76Srat

Makes me miss the good 'ol MAPA Log days and @jgarrison Jimmy's monthly Mooney market reports . . . With that said, I also look profusely at the market and take the Romanian and French Olympic diving judge approach, as in "throw out the highest and lowest" and then you arrive somewhere close to what each model should be trading at. But doing so doesn't mean I don't laugh every time I see a '64 M20C listed at $175K . . .

There are two words to solve all of this: Airspeed. Airspeed. Oh, and a third word goes with those two quite nicely: Airspeed.

Just got my copy and haven't put it down yet--amazing read. If you like stories like Stephen Coonts's Cannibal Queen (another phenomenal read; unfortunately out of print), you'll LOVE this book. The shortest summary possible: Egan (longtime Road & Track contributor and huge car, motorcycle and aircraft guy) and his wife took a country-wide trip in their J3 Cub and he wrote about their adventures. Here's a link to obtain your very own hardcopy or Kindle version: https://www.amazon.com/Landings-America-People-Summer-Piper/dp/1642341894/ref=sr_1_1?crid=3F9J2YCXV9QBV&dib=eyJ2IjoiMSJ9.MDODCHmI_wPCG1qntMHUucpgQGCrCt1ENu5TU8eM9lBsrZKhSY2X1o5Y6t3Id-zIL995ZcXImq6DBkzBeZQj86S6VFRMDbsgaAfefWxZY2AlOru4bqmZ90SxuAEj3qi3dLA540k_b1Q_TBP12sDchki_uYntMTUYIZx9YAFNVpahR4kiMcZHtjHXI-o04GJmYhpYkdKhM7QUV9F4i3nCuOp1klK5tytWxxjb7mdeh80.oM0eeskKgf3vq2-foGJFQS6b7BhuvV6TBzNoDjT0v2Y&dib_tag=se&keywords=peter+egan&qid=1756914317&sprefix=peter+egan%2Caps%2C144&sr=8-1

Not throwing rocks at all on the Mooney Summit process of how selecting the location(s) works every time. I know there are hundreds of considerations that go in to planning and putting something like that on--we're all grateful for all of that. That said, it would be great to see those decisions focus more toward more GA-friendly airports and locales. At the risk of sounding completely cynical, most airports in larger metro areas have zero interest in supporting anything involving piston and/or GA operations. I know holding the Summit in Tampa is far more glamorous and attractive than say, Ogala, Nebraska, but why do it at an antagonistic place? Thanks for posting your PSA--when policies don't match up to reality, we should move on.

Shhhhh . . . don't tell Cirrus. They'll ban its use in their aircraft immediately, for "not compliant with the STC" . . .

Thanks for your service--we all owe you a debt of thanks and gratitude for what you've done in your day job--way to go, man. First, give @parkerwoodruff a shout. He's our very own resident insurance expert (and a dandy one, at that). Second, apologies for some of the "picking fly sh*t out of the pepper shaker" talk on here about the benefits of this Cessna over this Piper over this M20C over this M20xx or whatever. We all have the best of intentions but sometimes we let the fog created from our own mouths cover up those huge building cumulonimbus building up in the flightpath ahead--you said you'd also like to use the aircraft for some charity work. A longbody Mooney will be perfect for that, too. I love the J3 and all family of Cubs, etc., but those aren't going to work for anything other than a Young Eagles flight at the local EAA Chapter meeting. Finally, I can't recall if you said where exactly your wife is on her 141 journey, but if she also needs to add her instrument rating via the 141 path (which I highly recommend due to the waivers enabled on that track), then make sure that particular school allows IFR training on the 141 program in your own aircraft--some do not. It would be terrible to find out that you/she cannot use your new-to-you Mooney for that purpose. Just a thought . . . Anyway, welcome aboard and enjoy your new adventure. Get the Mooney and love every minute of it. If saving .05 cents per gallon is your main concern, then subscribe to every possible aviation rag out there and merely dream about flying for real. Not trying to minimize anyone's concerns about flying expenses, etc., but let's face it: none of this is cheap and trying to do this great hobby in the cheapest way possible usually doesn't work out well in the end.

From her superb flying skills to the beyond-professional editing, there's so much good here. This is the standard against which I will compare all other GA flying clips on YT. Wow. Enjoy. PS--a total mystery to me why she doesn't have thousands of subscribers by now. Let's change that.

