Registration extension

[cowman]

So I have a problem...

I bought my airplane back in July and sent my application for registration in. About a month later I got back a letter saying that they weren't happy with the bill of sale we used and sent another. Ok, no problem I mailed that off to get the seller's signature on it and some time later I got that back and sent it in.

Well as of today I still don't have it and my 90-day period expires on 10/20. With the government shutdown I don't expect to see it by then either.

I understand you can get an extension but how does that work exactly? Can you just do it by phone with the registration branch or does there need to be more paperwork mailed out in which case at the speed they process it, I'm just going to be hosed for a while.

..and obviously if the idiots in congress don't get in gear before then I'm hosed either way...

 

[BillTIZ]

Phone with registration branch that is on furlough?
Good luck with that.

 

[dans2992]

I wouldn't worry about it. Probably won't get checked and if it does, you have a valid excuse...

 

[N747JB]

I'd look on the FAA website, it will show registration data before you get it in the mail. Print it out, even if it shows registration pending. Couldn't hurt.
Then again with the shutdown, I can't imagine too many ramp checks!

 

[N801BH]

I'd look on the FAA website, it will show registration data before you get it in the mail. Print it out, even if it shows registration pending. Couldn't hurt.
Then again with the shutdown, I can't imagine too many ramp checks!

+1....

 

[flyingron]

Who's going to enforce it with all the inspectors on furlough.

 

[poadeleted20]

Who's going to enforce it with all the inspectors on furlough.

The problem occurs if you have an accident or incident. The FAA jumps on you for violating the FAR's by flying an airplane not legally registered, and the insurance company denies the claim for the same reason. Likewise, if you get cross-wise with ATC and they file a Pilot Deviation, once the FSDO goes back to work and starts investigating, the first thing they'll do is check the airman and aircraft paperwork.

 

[Henning]

So I have a problem...

I bought my airplane back in July and sent my application for registration in. About a month later I got back a letter saying that they weren't happy with the bill of sale we used and sent another. Ok, no problem I mailed that off to get the seller's signature on it and some time later I got that back and sent it in.

Well as of today I still don't have it and my 90-day period expires on 10/20. With the government shutdown I don't expect to see it by then either.

I understand you can get an extension but how does that work exactly? Can you just do it by phone with the registration branch or does there need to be more paperwork mailed out in which case at the speed they process it, I'm just going to be hosed for a while.

..and obviously if the idiots in congress don't get in gear before then I'm hosed either way...

You probably have 2 more cycles of "we didn't like something" left

 

[Henning]

The problem occurs if you have an accident or incident. The FAA jumps on you for violating the FAR's by flying an airplane not legally registered, and the insurance company denies the claim for the same reason. Likewise, if you get cross-wise with ATC and they file a Pilot Deviation, once the FSDO goes back to work and starts investigating, the first thing they'll do is check the airman and aircraft paperwork.

Please show me in your policy where legal registration is a denial issue.

 

[poadeleted20]

Please show me in your policy where legal registration is a denial issue.

My policy says the airplane must be legally airworthy (or operating under a Special Flight Permit with the company's approval) for the policy to be in force. Since lack of current registration makes it legally unairworthy...

 

[silver-eagle]

....SNIP.... Likewise, if you get cross-wise with ATC and they file a Pilot Deviation, once the FSDO goes back to work and starts investigating, the first thing they'll do is check the airman and aircraft paperwork.

Thats when I go stealth mode and become 333RL.

 

[comanchepilot]

My policy says the airplane must be legally airworthy (or operating under a Special Flight Permit with the company's approval) for the policy to be in force. Since lack of current registration makes it legally unairworthy...

The paperwork does not make it unairworthy from a technical perspective. . . . merely from a paperwork perspective. The aircraft is unairworthy technically not substantively.

Ron, in order for an insurer to deny coverage in this very unusual situation they will need to prove that the lack of a piece of paper was caused by the policy holder, and that the lack of the piece of paper caused the incident or accident . . . . you know that the technical paperwork reasons for denial of claims expired back in the dark ages. . . .

 

[Henning]

The paperwork does not make it unairworthy from a technical perspective. . . . merely from a paperwork perspective. The aircraft is unairworthy technically not substantively.

Ron, in order for an insurer to deny coverage in this very unusual situation they will need to prove that the lack of a piece of paper was caused by the policy holder, and that the lack of the piece of paper caused the incident or accident . . . . you know that the technical paperwork reasons for denial of claims expired back in the dark ages. . . .

No, he doesn't. It actually goes even further, unless there was an intent to defraud, the insurance company will have a very difficult time denying.

 

[poadeleted20]

The paperwork does not make it unairworthy from a technical perspective. . . . merely from a paperwork perspective. The aircraft is unairworthy technically not substantively.

