We hope this update finds you in good health and high spirits. We know many of our clients and colleagues have been impacted directly by COVID-19, and almost all have experienced professional disruptions. As the impacts of COVID-19 continue to be felt through the aviation industry, we want to update you with temporary changes to the FAA Civil Aircraft Registry’s procedures,
and how Gilchrist Aviation Law is working to
minimize disruptions to our clients. What are the changes? Effective as of March 18 at 9:30 a.m. CDT, the FAA Registry has closed the “filing window” in the Public Documents Room. Rather than filing documents in real time through the filing window under the ordinary procedure, the FAA has placed drop boxes near the Public Documents Room to allow the continued submission of documents to the Registry. Priority submissions, including imports, exports, and submissions needing a Temporary Certificate of Registration (“flywire”) will be collected by Registry staff hourly. Submissions which do not qualify for priority processing will be collected twice daily. If a closing consists only of digitally signed documents, and no document exceeds twenty pages, the FAA is temporarily allowing digital submission of those documents by Public Documents Room licensees, including Gilchrist Aviation Law. What is the impact? Due to the delay between delivering documents to the FAA for processing and the receipt of the documents by the FAA, we are not able to issue legal opinions immediately at or immediately following filing as we customarily do. To alleviate the uncertainty introduced by the Registry’s temporary procedures, we will provide a written confirmation of the time all documents were deposited with the FAA for processing. Once the deposited documents have been received by the FAA and we are able to verify the time of the FAA file stamp, we will then proceed to issue our filing legal opinion. We expect the delay between depositing documents and confirmation of their filing to range between several hours and one business day. We will know more as the FAA works out this new, temporary procedure. What to expect? As a result of the Registry collecting priority submissions hourly rather than immediately upon submission, together with additional delays introduced by the temporary procedure, we anticipate longer than usual wait times in receiving Temporary Certificates of Registration and export confirmation wires. As always, we vigorously monitor all priority submissions and provide updates on the Registry’s progress to our clients. Although the temporary procedures are impacting the amount of time it takes the Registry to issue an International Registry Entry Point Authorization Code, the timing of International Registry registrations made by Gilchrist Aviation Law will not be impacted. We have determined a procedure we are confident meets the requirements of the Cape Town Convention and U.S. law.
Questions? If you have questions about how these temporary procedures may impact a transaction, including temporary “pink copy” authority for domestic U.S. operations, please contact Jack Gilchrist (jgilchrist@gilchristaviation.com; 405-252-8811) or Chad Gilson (cgilson@gilchristaviation.com; 405-252-8880). We look forward to working with you through these unusual times, and wish you, your family and coworkers safety and good health.
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