76Srat

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 . . .

[this is too easy to resist]: I'm sure the landing is fine. Isn't the ensuing takeoff a bit more of a concern?

I couldn't care less about FLYING being a crappy read; I hate that they bought up the other excellent resources, bundled them together with FLYING (I forgot to add above that I abhor paying ~$80.00/yr for Aviation Consumer/IFR/Aviation Safety, each, thus the bundle makes perfect sense), yet have now dropped all of the titles except for FLYING. It's a shame. But I still read the daily paper in hard copy that gets delivered to my driveway at whatever time the paper carrier decides is the proper time, sometimes (usually) a full day late anyway. But I digress . . .

FLYING has p*ssed me off for the last time. I renew every year and have since the 1980s, but also have steadily watched this great mark go down quicker than the Hindenburg. They took my bulk renewal for all 5 of their titles and removed all of them except the worst one--FLYING--without any notice but certainly with what is quickly becoming maliceaforethought. The only reason I bulk-renew every year is to get the very excellent "IFR" and "Aviation Safety" and I even found usefullness in "Aviation Consumer". Now all of those have been dropped and rolled up into the occassional single-article published in the mothership rag (FLYING). Kudos to Firecrown Media Resources (or whatever they call themselves) for taking an historically great magazine and a subset of excellent resources and dumbing them down to the basic, miniscule worthlessness that it is now, and trashing the long-standing community that soaked up all that their other excellent titles provided. Sorry to any FLYING fans out there who might be offended, but FLYING is now about as useful as an oil change shop specializing in Tesla oil changes. They've taken the equivalent of glass cockpits and removed everything but the whiskey compass (which is offensive to all whisky compasses out there). Now for the real kicker: I got an email this afternoon (in my spam folder, appropriately) asking me to "lock in my lowest renewal rate before any increases". Increasing subscription rates and decreasing content, quality and literally everything else that such a publication ever offered? Sounds about right. No thanks, FLYING. I'll be tossing your renewal offer in the bin from here on out. Just like my decades-long subscription to FLYING et al, this rant is over . . .

The wager you're pondering, and evidently looking for affirmation here, is that you'd like to: 1. Train for and obtain your PPL; 2. You'd like to do so in as complex/high-performance plane as possible; 3. You'd like to offset most, if not all expenses related to same. Well, at the risk of sounding fatherly (sorry, I suppose I am), you can't have all of those delicious morsels of cake and eat them, too. Here's why: just like any decision worth contemplating, and aside from costs themselves, buying a plane is a negotiation of range, speed and payload (meaning if you want a plane that goes further, you're likely not going to be able to carry as much; if you want a plane that goes faster, you're likely not going to be able to go further; and if you want to farther, you won't be able to go faster). This is why Mooneys are special in the marketplace (bias alert). Plane ownership really is Goldilocks. You can't sleep in all three beds or eat all three bowls of porridge at the same time--one will be "just right", for you. For us here, Mooneys scratch all of those itches in very special ways. Now, to focus on your idea to train for your PPL, congratulations. I echo the vast majority opinion here to say do that at your favorite local flight school (61 or 141) and enjoy the process. You'll be far more better off, as will the world of pilots, if you focus more on finding a CFI that you jive with and that jives with you instead of worrying about finding the right Mooney just for you to train in. Second, there are basic stick and rudder skills that you don't have until you have them. Focus more on nailing those, as opposed to learning from the start just "how to be a good complex, high-performance pilot". Stick and rudder, airspeed and airmanship are all vastly more important than becoming a competent pilot of high performance aircraft, which comes later The "cart" here is your pilot skills; the "horse" is training to become one, not the other way around. To paraphrase a prior post response: You'd never dream of putting a 15 year old student driver behind the wheel of a Formula One car, or even a WEC Porsche GT3RS. It just isn't smart. Has that been done before? Of course, but at last recollection, there aren't a lot of Sebastian Vettels or Max Verstappens out there (both piloted F1 cars to great success before they could legally drive on public roads in Europe; and each are now 4-time Drivers World Champions, but I digress). Third, in your effort to offset expenses and make it bit more palatable to your pocketbook, why couldn't you do that with a proper C172 or other capable trainer aircraft? The idea is a decent one, but you also need to understand how to manage that entire process and account for it. The fact that your AI question-creator generated the question the way it did leads me to believe that you're not opposed to hiring someone to do that for you, which is the only way to ensure its done correctly (unless you possess more skill in that department than you've disclosed here). Finally, you need to decide to pursue initial training properly, which likely will not coincide with your owning and training in a high performance, complex bird. Most folks need to acquire alot more skills that are vastly more important to the goals you've established for yourself. At the risk of being a fatalist, you will end up achieving a result, without question. The real concern for you should be which result do you want to achieve?

