WASHINGTON, D.C. — The FAA has issued a Notice of Proposed Rule Making to require photos on pilot certificates. But did you know that this isn’t the first time photos were on pilot certificates?
Details of the proposal are now being studied by various aviation groups, with the deadline for comments set for Feb. 17, 2011.
To apply for a certificate with a photo, the FAA would require a pilot to submit an application for a new or replacement certificate in person. For these in-person applications, a pilot must appear at a Flight Service District Office (FSDO) or other FAA designee, such as a Knowledge Testing Center or designated pilot examiner. All certificate holders applying for a certificate with a photo for the first time would submit that application in person. The FAA has 96 FSDOs in the U.S. and approximately 2,700 designees world-wide who can process applications.
The new certificates would be valid for eight years and a fee of $22 is proposed for each new or renewal certificate. After the eight year expiration date, renewal requires a new photo, which, like the first, must have been taken within 90 days of the application.
After a person has a pilot certificate with photo, he or she must appear in person to change the name, date of birth, or other data. Lost or damaged certificates may be replaced by mail.
Holders of private, recreational or sport pilot certificates would have five years to secure the photo certificates. Commercial pilots would have four years to comply and pilots with current airline transport ratings would have three years. Applicants for student certificates, currently exempt from the requirement for a plastic certificate, will be required to obtain a photo certificate, so the FAA proposes to discontinue the policy of Aviation Medical Examiners issuing student pilot certificates along with a first medical certificate.
The NPRM does not include specific identity verification standards and processes. These probably will be included in the final rule.
Currently there are about 740,000 pilots. With the initial application and renewal required every eight years, FAA estimates the cost to pilots over the next 20 years will be $445.8 million for the photo IDs ($235.8 million in today’s dollars). The fee, plus time off work, travel and other connected expenses, might be about $175 for each pilot, so total cost over the 20 years for the three certificates is projected to be about $375.
Officials with aviation’s alphabet groups are studying the NPRM, which covered more than 10 pages in the Federal Register. The National Business Aviation Association (NBAA) and the Aircraft Owners and Pilots Association (AOPA) are not opposing the rule, but officials said they are seeking ways to help the FAA develop a process that satisfies security issues without giving pilots undue burdens and costs.
The requirement for photos on certificates is not new. When I obtained my private license in 1954, the Department of Commerce, which oversaw aviation, required an airman identification card that included not only a photo, but a fingerprint as well. The card was issued by the designated examiner.
Comments about the NPRM may be submitted in any one of several ways. Identify your comments by Docket Number FAA-2010-1127. To comment online, go to Regulations.gov and follow the instructions. You can send your comments by mail to: Docket Operations, M-30, U.S. Department of Transportation, 1200 New Jersey Ave. SE, Room W12-140, West Building Ground Floor, Washington, D.C., 20590-0001. To send by fax, the number is 202-493-2251.
Charles Spence is GAN’s Washington, D.C., correspondent.