WHAT THEY ARE SAYING ABOUT
THE NEW AIRCRAFT REGISTRATION PROCEDURES

Here are some examples of what people have said about CASR 47 and the new aircraft registration procedures. Note the immense gulf between why CASA said they were needed when first proposed, and why CASA now says they are needed.

Do not transfer the registration of your aircraft to someone else unless you fully understand the potential consequences of doing so and you have satisfied yourself that there really is a legal requirement to do so.  Put CASA's letter of 21st September 2000 in the appropriate (round) filing place.

Here are some comments I have received from real people.

The purpose of this Notice of Proposed Rule Making (NPRM) is to:
*   simplify the aircraft registration procedures
*   clearly identify the person in possession of the aircraft as the person responsible for airworthiness control of the aircraft
*   remove the need to record property interest details in the Civil Aircraft Register.
CASA, 4th August 1998 (NPRM 9807)

CASR Part 47 is being introduced because there have been too many incidents in which vital safety information (such as Airworthiness Directives) has not been passed on by the Certificate of Registration holder to the person controlling the airworthiness and maintenance of an aircraft.
CASA, 21st September 2000 (Letter to aircraft owners)

You should also note that, amongst the 61 comments received on the NPRM for Part 47, was one from the Aircraft Owners and Pilots Association dated 25 September 1998, indicating that the proposal in the NPRM was acceptable without change.
CASA, 29th September 2000 (Letter from Richard Yates to Boyd Munro)
Unfortunately AOPA did not even inform its members after agreeing to this - much less consult them beforehand.

May I acknowledge to you my gratitude for your concern on matters affecting myself and other people like me who are pilots with a simple taste for flying that wish to escape the bureaucratic overload with which we are incessantly bombarded … Thank you.
Cessna Owner, Queensland, AOPA member

My first thought when this lovely piece of CASA toilet paper arrived was SOD OFF. It took me 16 years of hard work, huge amounts of grovelling to the Mrs and a dose of insanity to buy my Cessna. There is no way known I would ever assign my C of R to some one else. ITS MINE......
Cessna owner, Victoria

Thank you for your constant vigilance - the lawmakers at CASA are either incredibly devious or overwhelmingly stupid.  People like you keep them on their toes and are invaluable to the rest of us poor trusting slobs.
Piper owner, NSW, former AOPA member

Thanks for the valuable information. I had no intention of transferring my aircraft's registration and your letter certainly justifies my decision.
Piper owner, Queensland

Thank you Boyd for keeping us informed.  Original letter from CASA sure was misleading.   Good on you, keep them honest.
Cessna owner, NSW, former AOPA member

Thanks for doing this, Boyd .Of course this was not necessary before the change to the CARs made it so.  Bloody xxxxxx again.
Light aircraft owner, Victoria, AOPA member

Thanks Boyd, I got this letter saying that regarding CofR transfers and I thought to myself "what a load of ****", and threw it away, hoping CASA wouldn't get upset. Your e-mail makes me feel better about it.
Cessna owner, Queensland

That's a very interesting letter.  Unfortunately (or maybe fortunately) I do not own an aircraft but it sure is a very complicated and sensitive issue.
Private Pilot, Victoria, AOPA member

Thanks Boyd.  I had suspected as much (not that I have any desire to transfer the C of R of my aeroplane anyway).
Cessna owner, NSW, AOPA member

I think that this latest proposal of CASA to transfer aircraft Registrations is absolutely crazy.  It seems to me that they must mirror their own mentality when thinking about aircraft owners.  I often wonder how many of them have bought their own aircraft with their own funds after having worked and saved for many years to accumulate those funds.  I think they lack commercial reality.
Beechcraft owner, NSW, AOPA member

Thanks for your message.  I do own a small 'bug smasher' and when I read the letter from CASA my immediate understanding was that I control the maintenance because I arrange to have the servicings done when required.  I immediately binned the letter.
There is absolutely no way I would be signing over the certificate of registration to anyone else, particularly not a maintenance facility!
I really can't see the need for this CASA requirement.  Surely any organisation/operator who finds the owner unwilling to pay for maintenance to a required standard has the option of not utilising that aircraft?  Either way, it is a matter between the owner and the operator and the owner's rights should not be eroded.  Thanks for keeping me informed.
Piper owner, Queensland, AOPA member

Thanks for the information. I have been very concerned about our club aircraft in this situation. We have an operator that does all our maintenance and we were getting very concerned about the whole thing. Can you recommend an aviation lawyer who can advise us on this matter?
Cessna owner, Victoria, AOPA member

Got the letter from CASA and thought "What are they up to now". Dispatched it to the bin.  Pleased to get your fax re same and I followed instructions and mailed accordingly.
Light aircraft owner, Victoria, AOPA member

Thank you for your information on CofR. I too have serious misgivings in this area.  Although there are times in which I certainly disagree with your views, nevertheless I still appreciate your efforts, not only in this matter, but others as well.  Once again thanks for the "heads up".
Cessna owner, NSW, AOPA member

Boyd, thanks very much for the last email, I appreciate all your correspondence.
Commercial Cessna operator, Victoria, former AOPA member