FAA CARES: block ownership info on aircraft registry portal

[EricJ]

1 hour ago, N201MKTurbo said:

Was that over the Verde River?

Significantly west of the river.   I dug out the letter, and the description is:

1/2 mile East of Pima to 144th St North/South between Stagecoach Pass and Happy Valley Road. 

That includes the preserve area around Granite Mountain and Brown's Mountain, but also coincidentally includes Troon (a fairly wealthy neighborhood in North Scottsdale).    The request in the letter is to maintain 2000 ft AGL, which is generally not unreasonable.    Still, I'm sure they were using the ADS-B-out tail number and registration info to get the addy's to send the letters to.

 

[N201MKTurbo]

2 hours ago, EricJ said:

Significantly west of the river.   I dug out the letter, and the description is:

1/2 mile East of Pima to 144th St North/South between Stagecoach Pass and Happy Valley Road. 

That includes the preserve area around Granite Mountain and Brown's Mountain, but also coincidentally includes Troon (a fairly wealthy neighborhood in North Scottsdale).    The request in the letter is to maintain 2000 ft AGL, which is generally not unreasonable.    Still, I'm sure they were using the ADS-B-out tail number and registration info to get the addy's to send the letters to.

 

Was that for not disturbing the wildlife, or the wealthy?

I just looked that up. When flying from the south and going to DVT outside of the class B, you fly right through there.

[EricJ]

18 hours ago, N201MKTurbo said:

Was that for not disturbing the wildlife, or the wealthy?

Or the lawyers getting paid to send the letters? 

18 hours ago, N201MKTurbo said:

I just looked that up. When flying from the south and going to DVT outside of the class B, you fly right through there.

Yes, it's a convenient way around the bravo, so I think they were sending a lot of these letters out.   This was about six years ago, and I haven't heard of anyone getting one of these letters for a long time.   That was kind of still early days for mandatory ADS-B-out, too, but I don't know how else they would have been getting tail numbers to look up registrations.

[DCarlton]

I noticed yesterday that Flight Aware shows my registration expired.  The FAA Database shows it current.  I contacted Flightaware.  They said they couldn't do anything about it; they could only use the data pushed to them from the FAA.  Publishing your data is of concern; publishing bad data makes it a non-starter for me.  I'll likely opt out now too.

[Matthew P]

What gets me is that you can't run a person's license plate to get owner info but you can run an individual's Registration Number and get their info.

[Pritch]

Here in Humboldt County, on the North Coast of CA.  a company Named Vector Landing Fees Management teamed up with the county and use ADSB to charge a landing fee ($23.00) to pilots coming in for a visit.  Even if they only stopped for fuel (which is an outrageous price of $7.20 a gallon).  They have installed antennas at the local airports (4) so by going DARK you can save some $$$$$$.  There is a recent article in Flying Magazine By Meg Godlewski about this.  So follow the link and save https://www.faa.gov/pilots/ladd.

Pritch

[toto]

2 hours ago, Pritch said:

Here in Humboldt County, on the North Coast of CA.  a company Named Vector Landing Fees Management teamed up with the county and use ADSB to charge a landing fee ($23.00) to pilots coming in for a visit.  Even if they only stopped for fuel (which is an outrageous price of $7.20 a gallon).  They have installed antennas at the local airports (4) so by going DARK you can save some $$$$$$.  There is a recent article in Flying Magazine By Meg Godlewski about this.  So follow the link and save https://www.faa.gov/pilots/ladd.

Pritch

There’s a MS thread on Vector

https://mooneyspace.com/topic/50237-backlash-against-vector-airport-systems/

 

[Bolter]

48 minutes ago, Pritch said:

Here in Humboldt County, on the North Coast of CA.  a company Named Vector Landing Fees Management teamed up with the county and use ADSB to charge a landing fee ($23.00) to pilots coming in for a visit.  Even if they only stopped for fuel (which is an outrageous price of $7.20 a gallon).  They have installed antennas at the local airports (4) so by going DARK you can save some $$$$$$.  There is a recent article in Flying Magazine By Meg Godlewski about this.  So follow the link and save https://www.faa.gov/pilots/ladd.

Pritch

Which airport is charging $23 landing fees on Mooney-size GA? I landed at Murrary (KEUK) and Arcata (KACV) in 2024 without getting charged.  

Over the years, I have received Vector billing for SMO landing fees and last year a bill for overnight transient parking at Truckee.  Both were expected.  I would argue the the SMO landing fee was unjust in that it was implemented as part of their effort to close the airport, but it was published and I knew the bill would be coming.

-dan

[Pritch]

10 hours ago, Bolter said:

Which airport is charging $23 landing fees on Mooney-size GA? I landed at Murrary (KEUK) and Arcata (KACV) in 2024 without getting charged.  

