FAA is proposing that pilot certificate holders with only foreign addresses will be required to add a US-based agent/address to their file:
“The FAA proposes that individuals with foreign addresses, and no U.S. physical address of record on file with the FAA, who hold or apply for certain certificates, ratings, or authorizations designate a U.S. agent for service of FAA documents. The U.S. agent would receive service of FAA documents on the certificate holder or applicant’s behalf. This proposed rule would facilitate the FAA’s ability to accomplish prompt and cost-effective service of process and service of other safety-critical or time-sensitive documents to individuals abroad through service on their U.S. agents”
Apparently the logistics, legalities, delays and costs of foreign delivery to pilots in every country in the world are problematic, e-mail somehow isn’t allowable to serve legal notices and FAA wants to get out of the overseas document delivery business. Presumably the US agent would have to email or otherwise forward the info, but the clock starts ticking when the agent receives it (meaning a notice of certificate suspension or hearing or whatever). This would apply to anybody, including US citizens overseas who have no US address.
Comment period is open for a few more days. Link
The US trust seems to be the obvious choice.
They might charge a bit for the “mailbox” but in reality the only mail from the FAA is going to be relating to FAA medicals.
I have a mailbox in the US, it costs me something like $15/month. They scan everything I ask them to and will forward the physical mail if I ask them, at a somewhat eye-watering price. There are services like this at every second strip mall in the country.
So someone with an FAA licence will need to pay approx $200 per year for a forwarding address, just to retain their licence?
That would be a bit “ouch” for FAA licence holders.
I could imagine lots of hotel addresses being given, but with the result that you could be in a lot of trouble for “ignoring” mail that we legally deemed to be delivered to you. Especially so if it was serious enough to end up in front of a judge and you were having to explain why you didn’t get notice of suspension because you gave a ‘false’ address as your home address.
I am sure the Trustee will do this for you. It’s an obvious opportunity. They already do it for various things like issuing an updated CofA etc.
The exception are US citizens and Green Card holders who can legitimately own an N-reg personally but reside outside the US. They will need to pay for some mailbox service.
This is not new; lots of scenarios where a European CAA requires an in-country mailing address. One example was IIRC for PH-reg homebuilts which are based in large numbers outside NL.
Airmail is expensive nowadays and us N-reg owners have benefited massively from the US taxpayer and US govt generosity so I am not going to complain 
Peter wrote:
I am sure the Trustee will do this for you.
Sure, but I expect only a small percentage of FAA Airman certificate holders will be aircraft owners. So most FAA certificate holders, won’t have a trustee.
Take note that a mailbox service address won’t necessarily satisfy the proposed requirement. It has to be a physical address and an appointed legal person, so that the letter is legally received by your self-appointed agent. That way when they say something like “you have 30 days to respond before we pull your pilot certificate” (I made that up, obviously) the clock can start ticking. That is the primary FAA issue, not payment for postage or similar.
It does not need to be a place where you have ever lived, or ever been. I would expect some trustees would expand their business to do this, not just for aircraft owners, for a fee.
Another nail in the coffin although it seems large numbers of homebuilders do this already, though maybe without the “person” part i.e. just a mailbox.
OTOH if I use a mailbox service, isn’t the name on that address my name?
Take note that a mailbox service address won’t necessarily satisfy the proposed requirement.
True but it looks like a regular address apart from some stuff on the end of the street address line. So it’s something like:
Mr John H…
1234 Somewhere Boulevard 123/456
94045 Sunnyvale CA
I use it for various things that say they won’t accept a PO Box (like Social Security, and my Amex card, neither of which can handle a non-US address), and everything has been fine for two years.
I believe they want somebody appointed by you by name at the US address to sign for a letter. Or perhaps a legal person and on site representative. But I haven’t read the NPRM closely enough in that regard to be 100% sure.
Whether the typical Mailboxes Etc style address in your name with Suite xxx would satisfy FAA until they needed a signature (which is probably never) is another issue, I suppose.
