11/12/2010 08:47 2022675075 OFFICE OF RULEMAKING PAGE 01 

DEf^RTMENT OF 

October 5, 2010 ''^AHSPORWION 

^ UCKET OPER/VFIONS 

Senator Jim Demint 

340 Russell ;n;o m 12 A S: 01 

United States Senate 

Washington, DC 20510 

Senator Lindsey Graliam 

290 Russell Senate Office Building 

Washington, DC 20510 

Congressman Joe Wilson, 

212 Cannon House Office Building 

Washington, DC 20515 

Secretary Ray LaHood 

US. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Secretary Janet Napolitano 

Department of Homeland Security 

U.S. Department of Homeland Security 

Washington, DC 20528 

Federal Aviation Administration 

800 Independence Ave, SW 

Washington, DC 20591, 

Transportation Security Administration 

601 South 12th Street 

Arlington, VA 20598 

Dear Sir or Madam, 

This letter serves to request a review and revisions to regulations found in 14 CFR part 45 

(Attached) regarding the display and size of aircraft markings. Historically, aircraft markings are 

unique safety issue with responsibility squarely on the shoulders of the Federal Aviation 

Administration (F/\A). However, this regulation has not been revised in decades and is long 

overdue by time and domestic events. I believe at this time that policy development and 

enforcement responsibilities should be shared by multiple Federal agencies and the review 

should commence immediately. 

The FAA and local law enforcement agencies receive many telephone calls throughout the 

year by citizens reporting low flying aircraft. These reports are submitted by citizens concerned 

for safely of aircraft occupants, people on the ground or the suspicious nature of the aircraft 

activity. Many times, the citizens are sincere and attempt to do their best to identify these low 

flying aircraft by their registration number however they are frequently encumbered because the 
11/12/2010 08:47 2022675075 OFFICE OF RULEMAKING PAGE 02 

registration numbers are displayed in two or three inch size as permitted by 14 CFR 45.29 (a)-

(h). Also, they may be impeded because of shading/contrasting, ornamentation or italic design. 

While these areas are addressed registration displays are prohibited 14 CFR 45.21 and 45.23, 

enforcement seems to be difficult as one walking around a local airport will soon realize 

(examples attached). 

The fact is that rule 14 CFR 45, identity's any aircraft that reaches 30 years of age as an 

"antique" aircraft. With aircraft classified as an antique, the owner may now replace the 

aircraft's registration with three inches letters/numbers even though the aircraft may have 

previously or originally displayed twelve inch lettering. This rule also applies to aircraft that are 

currently manufactured if it resembles an antique aircraft of 30 years ago. These allowances 

might be appropriate for a unique aircraft such as a Boeing B-17 that is controlled by registration 

of when and where is can fly it makes no sense from a safety perspective or a security 

perspective. For example, there is virtually no difference in appearance between of a 1962 

Cessna Model 172 and a 2008 Model 172. So, why does one aircraft have to display a twelve 

inch letters and the other can resize down to three inch letters? Again, this makes absolutely no 

sense from either a safety or security standpoint. 

The use of two or three inch registration markings on civil aircraft should be discontinued for 

aircraft with surface areas large enough to display twelve inch markings as soon as possible. It 

does not take scientific research to determine that twelve inch letters/numbers of high contrast 

color are more easily seen that two or three inch letters of slightly contrasting colors. From a 

safety enhancement and security perspective, the age of the aircraft can no longer be a 

consideration. Considering the current environment of security and safety, we need to make 

aircraft identification markings easier for the public and government officials to read. 

Respectfully, 

(ern S. Mosher 

4338 Pinewood Circle 

Beaufort, SC 29906