. . . but damn ain't that fancy air conditioned Boeing village at AirVenture nice? Let's hope they keep that for us at least one more year. It's always fun and nice to duck in there for a cool rest, once in a while. I'm also a huge fan of Boeing actually sponsoring the youth-get-in-free movement for anyone under 18 being allowed in to AirVenture for free (with a paid, ticketed adult). Don't get me started on why EAA doesn't just cover this anyway, but I digress . . .

I've enjoyed all of the info on this thread, for sure. What's funny to me is that literally none of the FF issue is vital to being able to actually fly. Am I blown away by FF and all of the EFB stuff out there? Absolutely and my two-pilot household subscribes to literally every option of such out there. That said, my teenage pilot son has never flown without any of them, ever. Me? I literally never flew with any of them until he started flying three years ago. To me, six-packs were of the baby-seal-endangering plastic ring holder thingies and round dials in a panel. To him? Only the former. Back to the OP: Boeing off-selling FF and its entire digital asset portfolio (save for that related strictly to its monitoring and airframe maintenance programs themselves) is merely the result of a board room decision and the ~14BB write-down of its core business these past few quarters. It has nothing to do with the actual value/profits/losses/core value of the digital assets themselves to Boeing's bottom line. Akin to GE Aerospace doing what it (rightly) did a few short years ago: off-selling its finance and maintenance businesses to separate units. That's all Boeing are doing here. At its core, Boeing owning anything related to EFB makes zero sense, and I argue has never made any sense. Boeing has no interest in what happens in the mind of the pilot. Its an airframer on the civil side, pure and simple. Its larger business is that of government contractor, but that's the subject of for a different day. Bottom line to me: FF and all of its kindred in the marketplace has not just been a true game-changer for how we fly our planes, it is a totally new universe that is as exciting as the actual universe way up there. Is it required for us to actually fly? Absolutely not. If we're not in favor of the next best PE group buying it up, then we can always speak with our wallets and not engage in any of it. But guess what will happen when we do that? You guessed it: absolulely nothing. As the debacle that is the debate over EAGLE/UL100, etc., we as a general aviation lobby simply don't matter for squat when it comes to what will actually happen to that which we use while flying. Same is the inevitable case for what will happen with FF, etc.

Great article, Don. I echo the expectation that it'll take regulatory agency help in softening a few of the key sticking points on certification processes, etc., especially those related to the sheer expense directly related to getting new powerplants to market that can be drop-in replacements for legacy piston-powered airplanes. The reason why those are so expensive is because of the obvious: the OEMs return on investment. As to why the factory OH route is so expensive is a mystery to me because legacy certified powerplants were monetised decades ago by the OEMs. I think its merely a marketplace commodity factor and nothing else, which will not be sustained long-term. It'll take agency and private industry partnerships to make anything sustainable happen (much like we now see taking shape nicely on the avionics side). Until then, we should be planning on spaces in the mausoleum of legacy piston airplane boneyards . . .