I can attest and verify that your experience(s) with the morass that is the FAA medical process/Med"Express" is not your fault. It is solely and squarely the fault of the FAA in OKC. Here's a direct quote of a very high up at CAMI OKC on the delays related to all processing of all FAA medical applications: " . . . lack of overtime possibilities, DRP departures and influx of thousands of ATC applicants". I know this doesn't and shouldn't make any of us feel any better about this situation, but per Washington DC, all ATC applicants get priority over any other AME/Med"Express"/medical applications because of the optics and politics of it all. Combine that with the severe shortage of agency personnel who process such applications and we have the nastiness that we all encounter when our applications are either denied or simply delayed without any further explanation. Here's a quick and dirty example of just how ridiculous this has become (I'm in the process of trying to assist a family friend with what I'm about to describe): A now-18 year old student pilot applied for a medical via Med"Express" when he was 16 and was denied because of an ADHD prescription written to him when he was . . . five (5) years old. His parents actually forgot they ever had such prescription written for him back then. The FAA denied his medical application, as a result (error number one). When they appealed, the FAA took 6 months to respond, which the FAA then required this family to fly their son from Tulsa to Washingon DC to see the FAA Flight Surgeon. They tried for over 6 months to get an appointment, only to be given the cold shoulder until one day in the throes of an icy January Friday and they had somehow, magically been given an appointment for the following Tuesday, in DC. They pull the kid out of school, book last minute flights and had their appointment. The doc there asked them why they were even seeing him, to which they replied, "we were told we had to do this, if our kid wants to get his medical reconsidered". The doc then asked, "reconsidered for what? Did he get denied because of this [the former ADHD 'scrip from 10 years prior]?" "yes". Doc's answer: "This is ridiculous. Your kid is fine and I'm approving this appeal right now." This was two years ago, by the way. Fast forward to this very day: Still in limbo in OKC. The Tulsa-based AME failed to send in the DC Flight Surgeon's paperwork approving this appeal. When the Tulsa AME did, OKC refused to even confirm receipt, citing (get this) "HPAA regulations prevent us from discussing this matter altogether". Recall that this kid was originally 16 when all of this started. He's now 18 and thus an adult, so his parents are now on the outside looking in, and the FAA regional office (Ft Worth) are giving them the ultimate taffy-pull bulls*t response. We finally received word back in May that "the file is on the desk of the agent in OKC working this matter and will be processed in queue in June". This still hasn't moved from where it was two years ago as of this evening. This isn't a post to throw anyone at the FAA under the bus, but truly what the f*ck?? This is insanity on its finest display. An applicant can be suicidal, and on meds to curtail same, and as long as they can attest to not being suicidal for at least two years prior to applying, the FAA will automatically approve that applicant's medical. But this kid, who truly wants to fly and fly for a long time, gets denied for something he was prescribed when he was 5 years old and never filled the 'scrip and never took the meds can't get his damned medical app approved or his appeal worked timely? Ridiculous. Beyond ridiculous.

I was also laughing at what must have been quite a sight by any onlookers watching her "ground work" when she's balancing on one of the mains each time. Can only imagine the hangar-flyers critiquing "all of those bounces", when in reality they were a masterwork of controlled inputs and great reasons for them.

Love the correlation between stability and control: the more stable, the less controllable; the less stable, the more controllable. Flying is logic and she nailed the example as simply as I've ever seen it or heard it. Thanks for sharing this. Subscribed immediately.

The biggest whiff by the OKC group's comments/suggestions submitted to FAA, in my view, is that there is zero mention of the ADS-B issues that have infected this entire matter. Granted the OKC group is solely concerned with and knowledgable about the ins and outs of the Civil Aircraft Registry and filing documents there, but they missed the most important issue of them all: the very FARs requiring compliance with ADS-B by the good guys is now enabling very bad actors. This is yet another classic example of FAA's zeal lagging behind the actual operations subject to the FARs. The other irony, to me, is these very same firms and companies in OKC are the ones who have succeeded in lobbying FAA to open up the digitization of the Civil Aircraft Records. So euphamistaclly, they've led the horses out of the barn and are now asking the FAA to put them back in. It doesn't work that way. Back in the day, not so long ago, all such records were microfiched and you literally had to be physically present in the Public Documents Room in OKC just to have access to and research them. Now, with a simple internet account, you have instant and unbridled (mostly) access to all such documents from anywhere in the world. I guess we're getting what we deserve when we try to expedite and digitize access to these records.

Only registered owners can block the info. As long as the properly authorized person on behalf of the LLC requests the block (officer or manager; preferrably whomever signed the 8050-1 on behalf of the LLC), and presuming the FAA Registry records reflect your LLC as the registered owner, your LLC should be good to make your request.

