Comment Clustering v3.ipynb

{
 "cells": [
  {
   "cell_type": "code",
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   "source": [
    "# Imports\n",
    "from pickle import dump, load\n",
    "import nltk\n",
    "from nltk import word_tokenize,FreqDist\n",
    "import re\n",
    "from nltk.corpus import wordnet as wn\n",
    "from nltk.util import ngrams\n",
    "from sklearn.cluster import KMeans\n",
    "from nltk.stem.snowball import SnowballStemmer\n",
    "from sklearn.feature_extraction.text import TfidfVectorizer\n",
    "from sklearn.metrics.pairwise import paired_distances\n",
    "import pandas as pd\n",
    "import json"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 2,
   "metadata": {
    "collapsed": true
   },
   "outputs": [],
   "source": [
    "#cluster count\n",
    "def get_document_text(raw_text):\n",
    "    \"\"\" This function takes in raw document text as input which we receive from the API and returns a clean text \n",
    "    of the associated document. It cleans up any HTML code in the text, newline characters, and extracts supplemental\n",
    "    information part of the document.\n",
    "    \n",
    "    INPUT: string\n",
    "    OUTPUT: string\n",
    "    \"\"\"\n",
    "    raw_text = raw_text.replace('\\n',' ')\n",
    "    raw_text = raw_text.replace('*','') # added\n",
    "    raw_text = raw_text.replace('\\r',' ') # added\n",
    "    # Remove any residual HTML tags in text\n",
    "    cleanr = re.compile('<.*?>')\n",
    "    cleantext = re.sub(cleanr, '', raw_text)\n",
    "    return cleantext\n",
    "\n",
    "# def tokenize_text(corpus):\n",
    "#     pattern = r'''(?x)    # set flag to allow verbose regexps\n",
    "#     (([A-Z]\\.)+)          # abbreviations, e.g. B.C.\n",
    "#     |(\\w+([-']\\w+)*)      # words with optional internal hyphens e.g. after-ages or author's\n",
    "#     '''\n",
    "#     tokens = nltk.regexp_tokenize(corpus,pattern)\n",
    "#     all_token = [word.lower() for token in tokens for word in token if word != \"\" and word[0] != \"'\" and word[0] != \"-\"]\n",
    "#     return all_token\n",
    "\n",
    "# REGEX MODIFIED FROM THE ABOVE\n",
    "def tokenize_text(corpus):\n",
    "    pattern = r'''(?x)     # set flag to allow verbose regexps\n",
    "    ((?:[A-Z]\\.)+)         # abbreviations, e.g. B.C.\n",
    "    | (?:(\\w+([-']\\w+))+)  # words with optional internal hyphens e.g. after-ages or author's\n",
    "    | ([a-zA-Z]+)          # capture everything else\n",
    "    '''\n",
    "    tokens = nltk.regexp_tokenize(corpus,pattern)\n",
    "    all_token = [word.lower() for token in tokens for word in token if word != \"\" and word[0] != \"'\" and word[0] != \"-\"]\n",
    "    return all_token\n",
    "\n",
    "def tokenize_text_sent(corpus):\n",
    "    sent_tokenizer = nltk.data.load('tokenizers/punkt/english.pickle')\n",
    "    raw_sents = sent_tokenizer.tokenize(corpus) # Split text into sentences    \n",
    "    return [tokenize_text(sent) for sent in raw_sents]\n",
    "\n",
    "def tag_my_text(sents):\n",
    "    return [nltk.pos_tag(sent) for sent in sents]\n",
    "\n",
    "#Chunk noun phrases in tree \n",
    "def noun_phrase_chunker():\n",
    "    grammar = r\"\"\"\n",
    "    NP: {<DT|PP\\$>?<JJ>*<NN>}   # chunk determiner/possessive, adjectives and noun\n",
    "    \"\"\"\n",
    "    cp = nltk.RegexpParser(grammar)\n",
    "    return cp\n",
    "\n",
    "#Extract only the NP marked phrases from the parse tree, that is the chunk we defined\n",
    "def noun_phrase_extractor(sentences, chunker):\n",
    "    res = []\n",
    "    for sent in sentences:\n",
    "        tree = chunker.parse(sent)\n",
    "        for subtree in tree.subtrees():\n",
    "            if subtree.label() == 'NP' : \n",
    "                res.append(subtree[0:len(subtree)])\n",
    "                #res.append(subtree[0])\n",
    "                #print(subtree)\n",
    "    return res\n",
    "\n",
    "#remove tags and get only the noun phrases , can be adjusted for length\n",
    "def noun_phrase_finder(tagged_text):\n",
    "    all_proper_noun = noun_phrase_extractor(tagged_text,noun_phrase_chunker()) \n",
    "    #does not literally mean proper noun. Chunker only extracts common noun\n",
    "    noun_phrase_list = []                                                      \n",
    "    #noun_phrase_string_list =[]\n",
    "    for noun_phrase in all_proper_noun:\n",
    "        if len(noun_phrase) > 0: #this means where the size of the phrase is greater than 1\n",
    "            small_list =[]\n",
    "            for (word,tag) in noun_phrase:\n",
    "                small_list.append(word)\n",
    "            noun_phrase_list.append(small_list)\n",
    "            #noun_phrase_string_list.append(' '.join(small_list))\n",
    "    return noun_phrase_list\n",
    "\n",
    "#get freq dist obj for noun phrase of different lengths\n",
    "def find_freq(nested_list,nest_len):\n",
    "    #from nltk.probability import FreqDist\n",
    "    fdist_list =[]\n",
    "    for inner_np in nested_list:\n",
    "        if len(inner_np) == nest_len:\n",
    "            fdist_list.append(' '.join(inner_np))\n",
    "    fdist = FreqDist(fdist_list)\n",
    "    return fdist\n",
    "\n",
    "def get_top_unigrams(np):\n",
    "    unigrams = []\n",
    "    for item in np:\n",
    "        if len(item) ==  1:\n",
    "            unigrams.append(item)\n",
    "    fdist_uni = find_freq(np,1)\n",
    "    uni_list = fdist_uni.most_common()\n",
    "    threshold = 0.3 * len(unigrams)\n",
    "    top = []\n",
    "    s = 0\n",
    "    for word,count in uni_list:\n",
    "        top.append(word)\n",
    "        s += count\n",
    "        if s > threshold:\n",
