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Joining with those attempting to slow the spread of the Coronavirus (COVID-19) and to minimize exposure for Federal Aviation Administration (FAA) employees, FAA Public Document Room (PDR) permit holders, families, and the general public, the FAA Civil Aviation Registry (Registry) will be implementing changes which will affect how aircraft transactions are processed in the PDR during the Coronavirus pandemic. The good news is the Registry and PDR will currently remain open, aircraft records may still be accessed, and transactions still processed in the PDR. Nevertheless, effective 8 a.m. central time, Thursday, March 19, 2020 following are highlights of the changes that will be introduced:

The PDR filing window will be closed. Instead of the normal, open access for PDR permit holders to file documents throughout the day, the FAA will accept or pick up documents on the following schedule:

• Priority documents (e.g. exports, imports, etc.) will be picked up hourly.
• Non-priority documents will be picked up twice a day.

Parties may now file documents via email to 9-AVS-AR-Electronic-Submittals@faa.gov:

• Filing via email is limited to documents 20 pages or less.
• Documents must be limited to one aircraft per email.
• Documents which would otherwise need to be originally, ink signed must be digitally executed.
• The Registry has confirmed that an email receipt confirmation is NOT equivalent to the time ‘filed’ or ‘clocked’ with the Registry. Filing information will be available after the documents are scanned and file stamped.

The Registry is implementing a system where payment can be made via pay.gov, subject to a number of procedural details.

Parties may also continue to file documents:

• By U.S. Postal Service, Regular and Priority Mail at FAA Aircraft Registration Branch, P.O. Box 25504, Oklahoma City, OK 73125-0504; or
• By Commercial Delivery Services at FAA Aircraft Registration Branch, Registry Building Room 118, 6425 South Denning, Oklahoma City, OK 73169-6937

During the pandemic the FAA will not be able to guarantee “in by 11 out by COB” expedited processing of documents for imports.

It will take time to better understand how these changes will affect transactions, and for parties to be comfortable they can comply with the new processes. For instance, how will the pay.gov process work? Or, how and when will parties be able to obtain filing times for documents submitted through the new process? How long will it take to obtain Unique Authorization Codes for registrations on the International Registry?

The situation with the Registry remains fluid and there could certainly be more changes in the future as this crisis progresses. Please do not hesitate to call our aviation attorneys at McAfee & Taft if you have any questions. We will try to keep you updated!