FAA Feedback: Four Important Pieces of Paper

The Four: The registration certificate, airworthiness certificate, operating manual or flight manual, and weight and balance information

March 1997 article from Aircraft Maintenance Technology

If you ask any GA pilots what kind of aircraft paperwork the FAA requires them to have to have in the aircraft prior to flight, they will automatically respond with the acronym ARROW, which until just recently stood for airworthiness certificate, registration certificate, radio station license, operating manual, and weight and balance.

Just when we had everybody trained for a fast and accurate pavlovian response, wouldn’t you know that another government agency, the Federal Communications Commission, would come along and drop the requirement to have a radio station license for all U.S. registered aircraft operating in the domestic U.S. airspace. The new FCC rule became effective on Dec. 12, 1996, and on that same day it destroyed our “ARROW” acronym.

So now the acronym specialist in the FAA headquarters is pulling out his hair trying to come up with another buzz word so future “four stripers” can remember their paperwork requirements. By the way, any suggestions that any of you might have on what the new acronym should be will be gratefully accepted. Please submit your suggestion to:

General Aviation Operations

Branch, AFS-800

Attention: John Wensel

800 Independence Ave., SW

Washington, D.C. 20593    

Since this kind of paperwork is important, I would now like to go over the four remaining pieces of paper and see how they apply to mechanics, repair stations, and air carrier maintenance departments.

Registration certificate

The registration certificate is the most important regulatory document in the aircraft. You heard me right. The registration certificate is No. 1, the first in line. Why? In accordance with international agreements, the FAA cannot issue an airworthiness certificate or issue an airworthiness directive against an aircraft unless that aircraft is registered in the United States and an N number is assigned and displayed on the aircraft.

I sense some disbelief. You argue that everybody knows the airworthiness certificate is the most important piece of paper because that document defines what airworthy is and sets the standards for it. You are absolutely right, but as important as the definition and standards are, that still does not make the airworthiness certificate No. 1. If you don’t believe me just read a standard airworthiness certificate. The very first block of the certificate calls out the nationality and registration number of the aircraft, so the aircraft must be registered first in order to get an airworthiness certificate. 

I can also beef up my argument by pointing to Block six of the airworthiness certificate where it lists the terms and conditions for the airworthiness certificate. In Block 6 it states that the certificate will remain in effect as long as the aircraft is registered in the United States. So I hope I have convinced you that the most important regulatory certificate of all the aircraft’s paperwork is the registration certificate.

So far we have established that the registration certificate is important, but how does it apply to mechanics? First, as a holder of a FAA mechanic’s certificate, you cannot legally approve or return to service any work that you have performed on a foreign-registered aircraft. The FAA, by international law, can only grant privileges and limitations to certificate holders that work on N-numbered registered aircraft.

I am well aware that owners of foreign aircraft like to get work done in the United States and as part of the contract they want the work signed off in accordance with Sections 43.9  (maintenance) or 43.11 (inspections), and the work is performed in accordance with section 43.13 (performance rules). 

Will this conflict between earning a living and adhering to the FAR get you in trouble with the FAA? Will you be doomed to sleep with a night light on? The answer is no. Because the FAA has no legal jurisdiction over what is put in a foreign-registered aircraft’s logbook. 

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