    "            break      \n",
    "    return top\n",
    "\n",
    "# Lesk algorith for disambiguation in case of multiple synsets of a word\n",
    "def compare_overlaps_greedy(context, synsets_signatures, pos=None):\n",
    "    \"\"\"\n",
    "    Calculate overlaps between the context sentence and the synset_signature\n",
    "    and returns the synset with the highest overlap.\n",
    "    \n",
    "    :param context: ``context_sentence`` The context sentence where the ambiguous word occurs.\n",
    "    :param synsets_signatures: ``dictionary`` A list of words that 'signifies' the ambiguous word.\n",
    "    :param pos: ``pos`` A specified Part-of-Speech (POS).\n",
    "    :return: ``lesk_sense`` The Synset() object with the highest signature overlaps.\n",
    "    \"\"\"\n",
    "    # if this returns none that means that there is no overlap\n",
    "    max_overlaps = 0\n",
    "    lesk_sense = None\n",
    "    for ss in synsets_signatures:\n",
    "        if pos and str(ss.pos()) != pos: # Skips different POS.\n",
    "            continue\n",
    "        overlaps = set(synsets_signatures[ss]).intersection(context)\n",
    "        if len(overlaps) > max_overlaps:\n",
    "            lesk_sense = ss\n",
    "            max_overlaps = len(overlaps)  \n",
    "    return lesk_sense\n",
    "\n",
    "def lesk(context_sentence, ambiguous_word, pos=None, dictionary=None):\n",
    "    \"\"\"\n",
    "    This function is the implementation of the original Lesk algorithm (1986).\n",
    "    It requires a dictionary which contains the definition of the different\n",
    "    sense of each word. See http://goo.gl/8TB15w\n",
    "\n",
    "        >>> from nltk import word_tokenize\n",
    "        >>> sent = word_tokenize(\"I went to the bank to deposit money.\")\n",
    "        >>> word = \"bank\"\n",
    "        >>> pos = \"n\"\n",
    "        >>> lesk(sent, word, pos)\n",
    "        Synset('bank.n.07')\n",
    "    \n",
    "    :param context_sentence: The context sentence where the ambiguous word occurs.\n",
    "    :param ambiguous_word: The ambiguous word that requires WSD.\n",
    "    :param pos: A specified Part-of-Speech (POS).\n",
    "    :param dictionary: A list of words that 'signifies' the ambiguous word.\n",
    "    :return: ``lesk_sense`` The Synset() object with the highest signature overlaps.\n",
    "    \"\"\"\n",
    "    if not dictionary:\n",
    "        dictionary = {}\n",
    "        for ss in wn.synsets(ambiguous_word):\n",
    "            dictionary[ss] = ss.definition().split()\n",
    "    best_sense = compare_overlaps_greedy(context_sentence, dictionary, pos)\n",
    "    return best_sense\n",
    "    #return dictionary \n",
    "\n",
    "# this function takes in a word and gets the most relevant synset based on context from the text. \n",
    "# for exact algorith refer the text above (\"what I want to do\" markdown)\n",
    "def get_synset(word,pos_tag_text ,pos):\n",
    "    if len(wn.synsets(word)) == 1:\n",
    "        #print(\"here1\")\n",
    "        return wn.synsets(word)[0]\n",
    "    else:\n",
    "        #get all context sentences\n",
    "        all_sent =[]\n",
    "        for sent in pos_tag_text:\n",
    "            for (w,t) in sent:\n",
    "                if w == word:\n",
    "                    all_sent.append(sent)\n",
    "        #call lesk here\n",
    "        app_syn = lesk(all_sent[len(all_sent)//2], word, pos)\n",
    "        if app_syn != None:\n",
    "            #print(\"here2\")\n",
    "            return app_syn\n",
    "        else:\n",
    "            #second lesk trial with another context sentence\n",
    "            app_syn = lesk(all_sent[len(all_sent)//3], word, pos)\n",
    "            if app_syn != None:\n",
    "                #print(\"here2\")\n",
    "                return app_syn\n",
    "            else:\n",
    "                #give up and choose 1st synset from list with matching pos\n",
    "                #print(\"here3\")\n",
    "                all_syns = wn.synsets(word)\n",
    "                for syn in all_syns:\n",
    "                    #print(syn.pos())\n",
    "                    if syn.pos() == pos:\n",
    "                        return syn\n",
    "    return False\n",
    "\n",
    "# this functions take all the single and double legth phrases form grand_list and gets sysnset for all them. (1 each)\n",
    "def get_singles_synset(uni_list,pos_tag_text):\n",
    "    single_synset =[]\n",
    "    #get synsets of all singletons\n",
    "    for singles in uni_list:\n",
    "        singles_syn = get_synset(singles,pos_tag_text, 'n')\n",
    "        if singles_syn:\n",
    "            single_synset.append(singles_syn)    \n",
    "    return single_synset\n",
    "\n",
    "#get common parents\n",
    "def get_lcs(uni_list,pos_tag_text):\n",
    "    #get all relevant sysnsets\n",
    "    all_synsets = get_singles_synset(uni_list,pos_tag_text)\n",
    "    list_of_all_lcs =[]\n",
    "    for syn in all_synsets:\n",
    "        for syn2 in all_synsets[all_synsets.index(syn)+1:]:\n",
    "            lcs = syn.lowest_common_hypernyms(syn2)\n",
    "            if len(lcs)> 0:\n",
    "                if lcs[0] not in list_of_all_lcs:\n",
    "                    list_of_all_lcs.append(lcs[0])\n",
    "    return list_of_all_lcs\n",
    "\n",
    "# get themes\n",
    "def get_theme(uni_list,pos_tag_text):\n",
    "    # get common parent\n",
    "    parent_sysnset = get_lcs(uni_list,pos_tag_text)\n",
    "    # filter out absolute top level and get lemma_names\n",
    "    lemma_names =[]\n",
    "    for synset in parent_sysnset:\n",
    "        if synset.min_depth() != 0:\n",
    "            #print(synset)\n",