All good stuff here, guys. I've said it before and I'll keep saying it: Is this reality? Yes, it is the new reality. Therefore, are we still going to be staring at the top of our boots in the next 20 year timeframe and lamenting the extinction of our legacy piston fleet? And I'm including all legacy pistons in that assumption, not just our beloved Mooneys. Unless there is a drastic and universal change in equipment being available to the legacy piston fleet, it will no longer exist as we know and love it. Period. I argue that we should stop expecting the factory/field OH market to somehow come back to earth and show us a welcome "correction" as to what all of that costs. What has never been controversial or refutable is how one owner chooses to undertake such a project. As we've all discussed above in this very topic, each owner/operator is different than the next. Some might choose to overhaul/replace literally everything from the firewall-forward. Others choose to do such on an as-needed or for-cause basis. Its Ford vs Chevy at that point and that's been the prerogative since airplanes went to maintenance for the very first time ever. That will never change. What does need to change, and I argue what must change, is what we expect to happen if we stay the course and simple expect the certified piston engine marketplace to somehow all of a sudden be transformed into something we think we can all live with. Bluntly, it won't. Without new technology on the power plant side for the certified legacy piston fleet, this is a race to the bottom with only one possible result: extinction. There is no help from the newly-certified crowd (read: Cirrus et al), nor is there any help from the regulatory agencies themselves (FAA/EASA et al). Instead of lamenting and wishing for short-term solutions (which are anything but "short-term" in their pursuit) such as UL100 or other band-aid so-called solutions for existing piston power plants, we should be lobbying for and arguing in favor of replacement power plants themselves (small turbines/diesel-derivatives, etc.). This may sound like crazy talk and will be crazy-expensive, but it truly is the only way out of this mire and mess, if we truly want to save our legacy piston fleets. Where would the piston fleet be if there were no investment or tech which replaced our beloved steamguages a few decades ago? Look at what Dynon and Garmin have done for that? Could and should there be the same type of focus for the powerplant side? I argue not only should there be; there must be. Otherwise, our legacy pistons will be seen by our grandchildren in the occassional static display museums, which will be few and far between. I'll pop some popcorn and now watch the wailing and gnashing of teeth over this thought . . .

Correct that military aircraft weren't issued civilian registrations, though many civilian aircraft were used militarily (L-birds being the easiest to mention). And to clarify my earlier statement, the CAA would issue successive numbers to each manufacturer, so for example Taylorcraft would have its allotted numbers, as would Cessna/Beech/Piper, etc. So your C140 being a couple of numbers away from your neighbor's likely would have rolled out of Wichita one or two ships away from his. Either way, the earliest of registration numbers (N numbers, for the US) were successive and not vanity or custom like we can do today.

Also curious to see how the Registry will be able to reconcile this with its own regulations governing the requirements of the registration of Aircraft generally (49 USC 44101 et seq; and 14 CFR 47 and 49). In classic form, one reg requires that the FAA provide for methods of keeping your information private, but doesn't say how or where that information is otherwise supposed to be accessible, as required by the very regs that establish the Registry in the first place. You may not think this makes a hill of beans difference and that privacy is the key component here. It isn't and it makes a helluva a hill of beans difference. The very reason for Registry records in the first place is (was) to equip the enforcement agencies with the ability to find out who owns an airplane operated in US airspace***. Circa 1999, our friends at the Aeronautical Center Counsel's office in OKC issued a letter (just a letter, not a "ruling" or "regulation", but a guidance "letter" to all Registry examiners) requiring that "physical addresses be included in all 8050-1 forms filed with the Registry". How's that sit with you? Why should we have to comply with that? Nowhere in the then-regs did it require that your physical address be included in your documents filed in OKC anytime you wished to register your ownership of an aircraft once you bought it. FAA Registry documents examiners began immediately rejecting ownership and registration documents filed that didn't comply with that unpublished requirement. Perhaps some of us on here experienced this joy, which also caused some of us to operate unknowingly in violation of Registration requirements if such flights occurred beyond the 90 day "temporary" (pink copy) registration carried on board without having had the final registration card issued in the interim. Anyway, when queried about this craziness, the answer was twofold: "the FAA has been instructed by DOT and Treasury and Dept of State to require the physical location of where each US registered aircraft is to be based" and second, "the FAA has an interest in maintaining safe flight operations of all aircraft operated in US airspace". What??? Seriously, those were the answers. In reality, when pushed further on the topic and at multiple seminars following this silly unpublished change in the regs, ACC finally admitted it was so drug trafficking could be tracked more accurately and then it became a firm requirement once the disaster that was 9/11 happened. Thus, we've been required to show a physical address ever since. So guess what this triggered? Yes, you guess correctly: my aircraft is "physically located" at my hangar and I don't receive mail or notices at my hangar, because, well, my hangar doesn't have a f*cking address. The FAA hadn't thought of that. Remember the most recent debacle about requiring the "re-registration" of the triennial registration requirements? All of that was birthed by the ignorance of the FAA's own regulations about providing a proper address for registration purposes. The "physical location" of the aircraft requirement caused the removal of thousands of actual mailing addresses for FAA notices and manufacturer notices to reach the aircraft-owning pilot community. It's taken decades since to resolve. All of this to say that you may not think that what goes on at the FAA Civil Aircraft Registry affects you nearly as often as what goes on at Aeromedical, but it does. I argue it likely affects us more because the Registry records are one of the easiest ways to commit fraud using aircraft records. They're all there to see, as you wish. All of your financial data found in your loan documents on that fancy Mooney you just bought are in those FAA Registry records. Hopefully you used a proper aircraft title company in OKC and a proper aircraft lender who knows what not to include in those filings, but if you didn't, your info is there for all to see and the bad guys to exploit. Finally, think about this: next time you do a pre-buy and make an offer on a plane to purchase and you run a title search (which you should, always), how does availing oneself of these new privacy regs hurt your due diligence on important matters such as who owns the aircraft and, more importantly, who holds a valid encumbrance against that collateral? This reg is so vague and useless by its language and text that it will yet again open Pandora's box on more craziness that was never intended. Think that you'll always be able to review the records on a plane you're looking at, like we all could in the old days? Maybe and likely not, going forward. Welcome to FAA Registry Operations in the new age . . . ***Fun fact: ever wonder about those really old tail numbers you see in those really old photos, or perhaps even on the tail of some classic aircraft today, e.g. "N31178" on the tail of a 1940 Piper J-3? In the pre-DOT/pre-Civil Aircraft Registry days, circa 1958 and prior, the manufacturers assigned successive N numbers to the aircraft rolling out of their factories, which generally coincided with when that particular aircraft was registered with the Dept of War (the predecessor of our friendly, modern FAA Registry). Aside from a few exceptions through the decades, next time you're strolling the vintage ramp at Airventure, which everyone should do every year, you can safely assume that those airplanes bearing those old numbers were the "x" aircraft ever built in the US. So in 1940, N31178 (a 1940 J-3) was presumably the thirty-one thousandth and change airplane ever manufactured in the US. Seeing that there are now ~600,000+ US registered aircraft operating daily and airworthy currently (with legion more than that manufactured throughout history), I've always thought its rather cool to see an old aircraft with an old NC tail number.

