SAFE Drafting a Response, Urges Others to do the Same

The Society of Aviation and Flight Educators (SAFE) has taken a leadership role to address a Notice of Proposed Rule Making (NPRM) that could add up to $210 to the cost of pilot certificates. On November 19, 2010, the FAA issued an NPRM entitled, Photo Requirements for Pilot Certificates (Docket No. FAA-2010-1127; Notice No. 2010-16). Key elements in this NPRM and in other documents include:

• A proposed fee to the FAA 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 FAA estimated total cost of $718.7 million to implement photo certificates.

Taking all associated costs into account (e.g., FAA and testing center fees, pilot time, photo and travel expenses, etc.), the FAA estimates the financial burden on pilots to be $210 per new certificate. Under the current NPRM, flight instructors will have the added burden of needing to procure a new, $210 photo certificate every two years when they renew their CFIs.

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