    "            for each_name in synset.lemma_names():\n",
    "                if each_name not in lemma_names:\n",
    "                    lemma_names.append(each_name)\n",
    "                break\n",
    "    return lemma_names\n",
    "\n",
    "def get_cluster_count(document):\n",
    "    text = str(document['text'][0])\n",
    "    cleantext = get_document_text(text)\n",
    "    tagged_tokens = tag_my_text(tokenize_text_sent(cleantext))\n",
    "    np_list = noun_phrase_finder(tagged_tokens)\n",
    "    top_np = get_top_unigrams(np_list)\n",
    "    themes = get_theme(top_np,tagged_tokens)\n",
    "    return len(themes)"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 3,
   "metadata": {
    "collapsed": true
   },
   "outputs": [],
   "source": [
    "#Comment clustering\n",
    "def process_document(document):\n",
    "    comments = []\n",
    "    for c in document['comment_list']:\n",
    "        c = c.replace('\\n',' ')\n",
    "        if 'attached' in c and len(c) < 500:\n",
    "            pass\n",
    "        elif len(c) <200:\n",
    "            pass\n",
    "        else:\n",
    "            comments.append(str(c))\n",
    "    return comments\n",
    "\n",
    "# Modified from Brandon Rose:\n",
    "def tokenize_text_cluster(text):\n",
    "#     tokens = [word.lower() for sent in nltk.sent_tokenize(text) for word in nltk.word_tokenize(sent)]\n",
    "    # changing this to get rid of tokens like 's \n",
    "    tokens = [word.lower() for sent in nltk.sent_tokenize(text) for word in tokenize_text(sent)]\n",
    "    filtered_tokens = []\n",
    "    for token in tokens:\n",
    "        if len(token) > 2:\n",
    "            filtered_tokens.append(token)\n",
    "    return filtered_tokens\n",
    "\n",
    "# NOT USED ANYMORE!!\n",
    "# def stem_text(text):\n",
    "#     stemmer = SnowballStemmer('english')\n",
    "#     tokens = tokenize_text_cluster(text)\n",
    "#     stems = [stemmer.stem(t) for t in tokens]\n",
    "#     return stems\n",
    "\n",
    "def vectorize_comments(comments):\n",
    "    tfidf_vec = TfidfVectorizer(tokenizer=tokenize_text_cluster,\n",
    "                                stop_words='english',\n",
    "                                ngram_range=(1,4),\n",
    "                                min_df=0.2, max_df=0.8,\n",
    "                                max_features=200000)\n",
    "    tfidf_matrix = tfidf_vec.fit_transform(comments)\n",
    "    return tfidf_matrix, tfidf_vec\n",
    "\n",
    "def mash_comments(all_comments):\n",
    "    big_comment = []\n",
    "    for cluster in all_comments:\n",
    "        mashed = \"\"\n",
    "        for comment in cluster:\n",
    "            mashed += comment\n",
    "            mashed += \" \"\n",
    "        big_comment.append(mashed)\n",
    "    return big_comment\n",
    "\n",
    "# Adapted from: http://www.markhneedham.com/blog/2015/02/15/pythonscikit-learn-calculating-tfidf-on-how-i-met-your-mother-transcripts/\n",
    "def top_words(all_comments, n_top_words):\n",
    "    mashed_comments = mash_comments(all_comments)\n",
    "    tfidf_matrix, tfidf_vec = vectorize_comments(mashed_comments)\n",
    "    feature_names = tfidf_vec.get_feature_names()\n",
    "    dense = tfidf_matrix.todense()\n",
    "    top_words = []\n",
    "    for i in range(0,len(mashed_comments)):\n",
    "        cluster = dense[i].tolist()[0]\n",
    "        word_scores = [pair for pair in zip(range(0, len(cluster)), cluster) if pair[1] > 0]\n",
    "        sorted_word_scores = sorted(word_scores, key=lambda t: t[1] * -1)\n",
    "        temp_top_words = []\n",
    "        for word, score in [(feature_names[word_id], score) for (word_id, score) in sorted_word_scores][:n_top_words]:\n",
    "            temp_top_words.append(word)\n",
    "        top_words.append(temp_top_words)\n",
    "    return top_words\n",
    "\n",
    "def cluster_comments(document, num_clusters):\n",
    "    cluster_dict = {}\n",
    "\n",
    "    comments = process_document(document)\n",
    "    tfidf_matrix, tfidf_vec = vectorize_comments(comments)\n",
    "    \n",
    "    km = KMeans(n_clusters=num_clusters)\n",
    "    km.fit(tfidf_matrix)\n",
    "    clusters = km.labels_.tolist()\n",
    "    \n",
    "    cluster_center_list = []\n",
    "    for c in clusters:\n",
    "        cluster_center_list.append(km.cluster_centers_[c])\n",
    "    center_distances = paired_distances(tfidf_matrix, cluster_center_list)\n",
    "    \n",
    "    comment_clusters = {'comment': comments, 'cluster': clusters, 'dist': center_distances}\n",
    "    comment_frame = pd.DataFrame(comment_clusters, index = [clusters] , columns = ['comment', 'cluster', 'dist'])\n",
    "    \n",
    "    central_comments = []\n",
    "    all_comments = []\n",
    "    for i in range(num_clusters):\n",
    "        central_comments.append(comment_frame[comment_frame.cluster==i].min().comment)\n",
    "        all_comments.append(list(comment_frame[comment_frame.cluster==i]['comment']))\n",
    "    \n",
    "    tfidf_words = top_words(all_comments, 6)\n",
    "    \n",
    "    cluster_dict['central_comments'] = central_comments\n",
    "    cluster_dict['all_comments'] = all_comments\n",
    "    cluster_dict['top_words'] = tfidf_words\n",
    "    \n",
    "    return cluster_dict"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 54,
   "metadata": {
    "collapsed": false
   },
   "outputs": [],
   "source": [
    "doc_list =load(open(\"data/Master2_doc_content\",'rb'))\n",
    "document = doc_list[4]"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 67,
   "metadata": {
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   },
   "outputs": [
    {
     "name": "stdout",