This is perfect--what a great bit of advice. Thanks for supplying this and sharing your process. I still think it sucks that we have to establish multiple online accounts with the FAA (using different interfaces and even different vendors supplying the services to the FAA), just to apply for a medical or inquire/establish something with the Registry. CAMI and Civil Aircraft Registry buildings are merely a few yards away from each other in OKC. Why they don't use the same online portal will forever baffle me.

Only thing missing there, @EricJ would have been the Brady Bunch on their exciting vacation to the Grand Canyon or Uncle Jesse and Old No. 7 . . .

This I do know: donuts (and several boxes of them, and don't forget to add the apple fritters) work really well for the FBO line guys and those Little Caesars hot-n-ready $6.00 pizzas work great in the shop working on your airplane. These two small, relatively inexpensive gestures go a long way toward keeping everyone on the same wavelength. We're all human and we all make mistakes, all the time. Anyone not willing to admit this or agree with this won't be getting donuts or pizzas from me anytime soon.

^^^+1000 for @Parker_Woodruff and his attention to customer service and timely responses, etc. Just wrote a renewal with Parker yesterday and already referred a longtime pilot buddy to him who didn't know any better. Way to go, Parker.

I know, I know. I cringed right after I posted that. I was (stupidly) trying to think like an installer and forgot its as simple as designating which is which. My bad for overlooking a simplicity amidst what is usually Medusa's headdress of compliance BS.

Indeed yours is an interesting perspective, but what the ruling actually clarifies isn't the leaded versus unleaded avgas issue--it was a clear and unequivocal ruling that agencies (in this case, a county) cannot unduly deprive rightful access to something federally mandated otherwise. It just so happens that this case involves 100LL and 100UL of various types (such as they are). Unfortunately, all of aviation is on a downhill slide on this issue and literally every other issue taken up by those opposed to anyone exercising their freedom to fly. If we're truly supportive of GA overall, and I believe all of us on here are, then we need to come together and let the market bear out what should or shouldn't be available. To do anything less than that is to remain unwilling subjects to bureaucrats who truly do not have GA's best interests in mind. In fact, they have the opposite in mind: absolute abolishment. If all we do is sit back and expect to turn our heads and cough when told, then we shouldn't even expect a soft, gentle hand when asked to do so.

Interesting theory, PC. I'd be curious, however, to see how many annuals would get that wiring setup squawked by an IA for not being "i/a/w certification", etc. I could see several not signing off on that setup unless there's an approved published alternative in the installation process. Just thinking out loud here . . .