Over the years, I have received Vector billing for SMO landing fees and last year a bill for overnight transient parking at Truckee.  Both were expected.  I would argue the the SMO landing fee was unjust in that it was implemented as part of their effort to close the airport, but it was published and I knew the bill would be coming.

-dan

They just started the first of April 2025.  Although the local pilot are exempt, we are trying t fight it and would encourage all pilots to write the Humboldt County Board of Supervisors about how wrong this is.

Pritch

[Bolter]

12 hours ago, Pritch said:

They just started the first of April 2025.  Although the local pilot are exempt, we are trying t fight it and would encourage all pilots to write the Humboldt County Board of Supervisors about how wrong this is.

Pritch

Considering the difference in service between airports, it is shocking that they apply one of the higher landing fees ($23) at all airports across the board.  Eureka is a small airport with nothing but a self serve pump, and ACV is multiple runways and a commercial terminal building.  Especially as a fuel stop, this removes the entire county from my planning.  

[Scott Ashton]

I submitted my letter to the FAA for blocking my registration when this thread started and I just checked the FAA website and my aircraft ownership information is now blocked, so it only took a few weeks for them to complete it.

 

[hammdo]

Not everywhere… like yours, mine was gone in most places, also in the FlightAware tracks but… Mine showed up here also…

-Don

 

[Scott Ashton]

2 hours ago, hammdo said:

Not everywhere… like yours, mine was gone in most places, also in the FlightAware tracks but… Mine showed up here also…

-Don

 

Yeah I’m sure flight aware is keeping a database now to cross reference their registration data for as long as they can….at least if someone (Vector) is just pulling a current database file from the FAA it won’t be there.   

[hammdo]

Here is a quick query from Google AI on my plane - I’m betting Vector uses some kind of AI too… we’ll need to see how this changes once FAA reg changes propagates…

[shawnd]

ChatGPT looks like is using FAA’s source and not revealing owner information.
 

I like the text surrounding it…

 

If the owner’s information is withheld, as permitted by law, you may consider submitting a formal request to the FAA for access to the aircraft’s registration records. This process may involve submitting a Freedom of Information Act (FOIA) request and paying any applicable fees. For more information on this process, visit the FAA’s Aircraft Registration Branch page.

Additionally, third-party websites like FlightAware and RegoSearch aggregate FAA data and may provide ownership information, unless it has been withheld.

Please note that accessing or using personal information obtained through these means should comply with all applicable privacy laws and regulations.

[hammdo]

I asked the google ai to forget the n number registered owner. Got the same note to also ask FAA…

-Don

[76Srat]

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 

 

[midlifeflyer]

10 hours ago, 76Srat said:

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

I was wondering about those issues.

[Paul Thomas]

Can I block my info if my airplane is in an LLC or is that only for people who personally own their aircrafts?

[76Srat]

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.  

[shawnd]

24 minutes ago, Paul Thomas said:

Can I block my info if my airplane is in an LLC or is that only for people who personally own their aircrafts?

@hammdo was able to restrict information on the FAA site for his LLC. FlightAware still shows city, state and the owner name but no address. Maybe this will change in the future.

[76Srat]

4 hours ago, midlifeflyer said:

I was wondering about those issues.

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.

[midlifeflyer]

2 hours ago, 76Srat said:

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 that depends on your definition of  "not so long ago."  Before the current CARES setup, one could order a CD of the registry records for $10. $20 if you needed them certified for court. Turn around wasn't too bad. I still have one from 2007 and I'm sure it's not the first one I ordered. 

I wouldn't expect a discussion of ADS-B privacy issues in a response from a group primarily interested in title analysis and clearing capability, (even though that group is the one that always had access because they were local). I think the two issues are separate. I know people who have no problem with people knowing they own an aircraft but have PIA accounts to munge their tail number and ADS-B signature to keep their travel secret. 

[Matthew P]

Should be NO different than Vehicles...you can't find information about a car's owner by their license plate and you shouldn't be able to find information about an aircraft owner by their registration number....you can't go to a gov't website and type in a person's last name to find out if they are a licensed driver and get their information but you can go to the FAA Database to find out about any pilot...the same reasons and concerns that led to the GP not having access through name or tag searches applies to aircraft owners...the ONLY ones that should have access to that information is the Gov't Agencies, but not John/Jane Q. Public or 3rd party vendors.

[EricJ]

5 hours ago, Matthew P said:

Should be NO different than Vehicles...you can't find information about a car's owner by their license plate and you shouldn't be able to find information about an aircraft owner by their registration number....you can't go to a gov't website and type in a person's last name to find out if they are a licensed driver and get their information but you can go to the FAA Database to find out about any pilot...the same reasons and concerns that led to the GP not having access through name or tag searches applies to aircraft owners...the ONLY ones that should have access to that information is the Gov't Agencies, but not John/Jane Q. Public or 3rd party vendors.

If you have a few bucks to hire a PI you can do most of those things.   Privacy is largely an illusion these days.