     "output_type": "stream",
     "text": [
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n"
     ]
    }
   ],
   "source": [
    "cluster_num = get_cluster_count(document)"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 49,
   "metadata": {
    "collapsed": false
   },
   "outputs": [],
   "source": [
    "clust_dict = cluster_comments(document, cluster_num)"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 20,
   "metadata": {
    "collapsed": false
   },
   "outputs": [
    {
     "data": {
      "text/plain": [
       "dict_keys(['central_comments', 'all_comments', 'top_words'])"
      ]
     },
     "execution_count": 20,
     "metadata": {},
     "output_type": "execute_result"
    }
   ],
   "source": [
    "clust_dict.keys()"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 21,
   "metadata": {
    "collapsed": false,
    "scrolled": true
   },
   "outputs": [
    {
     "name": "stdout",
     "output_type": "stream",
     "text": [
      "\n",
      "\n",
      "\n",
      "\n",
      "\n",
      "-------------------------------------------------------------\n",
      "\n",
      "\n",
      "\n",
      "\n",
      "        Crowe Horwath LLP  Independent Member Crowe Horwath International     April 26, 2010   Internal Revenue Service  CC:PA:LPD:PR (REG -134235 -08)  Room 5205  P.O. Box 7604, Ben Franklin Station  Washington, DC 20044    Submitted  Electronically:   www.regulations.gov  RE: Crowe Horwath LLP comments regarding notice of proposed  rulemaking on furnishing  identifying number of tax return preparer   I am writing on behalf of Crowe Horwath, LLP  to  respond to your request for comments  on  proposed rulemaking  that was  published in the Federal Register on March 26, 2010 , which   proposes gui dance for tax return preparers on furnishing an identifying number with tax  returns and refund claims being filed.   In general, we support the concept of exclusively using the preparer tax identification number  (PTIN) to identify those  signing  tax returns.   Our firm has  fully  adopted the use of PTINs as the  identifier of return signers in lieu of the ir  social security number . The procedure protects  the  privacy of our signers.   In addition, we agree that the use of a dedicated identifying number for   preparer s is a sensible way for the IRS to track those providing tax services and to identify   problem areas with specific practitioners effectively.     Notwithstanding our general support , we do have  significant  concerns  with certain portions of  the proposed rulemak ing, and respectfully offer our thoughts and suggestions as follows:   1.  Non -signing preparer  PTIN registration  responsibilities:   Prop. Reg. section 1.6109 -2(g),  including examples  2 and 3 , call s for the PTIN requirements to extend to tax  professionals who work as part of a team that prepares a tax return, but who do not   ultimately sign the tax return.  We believe that this application of the PTIN rules is   unnecessarily expansive.  Most practition ers use duties such  as initial  return  preparation, client data collection, and routine tax law research  as the main method  to  train  inexperienced staff.  A requisite in this process is that there are layers of  professionals involved that can provide increa sed knowledge and experience,   culminating in final review and signing of the tax return.   The  person who signs the tax  return takes the ultimate responsibility for any preparer -related issues.  Furthermore,  the requirement that the firm name and  Employer I dentification Number ( EIN ) be  furnished gives further clarity of responsibility.     Internal Revenue Service  April 26, 2010  Page  2   A requirement that non -signing members of the preparation team  who are working  under a  Certified Public Accountant ( CPA ), Enrolled Agent ( EA), or attorney  maintain a  PTIN,  coupled with the potential that those who have not  yet  met  CPA, EA, or Bar  requirements will be subject to additional requirements for PTIN acceptance , will put an  unnecessary burden on professionals who are new to the profession and functioning in a   supp orting role.  In many cases,  the suggested  requirement  of competency testing and  education  will be superfluous, because those professionals  are already studying for the  CPA examination or the enrolled agent examination , and receiving tax education .     Another concern is how a requirement for non -signing preparers would  be monitored.   It seems impractical to document PTIN™s of all involved parties  on the actual  filed tax  return.  However , absent  such an approach, it would be difficult for the IRS to moni tor  compliance because there is no way  to prove  the specific team and responsibilities of  people working on the return.   Collection of the  firm name, EIN, and PTIN of the signer should give a clear picture of  accountabil ity for a particular tax return, the refore satisfying the goals of this proposed  rulemaking  without the  costly requirement to hold  non -signing team members  to the  PTIN requirements .  2. Creation of the title ﬁregistered return preparerﬂ :  Prop. Reg. section 1.6109 -2(d)  (expanded upon in the preamble) proposes a new  title  to assign to those receiving  PTINs : registered return preparer.     This  title  would presumably cover  tax preparers  who sign returns, but are not a CPA, lawyer, or  EA.  It is our position that this  new ti tle  creates  an unnecessary complication that will result in confusion to taxpayers.  The tax  preparation community and the IRS have long recognized that  designation as a  CPA , attorney, or  EA indicate s competence  in the area of tax preparation.  