It makes the plane legally unairworthy from an FAA perspective. They do not make differentiation about "technical" versus "paperwork" -- it's either legal or it's not, and the paperwork is part of the legality.

Ron, in order for an insurer to deny coverage in this very unusual situation they will need to prove that the lack of a piece of paper was caused by the policy holder, and that the lack of the piece of paper caused the incident or accident . . . . you know that the technical paperwork reasons for denial of claims expired back in the dark ages. . . .

Not if the contract requires it be legal for flight to be in force -- that would be a breach of contract, and they need not show more than that.

 

[flyingron]

It does NOT make the plane unairworthy. It's perfectly "airworthy", just not legal to operate. Airworthy is defined in 3.5:

Airworthy means the aircraft conforms to its type design and is in a condition for safe operation. ​

Further this is expanded in 8130.2G which defines the FAA process for determining airworthiness:

200. Definition Of The Term “Airworthy” for U.S.Type-Certificated (TC) Aircraft.
Although the term “airworthy” is defined in 14CFR § 3.5(a), a clear understanding of its
meaning is essential for use in the FAA’s airworthiness certification program. Below is a
summary of the conditions necessary for the issuance of an airworthiness certificate. A review
of case law relating to airworthiness reveals two conditions that must be met for an aircraft to be
considered “airworthy.” Title 49, United States Code (49 U.S.C.) § 44704(c) and
14CFR § 21.183(a), (b), and (c) state that the following two conditions necessary for issuance of
an airworthiness certificate:
a. The aircraft must conform to its type design. Conformity to the type design is considered
attained when the aircraft configuration and the engine, propeller, and articles installed are
consistent with the drawings, specifications, and other data that are part of the TC. This includes
any supplemental type certificate (STC) and repairs and alterations incorporated into the aircraft.
b. The aircraft must be in a condition for safe operation. This refers to the condition of the
aircraft relative to wear and deterioration, for example, skin corrosion, window
delamination/crazing, fluid leaks, and tire wear.
Note: If one or both of these conditions are not met, the aircraft would not be
considered airworthy. Aircraft that have not been issued a TC must meet the
requirements of paragraph 200b of this order.​

Operating with an expired registration only puts you in violation of 91.203, it doesn't render your aircraft unairworthy.

 

[cowman]

That's all interesting stuff but what I really wondering was if all it took to get an extension was a phone call.

 

[Henning]

That's all interesting stuff but what I really wondering was if all it took to get an extension was a phone call.

No need, fill out another form, keep the pink copy, throw away the rest until the permanent comes back on the other.

 

[cowman]

I should probably also mention I might be taking my checkride in a few more weeks. It would be good to have everything in order so the DPE won't have anything to complain about.

 

[N801BH]

I should probably also mention I might be taking my checkride in a few more weeks. It would be good to have everything in order so the DPE won't have anything to complain about.

Houston.............. Now we have a problem...

 

[cowman]

Good news for anyone else who was in this pickle- they're open again and yes they will give you an extension over the phone. Mine is being mailed out, they will also fax it if you have a fax handy.

 

[RJM62]

Good news for anyone else who was in this pickle- they're open again and yes they will give you an extension over the phone. Mine is being mailed out, they will also fax it if you have a fax handy.

Well, thank heavens for that. Who knows how many lives will be saved now that all those expired, utterly meaningless pieces of paper are being replaced with non-expired, but equally meaningless pieces of paper? Will an airplane even fly properly with an expired registration? That's like... it's like... it's like not filing a flight plan!

Aviation is surely safer today than it was yesterday, and all is well with the world.

(On a serious note, glad you got it squared away.)

-Rich

 

[cowman]

My extension arrived in the mail today, so technically I lost from midnight last night until around 2pm but I wasn't really going to be flying during that period anyway.

I have to give credit to the registration branch. I called and got right to the point, the woman who answered quickly looked me up by N-number and saw the issue. I got a "120 day or until application is processed" extension with no real hassle other than having to make the call when they were open. Very polite and got me taken care of quickly once I got through the waiting muzak... which considering they just re-opened that morning wasn't bad at all, I think < 10minutes but I didn't time it.

Interestingly enough she was able to tell me they had received my new bill of sale but it was going to be another 7 weeks before they process it. I assume they must have an automated system scanning in everything they receive, but wow. It's two names, an address, a date, and a signature on their own form. Wouldn't it have taken as much time and effort to just send me my real registration at that point? It's not like it takes a legal team to review something that simple, anyone who can read ought to be able to pull that much off.

I really think there ought to be a provision where if you've done everything you're supposed to do, you should be able to keep flying if the FAA doesn't hold up their end. As I said, I was happy with how they handled me on the phone and I'm flying again with minimal hassle but had the shutdown not ended I'd have been grounded over nothing more than a printed sheet of paper. That's BS IMHO.