2 Inch N-numbers -- Are They Still Legal?

Discussion in 'Hangar Talk' started by cwilliamrose, Nov 9, 2018 at 1:54 PM.

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  1. Nov 9, 2018 at 1:54 PM #1

    cwilliamrose

    cwilliamrose

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    The reason I ask is because Aircraft Spruce sells only 3" and 12" vinyl number strips and when I asked about 2" numbers they said 3" numbers are the requirement. I looked up FAR 45.2E and it still says 2" numbers are legal for 'antique' airplanes which (I believe) would include the Pitts airplanes since they date back to 1943.

    What's the latest guidance on this subject? I want to change the N-number on my S-2A but I do not want to be forced to go to larger numbers. Thanks......
     
  2. Nov 9, 2018 at 2:03 PM #2

    TFF1

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    i think that's reaching. Year of your aircraft it was certified and manufactured both come into play.
     
  3. Nov 9, 2018 at 2:08 PM #3

    wacoc8

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    Depends on when your S2A was built and when/if it has been repainted and recovered. Here is the reg.

    Sec. 45.22 Exhibition, antique, and other aircraft: Special rules.

    (a) When display of aircraft nationality and registration marks in accordance with Secs. 45.21 and 45.23 through 45.33 would be inconsistent with exhibition of that aircraft, a U.S.-registered aircraft may be operated without displaying those marks anywhere on the aircraft if:

    (1) It is operated for the purpose of exhibition, including a motion picture or television production, or an airshow;


    (2) Except for practice and test fights necessary for exhibition purposes, it is operated only at the location of the exhibition, between the exhibition locations, and between those locations and the base of operations of the aircraft; and


    (3) For each flight in the United States:

    (i) It is operated with the prior approval of the Flight Standards District Office, in the case of a flight within the lateral boundaries of the surface areas of Class B, Class C, Class D, or Class E airspace designated for the takeoff airport, or within 4.4 nautical miles of that airport if it is within Class G airspace; or


    (ii) It is operated under a flight plan filed under either Sec. 91.153 or Sec. 91.169 of this chapter describing the marks it displays, in the case of any other flight.

    (b) A small U.S.-registered aircraft built at least 30 years ago or a U.S.- registered aircraft for which an experimental certificate has been issued under Sec. 21.191(d) or 21.191(g) for operation as an exhibition aircraft or as an amateur-built aircraft and which has the same external configuration as an aircraft built at least 30 years ago may be operated without displaying marks in accordance with Secs. 45.21 and 45.23 through 45.33 if:

    (1) It displays in accordance with Sec. 45.21(c) marks at least 2 inches high on each side of the fuselage or vertical tail surface consisting of the Roman capital letter "N" followed by:

    (i) The U.S. registration number of the aircraft; or


    (ii) The symbol appropriate to the airworthiness certificate of the aircraft ("C", standard; "R", restricted; "L", limited; or "X", experimental) followed by the U.S. registration number of the aircraft; and

    (2) It displays no other mark that begins with the letter "N" anywhere on the aircraft, unless it is the same mark that is displayed under paragraph (b)(1) of this section.

    (c) No person may operate an aircraft under paragraph (a) or (b) of this section--

    (1) In an ADIZ or DEWIZ described in Part 99 of this chapter unless it temporarily bears marks in accordance with Secs. 45.21 and 45.23 through 45.33;


    (2) In a foreign country unless that country consents to that operation; or


    (3) In any operation conducted under Part 121, 127, 133, 135, or 137 of this chapter.

    (d) If, due to the configuration of an aircraft, it is impossible for a person to mark it in accordance with Secs. 45.21 and 45.23 through 45.33, he may apply to the Administrator for a different marking procedure.

    [Doc. No. 8093, Amdt. 45-5, 33 FR 450, Jan. 12, 1968, as amended by Amdt. 45-13, 46 FR 48603, Oct. 1, 1981; Amdt. 45-19, 54 FR 39291, Sept. 25, 1989; Amdt. 45-18, 54 FR 34330, Aug. 18, 1989; Amdt. 45-21, 56 FR 65653, Dec. 17, 1991]





    Sec. 45.29 Size of marks.

    (a) Except as provided in paragraph (f) of this section, each operator of an aircraft shall display marks on the aircraft meeting the size requirements of this section.