Furthermore , their  respective professional organizations provide  guidelines to  ensure competence, ethics  and continuing professional education.  In particular, the  EA designation was created by  the IRS and is administered by the IRS.  Rather than creating a new class  of professional,  the IRS should consider whether the  EA designation could be modified to encompass  the subset of tax preparers who are currently falling outside of the  three  existing  designations.  This would also serve to provide a framework for assuranc e of regular  education, since each of these designations carries continuing education requirements.   3. Int roduction of potential testing and education requirements.   The preamble to the  proposed rulemaking suggests the possibility of new testing and educatio n requirements.  C reation of new requirements will be redundant  with  what is common  practice among many tax preparers  and within the  EA program .  Most reputable firms  within the practitioner community recognize the benefit of continuing education from  the  day a person starts working in the tax compliance area.  Consideration should be  given to the suggestion above to make the PTIN requirements in this area the same as   those required for an  EA.  Furthermore, if a firm requires by policy that all professional s receive a level of tax education that is the same or greater than the amount required for   an  EA, that preparer should be relieved of any additional education requirements  and  the firm shou ld not need to monitor against another set of criteria . Internal Revenue Service  April 26, 2010  Page  3   4. Introduct ion of a user fee and renewal requirements.   Prop. Reg. section 1.6109 -2(e) (expanded upon in the preamble) proposes  renewal requirements and a user fee to be  assessed to preparers.  Renewal seems unnecessary  for CPAs, attorneys, and EAs  given  that  each designation currently has a specific renewal and examination process in place  to certify that practitioners are meeting the relevant educational and competency   requirements.  Additionally,  the IRS will be furnished with each signer™s PTIN within   the t ax return which will allow them to query for specific issues and review preparer  compliance.  Renewal responsibility  and fees  will cause  a burden on firms who will need  to establish  new  reimbursement programs for employees , add ing  administration and  cost t o operations, ultimately translating to higher fees for tax compliance.       The goals of the PTIN program  can  be accomplished through a monitoring system that  should be further enabled by increased electronic filing.   Recent law changes require   most firms t o begin filing all individual returns electronically, starting next year.   Therefore, d ata should be available for query to the  Service so that preparers can be  tracked without the need for renewal.   Furthermore, fees should be unnecessary to the  extent th at the PTIN requirements simply capitalize on the current program for  obtaining numbers.    Thank you for the opportunity to comment on this proposed rulemaking.  Ultimately, rules that   hold practitioners accountable are good for those in the profession that  prepare returns with  adequate training and  due diligence.  We respectfully request that as you establish such rules   and procedures, you do it in a way that allows unqualified practitioners to be identified and   dealt with, but not at the cost of creating a dditional cost and complication for those who have a  proven track record of educating and policing themselves.    Sincerely,         Louis J. Miller  Partner in Charge    Crowe Horwath  National Tax Office   \n",
      "\n",
      "\n",
      "\n",
      "\n",
      "-------------------------------------------------------------\n",
      "\n",
      "\n",
      "\n",
      "\n"
     ]
    }
   ],
   "source": [
    "for i in clust_dict['central_comments']:\n",
    "    print(i)\n",
    "    print('\\n')\n",
    "    print('\\n')\n",
    "    print('-------------------------------------------------------------')\n",
    "    print('\\n')\n",
    "    print('\\n')"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 10,
   "metadata": {
    "collapsed": false
   },
   "outputs": [
    {
     "data": {
      "text/plain": [
       "[['canadian',\n",
       "  'required carry',\n",
       "  'real safety',\n",
       "  'real safety means',\n",
       "  'safety means',\n",
       "  'enhance security'],\n",
       " ['nata',\n",
       "  'student pilot',\n",
       "  'cessna',\n",
       "  'design',\n",
       "  'student pilot certificates',\n",
       "  'design color'],\n",
       " ['pilots license',\n",
       "  'photo pilot license',\n",
       "  'photo drivers license',\n",
       "  'photo pilots license',\n",
       "  'license good',\n",
       "  \"isn't\"],\n",
       " ['department state',\n",
       "  'approach',\n",
       "  'air commerce',\n",
       "  'commerce',\n",
       "  'analysis',\n",
       "  'passcard'],\n",
       " ['student pilot',\n",
       "  'application',\n",
       "  'nafi',\n",
       "  'pilot certificate photo',\n",
       "  'student pilot certificate',\n",
       "  'applicant']]"
      ]
     },
     "execution_count": 10,
     "metadata": {},
     "output_type": "execute_result"
    }
   ],
   "source": [
    "clust_dict['top_words']"
   ]
  },
  {
   "cell_type": "markdown",
   "metadata": {},
   "source": [
    "## Write to Json"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 68,
   "metadata": {
    "collapsed": true
   },
   "outputs": [],
   "source": [
    "data = []"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 12,
   "metadata": {
    "collapsed": true
   },
   "outputs": [],
   "source": [
    "doc_list1 =load(open(\"data/Master_doc_content\",'rb'))\n",
