Multi-Part Answer Submitted To Four Government Entities

The Society of Aviation and Flight Educators (SAFE) has submitted a detailed response to the Notice of Proposed Rule Making (NPRM), Photo Requirements for Pilot Certificates (Docket No. FAA-2010-1127; Notice No. 2010-16). The response, prepared by SAFE member Robert Hadow, an instructor and flight school owner in NJ, was delivered to four government entities: the FAA; Office of Information and Regulatory Affairs (Office of Management and Budget); Committee on Homeland Security and Governmental Affairs; and Committee on Transportation and Infrastructure.

Provided government projections are accurate, the rulemaking could cost $210 every time a new certificate is issued, including every time flight instructors renew their CFIs. In a survey conducted by SAFE, 97% of respondents oppose the NPRM (83% strongly oppose); 92% believe the added cost would have a negative impact on CFIs (86% highly negative); and 89% believe the added cost would result in fewer pilots seeking advanced certifications, with 80% concerned that this could have a negative impact on aviation safety.

SAFE has provided specific objections to the NPRM as well as alternative solutions. The critical recommendation made was to discontinue the proposal altogether, or at least to delay it until the FAA has developed a workable business process for issuance of airmen certificates that is secure and cost effective, and that provides operational benefits to airmen and anticipates technological developments. Short of that, among SAFE's specific recommendations are that the subission process be made paperless, including the photo to be used on the certificate, that the term of the certificate be made 10 years, and that there should be no charge for the new photo ID.

Plastic Pilot's License

For flight instructors, SAFE says they should be able to obtain their certificates as they do now, without charge.

SAFE represents more than 500 of the industry's top aviation educators, including numerous local and national General Aviation Award winners in the flight instruction, aviation maintenance, avionics, and FAA Safety Team categories. SAFE is also chairing the GA Pilot Training Reform Symposium in Atlanta on May 4-5, 2011.

FMI: NPRM , SAFE Response