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FAA Photo Certificates Could Cost Instructors $210 Biennially
from Robert Hadow, concerned SAFE member, flight school owner, instructor:
On November 19, 2010, the FAA issued a Notice of Proposed Rulemaking (NPRM), Docket No. FAA-2010-1127, Notice No. 2010-16, entitled Photo Requirements for Pilot Certificates. Key elements in this NPRM and in additional documents include:
- A proposal 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 assertion that there is "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 $210 for a new CFI certificate every two years when they renew.
- An FAA estimated total cost of $718.7 million to implement photo certificates.
Here is the list of costs estimated by the FAA per new certificate:
FAA charge $50.00
Photo at CVS $8.00
Testing Center $42.50
Pilot Time $80.60 (130 minutes at $37.20 per hour)
Travel $29.25 (50 miles)
Total $210.35
The Intelligence Reform and Terrorism Prevention Act (IRTPA) requires the FAA to issue pilot's licenses with photographs. Now the FAA has a legal reason to replace the certificate system a second time in six years, and sees an opportunity to increase fees and staffing. What we need to do is point out the errors in logic and try to get something that works, rather than a regression to a paper-based 8710 system with silver prints requiring a physical visit to a FSDO or testing center.
We can urge Congress to change the IRTPA, or we can urge the FAA to adopt an implementation that is less costly and burdensome than the current proposal. If we don't respond, we're likely to get a system that costs $210 every time a pilot certificate or flight instructor certificate (new or renewal) needs to be issued!
General comments are due at the Department of Transportation on or before February 17, 2011; however, comments related to data collection and cost need to be submitted no later than January 18th. SAFE is preparing an official response to the NPRM, and we are soliciting input from members. You are urged to weigh in on this issue by January 14th by submitting the NPRM comment form posted on the SAFE website.
View the text of the NPRM:
http://www.regulations.gov/#!documentDetail;D=FAA-2010-1127-0001
View other comments posted on regulations.gov:
http://www.regulations.gov/#!searchResults;rpp=10;so=DESC;sb=postedDate;po=0;s=FAA-2010-1127
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