    "doc_list2 = load(open(\"data/Master2_doc_content\",'rb'))"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 13,
   "metadata": {
    "collapsed": true
   },
   "outputs": [],
   "source": [
    "doc_id1 = [\"FAA-2010-1127-0001\",\"USCBP-2007-0064-1986\",\"FMCSA-2015-0419-0001\",\"NARA-06-0007-0001\",\"APHIS-2006-0041-0001\",\"EBSA-2012-0031-0001\",\"IRS-2010-0009-0001\",\"BOR-2008-0004-0001\",\"OSHA-2013-0023-1443\",\"DOL-2016-0001-0001\",\"NRC-2015-0057-0086\",\"CMS-2010-0259-0001\",\"CMS-2009-0008-0003\",\"CMS-2009-0038-0002\",\"NPS-2014-0005-000\",\"BIS-2015-0011-0001\",\"HUD-2011-0056-0019\",\"HUD-2011-0014-0001\",\"OCC-2011-0002-0001\",\"ACF-2015-0008-0124\",\"ETA-2008-0003-0001\",\"CMS-2012-0152-0004\",\"CFPB-2013-0033-0001\",\"USCIS-2016-0001-0001\",\"FMCSA-2011-0146-0001\",\"USCG-2013-0915-0001\",\"NHTSA-2012-0177-0001\",\"USCBP-2005-0005-0001\"]\n",
    "doc_id2 = [\"HUD-2015-0101-0001\",\"ACF-2010-0003-0001\",\"NPS-2015-0008-0001\",\"FAR-2014-0025-0026\",\"CFPB-2013-0002-0001\",\"DOS-2010-0035-0001\",\"USCG-2013-0915-0001\",\"SBA-2010-0001-0001\"]"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 14,
   "metadata": {
    "collapsed": true
   },
   "outputs": [],
   "source": [
    "doc_title1 = [\"Photo Requirements for Pilot Certificates\",\n",
    "             \"Advance Information on Private Aircraft Arriving and Departing the United States\",\n",
    "             \"Evaluation of Safety Sensitive Personnel for Moderate-to-Severe Obstructive Sleep Apnea\",\n",
    "             \"Changes in NARA Research Room and Museum Hours\",\n",
    "             \"Bovine Spongiform Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products Derived From Bovines\",\n",
    "             \"Incentives for Nondiscriminatory Wellness Programs in Group Health Plans\",\n",
    "             \"Furnishing Identifying Number of Tax Return Preparer\",\n",
    "             \"Use of Bureau of Reclamation Land, Facilities, and Waterbodies\",\n",
    "             \"Improve Tracking of Workplace Injuries and Illnesses\",\n",
    "             \"Implementation of the Nondiscrimination and Equal Opportunity Provisions of the Workforce Innovation and Opportunity Act\",\n",
    "             \"Linear No-Threshold Model and Standards for Protection Against Radiation; Extension of Comment Period\",\n",
    "             \"Medicare Program: Accountable Care Organizations and the Medicare Shared Saving Program\",\n",
    "             \"Medicare Program: Changes to the Competitive Acquisition of Certain Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) by Certain Provisions of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA)\",\n",
    "             \"Medicare Program: Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2010 \",\n",
    "             \"Special Regulations: Areas of the National Park System, Cuyahoga Valley National Park, Bicycling\",\n",
    "             \"Wassenaar Arrangement Plenary Agreements Implementation; Intrusion and Surveillance Items\",\n",
    "             \"Credit Risk Retention 2\",\n",
    "             \"FR 5359–P–01 Equal Access to Housing in HUD Programs Regardless of Sexual Orientation or Gender Identity \",\n",
    "             \"Credit Risk Retention\",\n",
    "             \"Head Start Performance Standards; Extension of Comment Period\",\n",
    "             \"Senior Community Service Employment Program\",\n",
    "             \"Patient Protection and Affordable Care Act: Benefit and Payment Parameters for 2014\",\n",
    "             \"Debt Collection (Regulation F)\",\n",
    "             \"U.S. Citizenship and Immigration Services Fee Schedule\",\n",
    "             \"Applicability of Regulations to Operators of Certain Farm Vehicles and Off-Road Agricultural Equipment\",\n",
    "             \"Carriage of Conditionally Permitted Shale Gas Extraction Waste Water in Bulk\",\n",
    "             \"Federal Motor Vehicle Safety Standards: Event Data Recorders\",\n",
    "             \"Documents Required for Travel Within the Western Hemisphere\"]\n",
    "doc_title2 = [\"FR 5597-P-02 Instituting Smoke- Free Public Housing\",\n",
    "             \"Head Start Program\",\n",
    "             \"Off-Road Vehicle Management: Cape Lookout National Seashore\",\n",
    "             \"Federal Acquisition Regulations: Fair Pay and Safe Workplaces; Second Extension of Time for Comments (FAR Case 2014-025)\",\n",
    "             \"Ability to Repay Standards under Truth in Lending Act (Regulation Z)\",\n",
    "             \"Schedule of Fees for Consular Services, Department of State and Overseas Embassies and Consulates\",\n",
    "             \"Carriage of Conditionally Permitted Shale Gas Extraction Waste Water in Bulk\",\n",
    "             \"Women-Owned Small Business Federal Contract Program\"]"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 69,
   "metadata": {
    "collapsed": false,
    "scrolled": true
   },
   "outputs": [
    {
     "name": "stdout",
     "output_type": "stream",
     "text": [
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      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "14\n",
      "Warning: parsing empty text\n",
      "15\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
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      "Warning: parsing empty text\n",
      "16\n",
      "17\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
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      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "18\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
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      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
