partially offset by the elimination 

of the Triennial Aircraft Registration Program.

Our Cost Assumptions and Sources of Information

• Discount rate – 7%;

• Period of analysis – 2010 through 2029;

• All monetary values are expressed in 2007 dollars;

• The FAA based projections on a 1.4% annual growth rate

• The FAA will use the following unit costs:

g) $5 – fee per aircraft for both re-registration and renewal 

h) $37.20 – hourly rate of an aircraft owner’s time

i) $9.10 – FAA processing costs for re-registration per applicant

j) $5.82 – FAA processing costs for renewal per applicant

k) $1.63 – FAA processing costs for the Triennial Program for each notice sent

l) $16.80 – FAA processing costs for the Triennial Program per reply

Benefits of this Rulemaking
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The primary benefit of this rulemaking will be the increased accuracy of the records 

within the Aircraft Registry. Currently, over one third of registered aircraft 

information is incorrect. Inaccurate records have many negative consequences. For 

example, FAA uses aircraft records to identify owners of specific aircraft so that 

safety related information, such as airworthiness directives (ADs), can be delivered to 

those owners, but because of inaccuracies, many safety-related mailings are returned 

without delivery. Aircraft manufacturers also use aircraft records for the same 

reasons, to send out safety-related information. Law enforcement and security 

agencies rely upon FAA’s aircraft records to identify and locate owners of aircraft. 

The FAA has concluded that the level of accuracy in the system of records must be 

significantly improved in order to better serve the needs of the users of the system as 

well as support its own operations. Specifically, benefits will accrue from improving 

the database as well as improving the data collection process. The benefits from 

improving the Registry database include cost savings, better service for aircraft 

owners, and help with law enforcement. The benefits to be realized by improving the 

data collection process also include cost savings as well as a more accurate response 

rate.

Costs of this Rulemaking

This rulemaking requires that all aircraft owners will have to re-register their aircraft 

during a 3-year period, that all aircraft registrations will need to be renewed every 3 

years, and that the present Triennial Program is eliminated in its entirety.

The FAA estimates that approximately 244,600 aircraft will each go through the reregistration process, and so will be issued a new registration certificates. Following reregistration aircraft will renew their registration every 3 years. In calculating the costs 

of the rule, the FAA counts the number of aircraft transactions that result from either 

re-registration or renewal. Moreover, FAA did not include the cost of normal course 

of business registrations and the $5 fee because the fee is an economic transfer. These 

costs are recognized in a separate section in the rule but are not included in the total 

cost of the rule. 

The FAA estimates that over 20 years the Registry will process 1.3 million certificate 

actions, composed of re-registration and renewal. However, the Registry will achieve 

cost savings with the elimination of the Triennial Program. Over 20 years, the rule 

replaces the current system with a 3-year re-registration program, followed by a 3-

year renewal cycle that is estimated to cost $29.9 million ($16.3 million, present 

value).