@mhoffman Just lurking to see if you have an update on this? Has to have been maddening for something like this in-flight, compounded by the fact that the remedy is replacing the gear motor. We'd love to hear how your quest to replace that went/is going. Hopefully getting one reasonably is a bit easier than milking the truth out of a politician . . .

I hear you, Mr. Cone. My take on his diatribe is less about all GA pilots being wrong about it, and more about being wrong about overlooking establishing habits that focus on maneuvering speed versus religiously and rotely (is that a word?) going for glide speed in engine-out situations, instead of perhaps better options that give you more airspeed options (such as the aforementioned maneuvering speed instead of best-glide). Quick side story: My son is going through his PPL training now as a 16 year old and has been doing so since age 15 at my buddy's local 141 and he won't even be able to take his check ride until this summer when he turns 17 (I know; cue the "why are you doing that" questions). I occasionally go up with him and his instructor and I just watch and listen. I'm amazed at what they're doing now in 141 curriculum versus the part 65 when I did mine back some 7 presidential administrations ago. To my shock and dismay, there isn't a standard "engine-out" curriculum in the C172S 141 syllabus. Instead, there are all kinds of "engine out recovery" situations. Now I'm not here to debate the ills or extol the virtues of these many stair-stepped syllabus steps to learning emergency recoveries in a 141 environment--they all have their pros and cons. What does make we amazed and astonished is how rote and routine they try to make all of them. To me, there doesn't seem to be much thought or questions around why they do them or whether there are better ways to react and recall how to recover--it's literally become a check-the-box learning and achievement environment. Case in point: in the "engine fire in-cruise recovery" portion, guess what the very first requirement is? "Turn the aircraft toward the direction of the engine fire". Seriously? That's the stupidest thing I've ever heard. How about establishing where you're going to put the aircraft down safely, first? If one stops long enough to think about the recovery steps in that situation, shouldn't we ask "how on God's green earth, or more accurately, how in God's blue sky are we supposed to determine 'which side the engine fire is coming from'? If you're supposed to "turn in the direction of the engine fire", shouldn't you be able to figure out which side of the cowl it's coming from first? So please tell me, even at C172S cruise speeds of ~110kt, give or take, how are you doing to determine where the flames/smoke are? You can't. Ram air physically prevents it. So what good does that kind of recovery training teach a learning pilot-to-be? I detailed all of this with my son afterward and he hadn't even thought about it that way. Most, if not all such student never would think of it that way because it isn't "in the syllabus", so they aren't supposed to think of it that way. All of that sidebar to say that as long as videos and other elements of learning that are logical and get us to actually think about an emergency situation logically, we'll all arrive safely at our destination, whether such destination is planned or unplanned. After all, that's always our ultimate goal of flying: make sure our number of landings equals our number of takeoffs, period.

Haha. Thanks for the heads-up. Have no idea who he is other than someone IMHO who's doing his best to offer yet another way to fly as safely and as competently as possible. After 40+ years in GA and transport-category aviation in one for or another (but never as a CFI, btw), I hope I've learned the most valuable lesson of all: never stop learning. Hell, I can learn a lot from a bartender, even if I don't like his or her ultimate cocktail in my glass. I can and will always be learning, all the time. Reminds me the rare time my wife was with me at our local FBO years ago in the late '90s. She asked me "does that happen often out here??" after watching our local village (airport) idiot literally ramrod his homebuilt at about a 50kt rolling high-speed turn onto the runway, midfield, and take off. My reply: "not for very long and not very many times in a row". As fate would have it, that same idiot killed himself and 6 other innocent souls (yes, 7 total) when he attempted to takeoff in high DA in a summertime, over-gross Aerostar flight. While that story has nothing to do with the Dan Gryder video I posted above, it has everything to do with my lifelong obsession with being the best pilot I can be: never stop learning and always keep your options open, no matter the situation. That village idiot locked the door on learning years prior to his death and doing so ultimately did him in. The sadness of all of that is less about losing an idiot from the pilot corps and all about losing the 6 others (all from the same family) who had no idea he was such a f*****g idiot. The video is a great reminder that we can all learn from everyone else, both good and bad. I love the approach he shows on how to quickly and easily establish the most important part of any engine-out situation: quick awareness and reaction that gives you options. If we stall in that situation, all options are removed and there is likely only one inevitable result: your family, assuming they're not in the plane with you when it happens, will not be dining at the same table as you that evening. I never want that . . .