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      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
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      "19\n",
      "Warning: parsing empty text\n",
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      "20\n",
      "Warning: parsing empty text\n",
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      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "21\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
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      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
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      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "22\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "23\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "24\n",
      "25\n",
      "26\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "27\n",
      "Warning: parsing empty text\n"
     ]
    }
   ],
   "source": [
    "for i in range(len(doc_list1)):\n",
    "    print(i)\n",
    "    document = doc_list1[i]\n",
    "    cluster_num = get_cluster_count(document)\n",
    "    if cluster_num < 2:\n",
    "        cluster_num = 2\n",
    "    clust_dict = cluster_comments(document, cluster_num)\n",
    "    clust_dict[\"doc_id\"], clust_dict[\"doc_title\"] = doc_id1[i], doc_title1[i]\n",
    "    data.append(clust_dict)"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 70,
   "metadata": {
    "collapsed": false,
    "scrolled": true
   },
   "outputs": [
    {
     "name": "stdout",
     "output_type": "stream",
     "text": [
      "0\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "1\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "2\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "3\n",
      "4\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "5\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
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      "Warning: parsing empty text\n",
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      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
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      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "6\n",
      "7\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n",
      "Warning: parsing empty text\n"
     ]
    }
   ],
   "source": [
    "for i in range(len(doc_list2)):\n",
    "    print(i)\n",
    "    document = doc_list2[i]\n",
    "    cluster_num = get_cluster_count(document)\n",
    "    if cluster_num < 2:\n",
    "        cluster_num = 2\n",
    "    clust_dict = cluster_comments(document, cluster_num)\n",
    "    clust_dict[\"doc_id\"], clust_dict[\"doc_title\"] = doc_id2[i], doc_title2[i]\n",
    "    data.append(clust_dict)"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 82,
   "metadata": {
    "collapsed": false
   },
   "outputs": [
    {
     "data": {
      "text/plain": [
       "36"
      ]
     },
     "execution_count": 82,
     "metadata": {},
     "output_type": "execute_result"
    }
   ],
   "source": [
    "len(data)"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 76,
   "metadata": {
    "collapsed": true
   },
   "outputs": [],
   "source": [
    "top_obj ={}\n",
    "top_obj[\"data\"] = data"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 77,
   "metadata": {
    "collapsed": true
   },
   "outputs": [],
   "source": [
    "with open('data/comment_data.json', 'w') as outfile:\n",
    "    json.dump(top_obj, outfile)"
   ]
  },
  {
   "cell_type": "markdown",
   "metadata": {},
   "source": [
    "# BEGIN TESTING"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 2,
   "metadata": {
    "collapsed": false
   },
   "outputs": [],
   "source": [
    "with open('data/comment_data2.json') as comment_data_file:    \n",
    "    op_data = json.load(comment_data_file)"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 3,
   "metadata": {
    "collapsed": false
   },
   "outputs": [
    {
     "data": {
      "text/plain": [
       "34"
      ]
     },
     "execution_count": 3,
     "metadata": {},
     "output_type": "execute_result"
    }
   ],
   "source": [
    "len(op_data[\"data\"])"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 6,
   "metadata": {
    "collapsed": false
   },
   "outputs": [],
   "source": [
    "def mash_comments(cluster_dict):\n",
    "    big_comment = []\n",
    "    for cluster in cluster_dict[\"all_comments\"]:\n",
    "        mashed = \"\"\n",
    "        for comment in cluster:\n",
    "            mashed += comment\n",
    "            mashed += \" \"\n",
    "        big_comment.append(mashed)\n",
    "    return big_comment"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 7,
   "metadata": {
    "collapsed": true
   },
   "outputs": [],
   "source": [
    "mashed = mash_comments(op_data[\"data\"][0])"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 8,
   "metadata": {
    "collapsed": false
   },
   "outputs": [
    {
     "data": {
      "text/plain": [
