Tue, Jan 18, 2011
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.
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