Apologies in advance, but here is an extensive response to the FAA's proposed rulemaking on this very topic from an unaffiliated consortium of all of the relevant players on the title company/law firm side of the business here in OKC. Sorry it's such a large document, but it is worth reading and I have a multitude of thoughts about this response that I'll post as we go about reviewing the many thoughts below: https://media.licdn.com/dms/document/media/v2/D561FAQHckw_ACQdhlQ/feedshare-document-pdf-analyzed/B56Zb.xp02HgAc-/0/1748031156864?e=1749686400&v=beta&t=-3zt_jW0opL3GidvbkQBXFSVIyxl3EJI_5lAi8xh04M AIRCRAFT TITLE LAWYER & TITLE COMPANY COALITION May 23, 2025 Docket Operations, M-30 U.S. Department of Transportation 1200 New Jersey Avenue SE, Room W12-140 West Building Ground Floor, Washington, DC 20590 Subject: Docket No. FAA–2025–0638 – Comments on Proposal to Withhold Certain Aircraft Registration Information from Public Dissemination To Whom It May Concern: We are writing in response to the Federal Aviation Administration’s (“FAA”) Request for Comment regarding the proposal to withhold certain aircraft registration information from public dissemination (Docket No. FAA–2025–0638). We appreciate the FAA’s efforts to enhance privacy protections for aircraft owners as mandated by Congress, and we welcome this opportunity to provide input. In doing so, we aim to support a balanced approach that protects “individual” privacy while preserving the access to information necessary for legal, commercial, and safety- related activities. The following comments summarize key concerns and offer recommendations, drawing on recent industry analyses and our professional experience in aviation law and finance. Introduction and Background Oklahoma City serves as a critical hub for the aviation industry, not only because it is home to the FAA Mike Monroney Aeronautical Center and the FAA Aircraft Registry, but also due to its well- established aviation legal and title community. The aviation legal and title community in Oklahoma City work together in what we refer to as the Aircraft Title Lawyer & Title Company Coalition (“ATLTCC”) (A representative list of law firms and companies of the ATLTCC is provided at the end of this comment; The ATLTCC is not a formal entity or association). The participating law firms and companies of ATLTCC play an essential role for an overwhelming majority of aircraft registered in the United States with the FAA Aircraft Registry. The participants use their expertise in the Federal Aviation Regulations (the “FARs”), the U.S. Transportation Code, and the Cape Town Convention and its Aviation Protocol (collectively the “Cape Town Convention”). Participants of the ATLTCC are recognized globally for their services to the aviation transaction industry and their counsel and professionalism, ensuring compliance with the FARs in aircraft transactions. Our specialized knowledge provides the aviation community and the FAA itself with accurate transactional documentation and trusted guidance. This work of the ATLTCC makes us an invaluable part of maintaining the integrity and efficiency of aircraft transactions worldwide. Our expertise allows us a unique perspective to present the following comments in response to your request. In the FAA Reauthorization Act of 2024, Congress added 49 U.S.C. § 44114(b), which requires the FAA to establish a procedure for “private aircraft owners or operators” to request their personally identifiable information (“PII”) be withheld from “broad dissemination or display ... including on a publicly available website of the FAA.” In accordance with this mandate, the FAA’s proposal would remove from its public-facing websites the following data for those who elect privacy protection: (A) the mailing or registration address of the owner; (B) the owner’s email address; (C) the owner’s telephone number; and (D) the name of the aircraft owner. This represents a significant change for the FAA Aircraft Registry, which has historically made such information openly available to support over 1 million public inquiries per month. It is important to note that although § 44114(b) allows “private aircraft owner(s) or operator(s)” to request the withholding of certain information, it narrowly identifies the specific PII information that may be withheld. § 44114(b)defines PII as: · the mailing address or registration address of an individual; · an electronic address (including an email address) of an individual; · the telephone number of an individual; · the names of the aircraft owner or operator, if the owner or operator is an individual. Despite the narrow list set forth in § 44114(b), the FAA’s Request for Comment makes unclear whether these PII categories of information might be removed for any registered owner, individual or entity. This calls for clarification whether the intent is to limit the new privacy protections to natural persons (as the term “private aircraft owner” implies, and which is clarified by the PII categories listed therein), or if the FAA intends to extend the privacy protections to all non-governmental owners, including but not limited to business entities, partnerships and trusts. Many in the industry believe the privacy concerns are most acute for individual owners, and a one-size-fits-all removal of owner information for every aircraft would have unintended consequences on transparency and commerce. Additionally, under longstanding public record practices in the United States, names and addresses generally, but especially for corporate entities, have never been treated as confidential information. Real estate ownership records, UCC filings for security interests, vessel registries, and corporate entity records all publicly disclose names and addresses as part of ensuring transparency and notice to third parties. The FAA Aircraft Registry, which is a fundamental public notice system for title and lien interests in aircraft, has historically aligned with these other public systems. Shielding identifying information for aircraft ownership might be helpful in some circumstances, but the industry has determined over the last few years that aircraft are tracked in many different ways, regardless of whether the ultimate owner’s information is reflected