    (b) Height. Except as provided in paragraph (h) of this part, the nationality and registration marks must be of equal height and on--

    (1) Fixed-wing aircraft, must be at least 12 inches high, except that:

    (i) An aircraft displaying marks at least 2 inches high before November 1, 1981 and an aircraft manufactured after November 2, 1981, but before January 1, 1983, may display those marks until the aircraft is repainted or the marks are repainted, restored, or changed;


    (ii) Marks at least 3 inches high may be displayed on a glider;


    (iii) Marks at least 3 inches high may be displayed on an aircraft for
    which an experimental certificate has been issued under Sec. 21.191(d) or 21.191(g) for operating as an exhibition aircraft or as an amateur-built aircraft when the maximum cruising speed of the aircraft does not exceed 180 knots CAS; and


    (iv) Marks may be displayed on an exhibition, antique, or other aircraft in accordance with Sec. 45.22.

    (2) Airships, spherical balloons, and nonspherical balloons, must be at least 3 inches high; and


    (3) Rotorcraft, must be at least 12 inches high, except that rotorcraft displaying before April 18, 1983, marks required by Sec. 45.29(b)(3) in effect on April 17, 1983, and rotorcraft manufactured on or after April 18, 1983, but before December 31, 1983, may display those marks until the aircraft is repainted or the marks are repainted, restored, or changed.

    (c) Width. Characters must be two-thirds as wide as they are high, except the number "1", which must be one-sixth as wide as it is high, and the letters "M" and "W" which may be as wide as they are high.


    (d) Thickness. Characters must be formed by solid lines one-sixth as thick as the character is high.


    (e) Spacing. The space between each character may not be less than one-fourth of the character width.


    (f) If either one of the surfaces authorized for displaying required marks under Sec. 45.25 is large enough for display of marks meeting the size requirements of this section and the other is not, full-size marks shall be placed on the larger surface. If neither surface is large enough for full-size marks, marks as large as practicable shall be displayed on the larger of the two surfaces. If any surface authorized to be marked by Sec. 45.27 is not large enough for full-size marks, marks as large as practicable shall be placed on the largest of the authorized surfaces.


    (g) Uniformity. The marks required by this part for fixed-wing aircraft must have the same height, width, thickness, and spacing on both sides of the aircraft.


    (h) After March 7, 1988, each operator of an aircraft penetrating an ADIZ or DEWIZ shall display on that aircraft temporary or permanent nationality and registration marks at least 12 inches high.


    This reg is not followed all the time and is even misinterpreted by current day manufacturers and FAA ASI’s.

    Hope this helps!

    Dave
     
  4. Nov 9, 2018 at 2:27 PM #4

    cwilliamrose

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    Yeah,,, so,,,, The S-2A was certified June, 1971. My airplane was built in 1979 and it came out of the factory with 2" marks as best I can tell. The airplane has not been re-painted. The reg Dave posted says it can retain those 2" numbers until the marks are changed, then it must go to 12" numbers.

    This is from AC 45-2E, dated 10/01/2015;


    upload_2018-11-9_9-20-12.png upload_2018-11-9_9-22-30.png

    Which brings in the FAA definition of 'antique'. I have no idea why the exceptions have the 1981 and 1983 dates mentioned or if this has anything to do with an airplane considered to be an antique. Color me confused........
     
    Last edited: Nov 9, 2018 at 2:33 PM
  5. Nov 9, 2018 at 2:42 PM #5

    ndlakesdreamer

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    Between 1981 and 1983 new aircraft were allowed to use 2" markings. The exemption you site allows those aircraft to continue using them until they are refinished.
     
  6. Nov 9, 2018 at 2:46 PM #6

    cashflyer

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    Waco8 has the right reg, but missed on the interpretation.

    Since it is an "antique", it does not matter at all when or if it was painted. I've already been through this with the FAA regarding markings on a 1974 Cessna that our shop restored for a customer (including all new paint). It left here LEGALLY with 2 inch numbers.

