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Mon, Jan 03, 2011

Aero-Analysis: Feds Wrong -- Pilot Photo ID NPRM IS 'Economically Significant'

Aero-News Analysis by ANN Editor-In-Chief, Jim Campbell, and CFI Robert Hadow (SAFE)

ANN has been monitoring a number of reports and conversations concerning the FAA's forthcoming mandatory Photo ID requirements... and the attendant 'Bravo Sierra' foisted upon aviation assuring us that this is no big deal and of negligible cost -- or, to use FAA-Speak, "is not an `economically significant regulatory action'"


The FAA claims that an NPRM outlining 'Photo Requirements for Pilot Certificates' will have only a minimal amount of effect on the pilot community... and some excellent comments and analysis across a number of forums and comment boards has brought up significant exceptions to such reasoning.

And even when you peel away the layers of new FAA bureaucracy to be foisted upon we aviators, the document does reveal that, "Costs to pilots would sum to $445.8 million ($235.8 million, present value) over the above 20-year period."

Folks, that's nearly a half-billion dollars... and even in the aviation world, that's REAL money. In other words, we're getting screwed... again.

The NPRM Notes that, "This action would require a person to carry a pilot certificate with photo to exercise the privileges of the pilot certificate. This proposal responds to section 4022 of the Intelligence Reform and Terrorism Prevention Act (IRTPA). The FAA previously required all pilots to obtain a plastic certificate (excepting temporary certificates and student pilot certificates). This proposal furthers the fulfillment of IRTPA by requiring a photo of the pilot to be on all pilot certificates. The FAA also proposes to require student pilots to obtain a plastic certificate with photo. Student pilot certificates would also have the same duration as other pilot certificates. Additionally, because of the new photo requirements, this proposal modifies the application process and the fee structure for pilot certificates."

Society of Aviation and Flight Educator member Robert Hadow notes that:

I suggest that you all read some of the comments received by the FAA on the Photo Certificate proposal. The FAA has added materials to the library that indicate more intended regulation than the original NPRM.

You can access the comments at Search for "FAA-2010-1127"

(1) In document FAA-2010-1127-0004.1, the FAA proposes $50 per new certificate and $25.00 per replacement.

(2) The FAA claims that the new certificate fee represents no net cost to society. You can check the logic in the FAA's David Tietelbaum piece FAA-2010-1127-003.1

"While this is a real cost to the pilots, these payments to the FAA are considered transfer payments; OMB Circular A-4 defines transfer payments as "monetary payments from one group to another that do not affect total resources available to society." This $22 fee is a transfer payment from the pilots to the Agency and as such does not increase or decrease the cost to society of this rulemaking. Another way of looking at this is to realize that if the analysis adds in the $22 fee from the aircraft owners and then subtracts the same $22 to partially offset the FAA’s processing costs, the result would be that this application fee would, in effect, be zeroed out in the calculations and so would not be reflected in the cost of the rule to society. "

(3) The FAA claims that foreign pilots holding U.S. certificates would incur no additional travel expense as a result of having to visit a testing center, FSDO, DPE. FAA-2010-1127-003.1

(4) In FAA-2010-1127-003.1 the FAA describes "no additional expense to CFIs" as a result of the initiative because we also hold Commercial Certificates or ATP certificates. The NPRM however describes CFI certificates separately. If the NPRM language remains, CFIs will have to pay every two years for a new CFI certificate.

(5) The FAA estimates that testing centers will charge $42.50 to process an application for a new certificate. FAA-2010-1127-003.1

Here is the list of costs estimated by the FAA for a new certificate:

  • FAA charge $50
  • Photo at CVS $8
  • Testing Center $42.50
  • Pilot Time $80.60 (130 minutes at $37.20 per hour)
  • Travel $29.25 (50 miles)
  • Total $210.35

There are currently 166 comments on file. Most of the comments describe this effort as "security theatre" — a fee to put a photograph on a document that authorities never ask for.

What these folks don't understand is that the FAA has found a legal reason to replace the certificate system a second time in six years, and sees an opportunity to increase fees and staffing. We are unlikely to get out of it. What we can do is point out the massive errors in logic and try to get something that works, rather than a regression to a paper-based 8710 system with silver prints that requires a physical visit to a FSDO or testing center.

I had to think for a while why the federal government does not want to continue accepting drivers licenses as the photo id that confirms the identity of the pilot. The federal government needs the digital images of all pilots to compare with other databases. Currently only two states share digital images,

In those 166 comments was one organization, the University of Oklahoma. EAA didn't comment. AOPA didn't comment. Nor ALPA. Nor SAFE. If we don't say something, we're going to get a system that costs $210.35 every time a pilot certificate, flight instructor certificate, or ground instructor certificate needs to be issued. If that's what we want. Fine.

Aero-News Analysis: Hadow is spot on... and did an excellent job of boiling down the usual FAA BS with the help of the sources he cites... this proposal is poorly conceived, it hurts aviation and more to the point, when you add this nonsense to all the other nonsense we put up with, it continues to decimate what is left of an embattled industry...

  • If the FAA keeps this up, we're toast.
  • If the associations keep sticking their heads in the sand, we're toast.
  • If the aviation community doesn't rise up and fight this noise, we're toast.

Mind you, this doesn't have to be this way... if there's one thing that we learned from the recent FlightPrep scandal, its that aviators will fight what they feel to be wrong when they have the chance... but it's also obvious that the way that aviation communicates such issues has to change, RADICALLY, to fit the obstacles we face -- but that's an editorial topic for another time... and in the very near future.

In the meantime, we suggest aggressive response to this NPRM, on or before the deadline of February 17, 2011. But even more important than that, this community needs to have a "Come To Jesus" with this FAA and let them know that the fate of this industry is, in part, in their hands... and so far they're doing a pretty damned poor job with it. Things have to change... radically. And yeah, we'll have a lot to say about that VERY shortly. We've had our thinking cap on overdrive and we think we have some solid ideas about WHAT TO DO... rather than sitting here bitching and moaning about it all. MUCH More info to follow. 

You may send comments identified by Docket Number FAA-2010-1127 using any of the following methods:

  • Federal eRulemaking Portal: Go to and follow the online instructions for sending your comments electronically.
  • Mail: Send comments to Docket Operations, M-30; U.S. Department of Transportation, 1200 New Jersey Avenue, SE., Room W12-140, West Building Ground Floor, Washington, DC 20590-0001.
  • Hand Delivery or Courier: Take comments to Docket Operations in Room W12-140 of the West Building Ground Floor at 1200 New Jersey Avenue, SE., Washington, DC, between 9 a.m. and 5 p.m., Monday through Friday, except Federal holidays.
  • Fax: Fax comments to Docket Operations at 202-493-2251.
FMI:!documentDetail;D=FAA-2010-1127-0001,, Comments/Criticism For ANN????


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