as the registered owner on the FAA website. Finally, the aircraft privacy issues are complex and must be balanced against other obligations and uses of the FAA Aircraft Registry. The FAA’s initiative is a positive development in that it invites stakeholders to weigh in on critical questions such as how often owner data is used, the impacts on privacy, safety, and commerce, and how best to implement the changes. In that spirit, we offer the following specific comments and recommendations to ensure the final outcome achieves the appropriate balance between privacy protection and necessary information access. Ensuring Access for Legal and Commercial Stakeholders Preserving Title and Liens Transparency: The FAA Aircraft Registry’s core purpose extends beyond registering aircraft for operational and safety purposes – it serves, together with the International Registry under the Cape Town Convention, as the central registry for ownership rights and security interests in aircraft. Parties file bills of sale, leases, and lien documents with the FAA Aircraft Registry to provide notice under 49 U.S.C. § 44107 to third parties and to perfect interests in aircraft. Unlike filings under the Uniform Commercial Code and other registries that allow simple notice of interest, the FAA is similar to a real estate registry where for over sixty (60) years the actual conveyances/documents have been filed and recorded with the FAA Aircraft Registry. All of these cumulative, historical records are available for examination and vital for every transaction in aircraft. It is imperative that buyers, sellers, lenders, lessees, law firms and title companies continue to have a reliable way to determine who owns an aircraft and what liens or claims exist on it. The U.S. Supreme Court has underscored this role, describing the FAA Aircraft Registry as “a central clearing house for recordation of titles” so that anyone can readily discover “claims against, or liens, or other legal interests in an aircraft.” Philko Aviation, Inc. v. Shacket, 462 U.S. 406, 411 (1983). Additionally, US courts have determined that parties are not simply deemed to be on notice of documents recorded with the FAA Aircraft Registry, but actual notice “under section 1403(c) includes not only knowledge that one's seller lacks good title but also knowledge of facts that would lead a reasonable person to inquire further into the seller's title.” Shacket v. Philko Aviation, Inc., 841 F.2d 166, 169 (7th Cir. 1988). Courts have also determined a document recorded with the FAA provides not only “constructive notice of its own existence and contents”, but also “gives rise to implied notice of such other facts as would be disclosed by duly prosecuted inquiries suggested by it.” McCausland v. Davis, 204 So. 2d 334 (Fla. Dist, Ct. App. 1967). It is therefore essential parties have access to the complete documents filed with the FAA Aircraft Registry. Although recording with the FAA is a prerequisite for perfection or possibly enforceability against third parties, it does not determine the underlying validity of a conveyance. Philko Aviation, Inc. v. Shacket, 462 U.S. 406, 411 (1983). In addition, 49 U.S.C. § 44103(c) confirms that “A certificate of registration issued under this section is not evidence of ownership of an aircraft in a proceeding in which ownership is or may be in issue.” A thorough examination of the FAA records relating to title and conveyances necessitates parties verify not only what documents have been recorded by the FAA Aircraft Registry in connection with an aircraft, but also a review of all the documents in the record along with the ancillary documents mandated under FARs Part 47 and Part 49. These ancillary documents contain powers of attorney, signature authority statements, trust agreements, court orders, merger documents and other records that must also be examined along with the recorded documents. It is essential to assess whether the recorded documents create valid interests, are properly executed, comply with the FARs, and refer to other rights or interests that warrant further investigation. If owner or operator names and contact details are broadly withheld without an alternative and convenient means for legitimate stakeholders to obtain that information, there is a risk of confusion and uncertainty in aircraft transactions. With over 300,000 aircraft on the FAA Aircraft Registry – collectively valued in the hundreds of billions of dollars – transparency in ownership and lien status is crucial for maintaining confidence in the validity of recorded interests. We urge the FAA to ensure that the new privacy measures do not erode the ability to quickly verify title and encumbrances in real time for the purpose of aircraft sales, financing, and leasing transactions. This may be achieved by continuing to provide complete access to the data for authorized users at the FAA Public Documents Room. Without such assurances, the well-intended privacy initiative could inadvertently disrupt essential commercial functions in the aviation industry. Impact on Safety and Maintenance: In addition to commerce, public availability of owner information has traditionally aided safety and operational needs. For example, maintenance providers, manufacturers, airports, or authorities may use the FAA Aircraft Registry data to contact owners about urgent safety bulletins, Airworthiness Directives, or other critical information. If owner contact data is removed from public view, the FAA should consider how those with safety and maintenance responsibilities can still timely reach aircraft owners when needed. While privacy is of importance, it should not come at the expense of being able to notify an owner of a safety issue with their aircraft. Specific Concerns and Recommendations Below we address specific issues raised by the proposal and offer recommendations to refine the privacy program. These points echo concerns voiced by industry experts and stakeholders in recent analyses of the FAA’s privacy initiative. Each item is critical to striking the right balance between protecting personal data and preserving the functional utility of the FAA Aircraft Registry. 