A lot of pilots I talked to recently seem excited to hear that they will soon get a pilot certificate that has their picture on it. I am sorry to hear this as getting a new pilot certificate with my picture on it is somewhere around the last thing I need. My certificate already has my name, address and description as well as a very nice picture of Wilbur and Orville. Why would I want my picture there also? I get to see my smiling face every morning when I shave and for me that’s plenty.
I wonder if those who think this is a good idea have given this much thought. I also wonder if they have read the 14 page notice of proposed rulemaking that the FAA has published to describe this program. (Docket no. FAA-2010-1127; Notice No. 2010-16 Photo requirements for pilot certificates)
Here are some of the things it tells us. First off, every pilot who holds a pilot certificate, including student pilots, will have to get a new one. That alone should create a lot of new government jobs; I guess that could be good for the unemployment rate. But, in my view not so great for us pilots. The NPRM also tells us that the FAA needs to recover the additional costs associated with this rule so in the future these new pilot certificates will cost us about $22 bucks, only to increase over time. Today, if you take a check ride and get a new certificate, it is free. If you need a duplicate it is just $2. See the progress so far?
Now, I wonder where those pictures will come from. Some say well, we can get our picture taken when we take our FAA medical exam. Not true, according to the NPRM, FAA doctors will not be authorized to do that. In fact, FAA doctors will no longer be able to issue student pilot certificates either. So, we will have to go someplace else to get a picture taken and it must be in accordance with the very specific instructions issued in the NPRM. Read that to mean more cost for the pilot.
Now that you have your pictures, don’t think you can just send them to the FAA and get a certificate. No, instead they say, we must go to the FSDO, a knowledge testing center or a designated pilot examiner to get our application verified. In the words of the NPRM “The FAA anticipates that designees would charge a fee, in addition to the fee charged by the FAA, to accept and verify applications”. Another added cost for pilots.
OK, we have paid for our pictures, paid our verification fee and attached our check for $22 to the FAA now I wonder how long it will take to get this new certificate? The NPRM says it could take six to eight weeks!! This now includes student pilot certificates. Remember, you can’t fly without a certificate.
So here we are with added FAA bureaucracy, significant additional fees and greater inconvenience to the pilot population all to replace a system that is currently working fine. The comment period for this proposal ends on Feb. 17, 2011. I hope other pilots are inspired to comment.