Officials at the Society of Aviation and Flight Educators (SAFE) are urging all pilots to comment on a Notice of Proposed Rule Making to add photos to pilot certificates, a move that could add up to $210 to the cost of those certificates.
On Nov. 19, 2010, the FAA issued an NPRM, Photo Requirements for Pilot Certificates (Docket No. FAA-2010-1127; Notice No. 2010-16). SAFE officials point out that key elements in this NPRM and in other documents include:
- A proposed fee to the FAA of $50 per new certificate and $25 per replacement.
- A requirement that student pilots wait 6-8 weeks to get a certificate before solo.
- A claim that the new certificate fee represents no net cost to society.
- An assertion that the proposed photo procedure is “in the interest of reducing burdens on the certificate holder…”
- A claim that foreign pilots holding U.S. certificates would incur no additional travel expense as a result of having to visit a testing center, FSDO, or DPE.
- An FAA estimated total cost of $718.7 million to implement photo certificates.
Taking all associated costs into account (e.g., FAA and testing center fees, pilot time, photo and travel expenses, etc.), the FAA estimates the financial burden on pilots to be $210 per new certificate. Under the current NPRM, flight instructors will have the added burden of needing to procure a new photo certificate every two years when they renew their CFIs.
The Intelligence Reform and Terrorism Prevention Act (IRTPA) now requires the FAA to issue pilot’s licenses with photographs. According to concerned SAFE member Robert Hadow, “The FAA has a legal reason to replace the certificate system for the second time in six years, and apparently sees this as an opportunity to increase fees and staffing.” A flight school owner and instructor, Hadow added, “The aviation community needs to get engaged in this issue to get something that works, rather than a regression to a paper-based 8710 system requiring a physical visit to a FSDO or testing center.”
General comments are due at the Department of Transportation on or before Feb. 17, 2011; however, comments related to data collection and cost need to be submitted no later than Jan. 18, 2011, SAFE officials warn.
SAFE is preparing an official response to the NPRM based on input from its membership. Pilots, flight schools, and other aviation organizations are urged to weigh in on this issue before the appropriate due dates as well.