1. Third-Party Assistance via CARES The FAA has indicated that private aircraft owners must submit privacy requests through the Civil Aviation Registry Electronic Services (“CARES”) system, likely by creating a CARES account and uploading a request form. Many owners rely on attorneys, trust companies, or title service companies to handle their registration matters. Will third-party agents such as those in the ATLTCC (e.g., attorneys, title companies, etc.) be able to create CARES accounts and submit privacy requests on behalf of their clients? We strongly encourage the FAA to allow authorized representatives to utilize CARES for their clients’ privacy requests. This could entail a mechanism for an owner to grant permission or a power-of-attorney to their chosen representative to create and maintain the CARES account. Allowing third-party facilitation will ensure that individuals who desire privacy of their PII can submit such a request at the time documents which require this information are being filed with the FAA Aircraft Registry. This would also help law firms and corporate service providers to efficiently manage privacy settings for multiple aircraft owners. Establishing a CARES account is very similar to the process utilized by the International Registry under the Cape Town Convention, and allowing third party administrators to establish and maintain the accounts has proven to be crucial to the industry for efficiently closing transactions. 2. Immediate Activation/Deactivation of Privacy Settings It is crucial that the privacy preference can be turned on or off without delay when circumstances change. For example, if an owner has opted to withhold their name but is now in the process of selling the aircraft, they may need to reveal their identity quickly so that a buyer, lender, or escrow agent can verify the chain of ownership. In the current proposal, it’s not clear how quickly the FAA Aircraft Registry would process a request to restore information to public view (or vice versa). We recommend that the FAA Aircraft Registry implement an immediate or near-real-time activation/deactivation capability via CARES. Ideally, an owner (or their agent) could log in and toggle privacy off before a pending transaction, and the FAA Aircraft Registry listing would update promptly. Likewise, after the transaction or whenever appropriate, the owner could reactivate the privacy settng. The ability to “lift” the privacy flag on short notice – even temporarily – will prevent delays in closings and ensure that privacy measures do not hinder time-sensitive deals. In practice, this might involve an automated update to the online registry database once a request is submitted, rather than waiting days or weeks for manual processing. The FAA should clarify this process. Speed and flexibility in managing privacy settings will greatly reduce potential commercial friction while still giving owners (past and present) control over their data exposure. 3. FAA Public Documents Room Access and Use of Data The Request for Comment suggests that information removal is specifically from FAA websites, implying that data might still be available for public review in the FAA’s Public Documents Room or via other non-web avenues. In line with this, it is essential that FAA-approved Public Documents Room Permittees (individuals and companies who have been vetted and granted access to the full FAA Aircraft Registry records) continue to have full access to owner names and contact information, even if such details are no longer visible on the public website. Furthermore, these Permittees must be allowed to disclose the pertinent owner information in their reports to third parties, such as title search reports, escrow closing reports, or lien status reports. If Permittee firms (who often serve as the researchers and intermediaries for aircraft buyers and financiers) could access the data but were prohibited from sharing it with their client who requested the search, their services will lose much of their utility. Such an outcome would defeat the purpose of having permittees. We urge the FAA to explicitly confirm that nothing in the privacy program will prevent FAA Public Documents Room Permittees from retrieving owner information and relaying it to parties with a legitimate need. These professionals are already trusted with sensitive information under existing agreements, and they play a key role in the aircraft title system. Preserving their ability to function will help balance privacy with commerce – the general public might not see an owner’s name on a website, but an interested buyer or lender can obtain a comprehensive title report through an authorized channel. This approach still limits broad public dissemination while ensuring that critical information flows through vetted, responsible parties. 4. Limiting Public Access to Authorized Parties Building on the above, we suggest the FAA consider implementation where the general public’s access to owner data is curtailed as required by the 2024 Reauthorization Act, from “publicly available websites,” but vetted and authorized parties have privileged access. This could mean that the FAA’s online lookup tools and downloadable databases simply omit or redact the personal data of owners who requested privacy, whereas those who have a bona fide need can obtain unredacted records by request or through a secure portal. In effect, the information would be withheld from “broad dissemination” (e.g. casual browsing or bulk public data), satisfying 49 U.S.C. § 44114(b), but it would not be absolutely secret. Instead, access would be tiered: open access for non-PII data, and controlled access for PII data. Such a system might involve expanding the role of the FAA Public Documents Room or creating a digital equivalent where users are required to register, agree to terms of use, and possibly demonstrate a permissible purpose to retrieve sensitive owner information. The FAA could limit this higher tier of access to the established Permittees (law firms, title companies, escrow agents, etc., that regularly use the FAA Aircraft Registry) and perhaps other categories of requestors such as owners themselves, lessees, or lienholders on an aircraft-by-aircraft basis. By limiting access to only vetted individuals and organizations, the FAA can greatly reduce the risk of misuse of