Temporary Registration Number

[NoHeat]

Does anybody have experience with temporarily covering up a new N-Number on an old plane, while waiting for the FAA form 8050-64 for the new number?

Let's say my old registration number is N1111 and I reserved N2222. I then sent a request to the FAA to assign N2222 to the plane. But the FAA is slow, with a month-long backlog before they can send me the form 8050-64 that I must possess before N-Number can be officially changed. The shop says no problem, we'll peel off the old N1111 vinyl letters, put on the new N2222 vinyl letters, and immediately cover up the N2222 with a temporary sheet of low-tack white vinyl bearing the old number N1111. I can then fly the plane with my old registration and airworthiness certificates for N1111. The temporary number won't blow off in the wind, but it will come off easily when I'm ready -- once I receive the delayed form 8050-64.

I'm just wondering if this could lead to any trouble. The authority that the factories use with the non-permanent letters is 45.21:

(c) Aircraft nationality and registration marks must—
(1) Except as provided in paragraph (d) of this section, be painted on the aircraft or affixed by any other means insuring a similar degree of permanence;
(2) Have no ornamentation;
(3) Contrast in color with the background; and
(4) Be legible.
(d) The aircraft nationality and registration marks may be affixed to an aircraft with readily removable material if—
(1) It is intended for immediate delivery to a foreign purchaser;
(2) It is bearing a temporary registration number; or
(3) It is marked temporarily to meet the requirements of §45.22(c)(1) or §45.29(h) of this part, or both.
​

This situation doesn't qualify for (1) as there's no foreign purchaser, and not for (3) because that's just for putting big letters on a plane flying into the ADIZ. So how about (2), the temporary registration number?


I'm not sure how broad the term "temporary registration number" is. Among other FARs, it is only mentioned in 47.16 as something for manufacturers and dealers to use. There's no manufacturer or dealer involved in my situation, just a maintenance shop. I'm wondering if the use that the shop proposes would also qualify. Any thoughts?

 

[wabower]

It's common to paint the new number on the plane and cover it with a decal of the old number while awaiting changes to clear FAA, or sale to close, or whatever.

Does anybody have experience with temporarily covering up a new N-Number on an old plane, while waiting for the FAA form 8050-64 for the new number?

Let's say my old registration number is N1111 and I reserved N2222. I then sent a request to the FAA to assign N2222 to the plane. But the FAA is slow, with a month-long backlog before they can send me the form 8050-64 that I must possess before N-Number can be officially changed. The shop says no problem, we'll peel off the old N1111 vinyl letters, put on the new N2222 vinyl letters, and immediately cover up the N2222 with a temporary sheet of low-tack white vinyl bearing the old number N1111. I can then fly the plane with my old registration and airworthiness certificates for N1111. The temporary number won't blow off in the wind, but it will come off easily when I'm ready -- once I receive the delayed form 8050-64.

I'm just wondering if this could lead to any trouble. The authority that the factories use with the non-permanent letters is 45.21:

(c) Aircraft nationality and registration marks must—
(1) Except as provided in paragraph (d) of this section, be painted on the aircraft or affixed by any other means insuring a similar degree of permanence;
(2) Have no ornamentation;
(3) Contrast in color with the background; and
(4) Be legible.
(d) The aircraft nationality and registration marks may be affixed to an aircraft with readily removable material if—
(1) It is intended for immediate delivery to a foreign purchaser;
(2) It is bearing a temporary registration number; or
(3) It is marked temporarily to meet the requirements of §45.22(c)(1) or §45.29(h) of this part, or both.
​

This situation doesn't qualify for (1) as there's no foreign purchaser, and not for (3) because that's just for putting big letters on a plane flying into the ADIZ. So how about (2), the temporary registration number?


I'm not sure how broad the term "temporary registration number" is. Among other FARs, it is only mentioned in 47.16 as something for manufacturers and dealers to use. There's no manufacturer or dealer involved in my situation, just a maintenance shop. I'm wondering if the use that the shop proposes would also qualify. Any thoughts?

 

[poadeleted20]

I'm with Wayne -- it's what you see, not what you can't see, that matters to the FAA. Just be ready to explain if some TSA or DEA officer who sees that the original number is covered starts to make something of it, because covered/changed numbers are one of the "clues" they use to identify possible drug runners and the like for further investigation. Having copies of your N-number change FAA paperwork in the plane might be helpful in defusing that situation.

 

[denverpilot]

I'm with Wayne -- it's what you see, not what you can't see, that matters to the FAA. Just be ready to explain if some TSA or DEA officer who sees that the original number is covered starts to make something of it, because covered/changed numbers are one of the "clues" they use to identify possible drug runners and the like for further investigation. Having copies of your N-number change FAA paperwork in the plane might be helpful in defusing that situation.

Also helps not to dress like Martha King, the aviation terrorist.

 

[poadeleted20]

Also helps not to dress like Martha King, the aviation terrorist.

Or like this:

 

[wabower]

A couple of fast-sign shops near KADS have become proficient at the airplane decal business and will ship them quickly. Let me know if you need help.

 

[denverpilot]

Or like this:

That wouldn't even garner a search... that's just a nice normal um... person.