    45.22
    (b) A small U.S.-registered aircraft built at least 30 years ago or a U.S.-registered aircraft for which an experimental certificate has been issued under §21.191(d) or 21.191(g) for operation as an exhibition aircraft or as an amateur-built aircraft and which has the same external configuration as an aircraft built at least 30 years ago may be operated without displaying marks in accordance with §§45.21 and 45.23 through 45.33 if:

    (1) It displays in accordance with §45.21(c) marks at least 2 inches high on each side of the fuselage or vertical tail surface consisting of the Roman capital letter “N” followed by:

    (i) The U.S. registration number of the aircraft;
     
  7. Nov 9, 2018 at 2:47 PM #7

    cwilliamrose

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    OK, thinks for clearing that up ndlakesdreamer.

    So the question remains -- what does the FAA consider to be an antique? I have yet to find anything on FAA.GOV that defines that term. Since it is used in the AC 45.2x documents there must be a definition somewhere......
     
  8. Nov 9, 2018 at 2:53 PM #8

    cwilliamrose

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    Thanks Harvey,

    That seems clear enough as it does not limit this to experimental airplanes and has a firm 30 year window.
     
  9. Nov 9, 2018 at 2:55 PM #9

    cashflyer

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    Appendix C - Definitions

    Antique aircraft.
    Paragraphs (1) through (3) below define antique aircraft.
    Paragraphs (2) and (3) below include restored or replica aircraft even if the aircraft is not identical to the original in every detail. Minor differences in configuration due to modern equipment and components are acceptable. Examples of such differences include using a tail wheel instead of a tailskid, main wheel brakes, or a modern type propeller.
    (1) A U.S.-registered aircraft built at least 30 years ago,
    (2) A U.S.-registered aircraft possessing a special airworthiness certificate in the experimental category for the purpose of exhibition with the same external configuration as an aircraft built at least 30 years ago, or
    (3) A U.S.-registered aircraft possessing a special airworthiness certificate in the experimental category for the purpose of operating an amateur-built aircraft with the same external configuration as an aircraft built at least 30 years ago.
     
  10. Nov 9, 2018 at 3:07 PM #10

    cashflyer

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    I advise though that you know the reg because if you are ever ramp checked, this could come up.

    Our customer's plane was still in my shop and our PMI was giving me grief about the N number we had applied. The FSDO finally agreed that §45.22 trumps 45.29 because 45.22(b)(1) specifically allows 2 inch marks.
     
  11. Nov 9, 2018 at 3:09 PM #11

    wacoc8

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    Waco8 has the right reg, but missed on the interpretation.

    Well, I just posted the reg....I didn’t think I interpreted it. But if I did, since the S2A was built more than 30 years ago, it may retain the original registration markings in the size originally posted on the aircraft, which were 2” markings. This has nothing to do with the definition of Antique airplane, which I do not believe the FAA has defined, thus the wording “built more than 30 years ago”. The confusion comes from when the reg was written, 1983 was 30 years ago and that is when 12” numbers became the norm for new certified aircraft.

    This reg is mis-applied regularly by all kinds of airplanes........Bonanza’s, Mooney’s, Pipers, Cessna, as well as Classic Waco........and that is just the certified airplanes.......
     
  12. Nov 9, 2018 at 3:35 PM #12

    cwilliamrose

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    I'm probably the one with the screwed up interpretation. I was looking at this statement from Table 3 of AC 45-2E dated Oct, 2015;

    On an aircraft displaying 2-inch marks before November 1, 1981, and on aircraft manufactured between November 2, 1981, and January 1, 1983, you may display those marks until the aircraft is repainted or the marks are repainted, restored, or changed. Once the aircraft is repainted or the marks are repainted, restored, or changed, the N-number is required to be 12 inches high.

    Since the S-2A was built and marked prior to Nov1, 1981 I thought this would apply to my airplane because it does not exclude 'antique' airplanes.

    In any case I agree that having your understanding and documentation of the reg handy would be a good thing. For now I intend to do nothing more than an N-number change but new fabric/paint is in the plans.
     
  13. Nov 9, 2018 at 9:51 PM #13

    cashflyer

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    Sorry, I thought that "Depends on when your S2A was built and when/if it has been repainted and recovered." was your interpretation of the regulations.

    In Post #9 above, I posted the FAA definition of Antique aircraft.

    How is the reg mis-applied? It is their reg.
    If applying 45.22 to an antique Mooney is not their intent, then they need to make a NPRM and change the reg.