personal data while still enabling legitimate stakeholders to get the information they need. This concept aligns with practices in other domains (for example, the Driver’s Privacy Protection Act limits motor vehicle record data to certain approved users). Implementing a similar vetted-access model for aircraft registration data would help strike an optimal balance between privacy and transparency. On October 31, 2024, the FAA announced the loss of access to certain documents filed with the FAA for notice purposes, generally known as Work in Process (“WIP”). The loss of WIP access serves as a clear example of the FAA’s recent shift toward a privacy-first approach, which has already begun to impact everyday functions of the FAA Aircraft Registry and the ability of the ATLTCC to close transactions in certain circumstances. As listed above, the vetted parties would be able to have privileged access to PII data. It would then be logical and consistent to restore access to WIP, ensuring a comprehensive view of the available data on the FAA Aircraft Registry, for the same reasons of commercial necessity discussed at length above. 5. Scope of Privacy Requests – Current and Prior Owners/Operators Clarity is needed on whether a privacy request, once granted, applies only to the current owner/operator of the aircraft or also to historical ownership data. The FAA notice focuses on withholding an aircraft owner’s information, presumably in the context of the current registered owner. However, many aircraft have been bought and sold multiple times; their records contain a chain of previous owners and operators. Some aircraft, for example, have dozens of prior individual owners in the historical records. (See example N669QS). Will individuals who owned or operated an aircraft in the past be able to request that their names be hidden in the historical records? And if a current owner who obtained privacy protection sells the aircraft, will that owner’s name remain suppressed in the records going forward? These scenarios have implications for the completeness and accuracy of the FAA Aircraft Registry from a historical perspective. Removing historical information from the FAA records would obscure aircraft ownership verification and make title research virtually impossible (e.g. a gap in the ownership chain if names are redacted, or fraud in selling aircraft never purchased/owned). Our recommendation is that the FAA define clearly the scope of a privacy request. In our view, privacy requests should apply to the current owner/operator record, and the FAA should not retroactively mask previous owner names or maintain privacy requests once title has passed to a new owner. If a prior owner is an individual with continuing privacy concerns (for example, someone who sold the aircraft recently), perhaps they could be given the option to request privacy from broad dissemination for the period they were listed as owner, with access only given to the Permittees noted above. But this must be weighed against the need to maintain a chain of title and verify ownership. We encourage the FAA to develop a policy that respects privacy without erasing essential historical data especially for title reporting and legal opinion purposes addressing the status of the FAA Aircraft Registry records. 6. Access for Parties with Current or Past Interests: It is important to allow access to relevant registration records for individuals or entities with a current or past interest in an aircraft, even if those records contain PII that is not publicly displayed. For example, a lender or lienholder listed on an aircraft should be able to obtain full details of the owner (current or any previous) to enforce their rights or to send required notices. Similarly, a co-owner, beneficiary of a trust, or past lessor/operator might have a legitimate need to retrieve documents from the FAA record that include names and addresses. The new privacy procedures should accommodate such needs. This could be achieved by a verification process: e.g., if someone is listed on a document (such as a lien or lease) in the aircraft’s file, they could, upon proof of identity, request the file or view the records in the FAA Public Documents Room even if the owner’s name is otherwise suppressed online. We recommend the FAA explicitly allow owners, operators, lessors, lessees, lenders, lienholders, and other interest holders – both current and former – to access all registration documents pertaining to aircraft. 7. Transparency and Acknowledgment of Public Record: As a procedural safeguard, the FAA should consider requiring any party submittng documents to the FAA Aircraft Registry (such as registration applications, bills of sale, or security agreements) acknowledge that submitted information, including PII, will become part of the public record. Today, many owners and signatories may not fully realize that when they file a document with the FAA, their name, address, and signature could be viewable by anyone. An explicit acknowledgment (for instance, a checkbox on a form or an advisory in the filing instructions) would serve to inform filers of the public nature of the FAA Aircraft Registry. Importantly, this would also highlight the availability of the new privacy option – filers should be made aware that if they are a private individual and have concerns about their personal information, they have the right to request confidentiality under the new system. This step does not change any legal rights but promotes transparency and informed consent. In essence, if one chooses to register an aircraft or record a document, one should do so with the understanding that certain details will be accessible to the public, or at minimum to authorized searchers. 8. Clarification of “Private Aircraft Owner or Operator” The FAA should clarify the intended scope of the term "private aircraft owner or operator" under the proposed privacy framework. Specifically, we ask the FAA to confirm whether eligibility for privacy protections is determined based on the type or model of the aircraft, or based on the operational use of the aircraft (i.e., whether it is operated under Part 91, Part 135, or Part 121 of the FARs). Many aircraft are operated primarily under Part 91 for private use but may also conduct limited operations under Part 135 (on-demand charter). Others may transition between private and commercial use over their lifespan. We seek clarification whether an aircraft used part-time under Part 135 remains eligible for privacy protections, and whether aircraft operated exclusively under Part 121 (scheduled airline service) are categorically excluded from the privacy program. Clear guidance on whether "private" refers to aircraft use, operational certification, or both, will be critical to ensuring consistent application of privacy protections across the aviation industry. 9. Proof of "Operator" Status Additionally, the FAA should clarify what documentation or evidence will be required to demonstrate "operator" status for purposes of requesting privacy protections. Many aircraft are operated by parties other than the registered owner, such as lessees, management companies, or beneficial owners under trusts. It would be helpful for the FAA to specify acceptable forms of proof — such as lease agreements, management contracts, or operator declarations — that would allow non-owner operators to request protection of their PII. Providing clear guidelines on how operator status is established will ensure consistency in the application of privacy rights and will avoid unnecessary confusion or delays. 10. Special Purpose Entities for Aircraft Ownership The FAA has issued numerous legal interpretations confirming a company formed solely to operate an aircraft, with no other business or purpose, is providing common carriage when carrying passengers or property and must conduct those flights under Part 121 or Part 135 of the FARs. See Legal Interpretation to James E. Cooling by Lorelei Peter, Assistant Chief Counsel for Regulations, AGC-200 (August 22, 2017 ); and Legal See Legal Interpretation to James W. Dymond, Esq. by Rebecca B. MacPherson, Assistant Chief Counsel Regulations Division, AGC-200 (March 9, 2007 ). Many owners don’t understand that a special purpose company is not restricted from owning an aircraft and registering the aircraft in its name at the FAA Aircraft Registry; only the operation of the aircraft out of the special purpose company is prohibited under 14 CFR Part 91. The FAA need only clarify to an applicant for registration that ownership of an aircraft in a special purpose entity is acceptable so long as to the special purpose company does not operate the aircraft. This would allow any individual aircraft owner wanting to protect PII from public view to set up a special purpose entity with a name, mailing address, e-mail address and telephone number associated with that entity, rather than the individual’s personal information. The use of special purpose entities is not a novel concept as it is a common practice in real property ownership and is already used by many aircraft owners. This practice prevents the prying or curious public from identifying the true owner of property and puts the responsibility of privacy on the individual and not on the government agency. This solution assumes of course that the FAA’s new policy would apply only to aircraft registered to individuals, as opposed to a corporation or LLC, which may fall under the FAA’s intended meaning if a “private aircraft owner”. Balancing Privacy with Necessary Information Access Through these comments, the recurring theme is the balance between privacy and transparency. We support the FAA’s initiative to give aircraft owners and operators more control over their personal data. In an era of increasing concerns about privacy, identity theft, and even personal safety (for example, high-profile individuals may not want their travel activities publicized via easily accessible tail number data), these measures are timely and responsive to Congress’s mandate. Protecting an owner’s name, address, and contact details from “broad dissemination” can enhance personal security and peace of mind, particularly for private individuals. At the same time, the FAA Aircraft Registry exists for important public-interest reasons. It is the backbone of our title and lien system for aircraft, and it supports safety, regulatory compliance, and commerce. The FAA itself recognizes that privacy measures must be weighed against the reasons that parties are required to submit information to the FAA Aircraft Registry in the first place. In crafting the final rule or policy, we urge the FAA to incorporate the safeguards discussed above so that we do not unintentionally impede maintenance of aircraft, performance of safety checks, due diligence in purchasing and financing, or law enforcement and national security checks. The good news is that these goals are not mutually exclusive. A well-designed system can shield sensitive data from public view while still making it available to those who truly need it (whether via owner consent, authorized request, or limited-access channels). Thank you for considering these comments. Sincerely, Aircraft Title Lawyer & Title Company Coalition McAfee & Taft A Professional Corporation 8th Floor, Two Leadership Square 211 N Robinson Ave, Oklahoma City, OK 73102 Gilchrist Aviation Law, P.C. 1200 NW 63rd Street, Suite 4000, Oklahoma City, OK 73116 Crowe & Dunlevy Braniff Building, 324 N. Robinson Ave, Suite 100, Oklahoma City, OK 73102 Daugherty Fowler Peregrin Haught & Jenson 5801 N. Broadway Ext., Suite 100, Oklahoma City, OK 73118 Lytle Soule & Felty 119 N Robinson Ave Suite 1200, Oklahoma City, OK 73102 AIC Title Service 6350 W. Reno Oklahoma City, OK 73127 U.S. Aircraft Titles Inc. 3600 S Moulton Dr. Oklahoma City, OK 73179 Dixie Aire Title Service Inc. 1220 Bell Dr, Newcastle, OK 73065 Insured Aircraft Title Service 21 East Main Street, Suite 100 Oklahoma City, OK 73104 King Aircraft Title, Inc. 14801 SW 65th St. Mustang, OK 73064 Aero-Space Reports 13320 N. MacArthur Blvd. Oklahoma City, OK 73142 AEROtitle 1200 Metropolitan Ave, Oklahoma City, OK 73108 Aviators Title and Escrow 1304 Camelot Drive Yukon, OK 73099 Elite Aircraft Title & Escrow LLC 10600 S. Pennsylvania Ave Suite, 16 #9042 Oklahoma City, OK 73170 Powell Aircraft Title Service 10005 S. Pennsylvania Ave. Suite A Oklahoma City, OK 73159 International Aircraft Title & Escrow Inc. 10007 S. Penn, Suite F Oklahoma City, OK 73159