    If you really, really want to know, then send a request for interpretation to the Office of Chief Council. Ask, "Does 45.22(b)(1) allow me to use 2 inch registration numbers on a Mooney built in 1985, and that was repainted in 2018?"

    I have sent several requests to the Chief Council over the years and it usually takes about 6 months to get an answer. Up to a year or more if your request involves any FOIA information.
     
  14. Nov 9, 2018 at 10:56 PM #14

    PittsDriver68

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    For what its worth, when they wrote the 30 years in Appendix C, the folks who fly large steel desks at the FAA never anticipated that light aircraft production would hit pretty much a wall, with new designs becoming few and far between, and production numbers dropping off a cliff, a couple of years later.

    Its their rule so go ahead and use 2" numbers. Don't overthink it and worry about future rulemaking. Any future rulemaking will grandfather the current fleet just like they tried to in the early '80's.

    It doesn't have to be logical, consistent, or make sense. Its the FAA.

    Best of luck,

    Wes
     
  15. Nov 10, 2018 at 12:56 AM #15

    Timbob

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    Hey Bill, instead of buying individual numbers and numerals from AS, isn't this a perfect application for that custom vinyl decal thang?
     
  16. Nov 10, 2018 at 1:09 AM #16

    cwilliamrose

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    ACS sells number 'strips' that have the complete number on backing paper so you can apply it easily. They don't offer 2" numbers but I have them checking on that with their vendor. I looked into it with a local company and they going to need $42 for two numbers strips, I'm hoping ACS can do better.
     
  17. Nov 10, 2018 at 1:20 AM #17

    Timbob

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  18. Nov 10, 2018 at 1:01 PM #18

    Dana

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    As I read it, any aircraft 30 years old, or any experimental that looks like a 30 year old aircraft, can use 2" numbers. The references to 1981 or 1983 are obsolete and meaningless because any such aircraft are now over 30 years old anyway. So since Bill's S-2A was built before 1988 it falls under 45.22b and can use 2" numbers.

    Just be glad we don't have to use the old giant numbers on the top and bottom of the wings that went with 2" numbers back in the day!
     
  19. Nov 10, 2018 at 2:22 PM #19

    cashflyer

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    With deference to Waco8, he and PittsDriver have a point. And this is likely why Waco8 said the reg is misapplied.... I don't think the FAA intended the 30 years to be a rolling data point. I think what they meant was for any plane that was 30 years old when the regulation was written to be granted the ability to use 2 inch numbers. This theory is supported by the fact that the "antique aircraft" rule was actually a carry-over from the 1963 revision of CAR 1.

    But in that revision, the CAA defined an antique aircraft as "manufactured before January 1,1933, or if, irrespective of date of manufacture, it has the same external configuration as an aircraft for which a type certificate, airworthiness certificate, license, or any other authorization was issued before January 1, 1933, by the United States Government."

    So likely, they should have written "planes built before Dec 31 1981" (or whatever date was intended). But they didn't, so as PittsDriver said... It's their rule. Don't overthink it.


    For some historical perspective, prior to Dec 31 1960, the regulations prescribed 20-inch wing marks and 2-inch side fuselage or vertical tail surface marks. This is what Dana mentioned. So be happy that 45.22 only requires the 2" numbers and not the 20" wing numbers!


    Jan 1 1961 is when the current 12" number configuration became the requirement - prescribing 12-inch identification marks to be located either on the side of the fuselage, or on the vertical tail surfaces, for fixed-wing aircraft.

    The CAA adopted the 12-inch side identification marks as standard for fixed-wing aircraft as a means of decreasing the collision hazard associated with air-to-air identification of civil aircraft by U.S. Air Force interceptor aircraft engaged in national defense.

    So why did they do away with the 20" wing numbers?
    The wing numbers were there so that TOWER personnel could identify the plane as it flew over, or as it taxied around at the airport. Effective December 26, 1961, a new regulation went into effect which required that aircraft operated to, from, or on an airport at which an airport traffic control tower is operated be capable of two-way radio communication with that control tower. With two-way communication available, control tower personnel had little need to visually identify aircraft by means of its identification marks.

    [source of information for this post: FR-1963-07-25, p 7557]
     
  20. Nov 10, 2018 at 3:08 PM #20

    AQAdude

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