Not trying to make light of emergency airspace issues such as the sad DCA debacle or any other mishaps (or worse) due to bad/mis-comms, but I can't recall any aircraft ever falling out of the sky just because control lost their comms or due to radio failure, especially for those on an instrument flight plan en route. Pilots, on the other hand, have often forgotten the number one rule of aviating . . . The media make this sound like the literal sky falls every time the screens go dark in the tower. The sky doesn't fall when that happens. As to the issue of FAA tech and upgrades/maintenance, etc., just imagine if the US Govt was in charge of healthcare versus private industry running it. Oh wait, that already exists: check out your local friendly VA health system versus your local friendly privately-operated hospital. You get what you pay for, which is where this is all heading anyway. I hated seeing the WSJ begin to advocate for privatising the control of US airspace and using Europe and Canada as the best case examples for doing so. Has anyone bothered reminding the WSJ just how few ops there are in Western Europe and Canada combined compared to US airspace? It doesn't even compare. GA will get screwed yet again because the only paying passengers on board to pass through that expense like the airlines do are those of us paying for the plane anyway. And if we think flying is expensive now, just wait until private equity gets involved in that. Ross Perot's huge sucking sound just got its second wind . . .

Haven't bothered with the article and likely won't, but my very first thought is what about constant shaft/direct drive horsepower? Moto engines require a gearbox. Will this one be direct-drive, constant shaft RPM? If so, how? If not, why not? I've been advocating for our collective belief as a group in alternative power supply for the entire legacy piston fleet instead of replacement UL avgas alternatives to existing fleet power sources. The former is the only way forward; the latter is dead-man walking, er flying. Love seeing new ideas in the marketplace, but piston moto engines isn't where my brain wants to go . . .