       "['If the proposed financial Impact to a CFI is $210 every 2 years, in addition to the other financial impacts to CFI\\'s currently, I seriously doubt I will maintain my certificate, and feel I will not be alone. The CFI will be a dying breed. Once dead, so will pilot startups and thus the need for the FAA. Your call.  Dear Sir,  A photo incorporated into the plastic pilot certificate would seem to be redundant and unnecessary.  States require a photo ID for driver\\'s licenses, which should be sufficient to identify a pilot in conjunction with the pilot certificate.  Instead of cluttering the plastic card with superfluent visual data, perhaps a better suggestion would be to increase the font size of the miniscule certificate number already on the plastic certificate.  Thank you for your time and attention.  Larry Bell I am in favor of having a photo on our pilot\\'s certificate.  That being said, I take issue with several of the proposals offered in this NPRM.  The first thing I take issue with is the requirement that CFI certificates have a photo on them.  This is redundant because the CFI certificate is only valid when accompanied by a commercial certificate, which should in theory  have a photo on it already.  The second reason I oppose this requirement is because CFI certificates expire every 24 months.  This would create a burden in increased cost to every flight instructor and a burden of increased cost and labor to the FAA. It just doesnt make sense.  The second thing I take issue with is the requirement for a photo on a new plastic student pilot certificate which would take 6-8 weeks to get.  This would hurt the accelerated flight training programs, as well as students who decide to learn to fly in late summer.  If it takes two months to get a new plastic student pilot certificate to solo, the winter season could delay solo until spring...the student may get frustrated and decide to move on other things further reducing our retention rate for pilots who make it from student pilot to private pilot.  Furthermore, we endorse the student pilot certificate for solo, and solo cross country privileges.  There is no provision or mention in this NPRM that would allow a CFI to endorse a plastic card. How would we endorse the back of it?  If the solution is to keep the paper medical/student pilot certificate for endorsements, we might as well just exempt the student pilot certificate from becoming a plastic license with a photo.  The last thing I think needs to be changed is the period a photo would be valid for.  The current proposal suggests 8 years, however I feel that it should be extended to 10 years which would make the photo valid for as long as a passport, which is an already accepted means of photo ID.  This would also reduce the cost and burden to pilots and the FAA. While this rule change may be well-intended,  I believe that the time, effort, and expense required to implement it make it not worth doing.  The added expense is not  just placed on pilots, but on the FAA itself:  The FAA has already expended time, effort, and funding to change the pilot certificate format to the current plastic certificates, and now it is proposing to change it again already?  I don\\'t think this is the best use of the FAA\\'s resources.  The effect on pilots will be deleterious as well, as this rule will effectively put an expiration date on all pilot certificates.  Also, many prospective pilots may be dissuaded from applying to be student pilots, as the process for obtaining a student pilot certificate will be fraught with delays and will become impractical.  The current process of using existing government-issued photo ID (such as a current driver\\'s license) and current FAA medical certificate is working well and should suffice.  Existing photo IDs such as driver\\'s licenses have to be updated periodically, so a current photo should always be in the pilot\\'s possession, making the addition of a photo to the pilot\\'s certificate unnecessary. Pilots are already bound by FAR 61.3(a)(2), which requires a pilot certificate holder to also have a valid photo ID in their possession. The entire U.S. pilot population already meets this requirement today, without any extra burden to them or to the agency. There is no reason for this rule to exist, especially for a certificate that almost nobody ever sees. Pilots already possess the new plastic certificates if they exercise the privileges of the certificates they hold. The idea that the fees pilots will pay are \"transfer payments\" with no economic impact is ridiculous. A CFI, with a Commercial certificate and a ground instructor certificate would have to pay three times under this ill advised scheme, taking real money out of their hands that could be otherwise spent in the real economy and adding it to government bureaucracy and accomplishing nothing useful in the real world. This proposal is poorly conceived, it hurts aviatiors and accomplishes nothing useful.  This proposed rule to require photos on pilot certificates is unnecessary.  The current rules require a pilot to carry along with the pilot certificate an ID that has a photo on it, such as a current state driver\\'s license.  This is completely redundant.  If a person\\'s pilot certificate matches the one with a photo ID then the result is the same as the proposed rule.  This proposed rule is only going to make things more expensive.  Why?  Stay with the current rules.  Why create more red tape?  It is time for government to be less intrusive.  It keeps growing like an out of control monster.    Please don\\'t create more bureaucracy.  Keep the requirement to have a pilot possess an official photo ID along with the pilot\\'s current certificate.  That accomplishes the same thing as the proposed rule without the additional costs. I submit that photos on pilot certificates does nothing to enhance security.  Furthermore, it is unneccesary and wasteful in time and money.   All U.S. FAA Certificated pilots carry state drivers licenses with photos which can be matched up with the pilot license in the rare instance where that might be necessary.  In 42-years and 13,000 hours of flying in general aviation, I have never been asked for my certificate except during a checkride or certificate renewal type of event. Nor has there been any cause or reason for anyone to check it.  A thief is not going to be deterred from stealing an airplane because he does not have a photo ID. There is nothing positive to be accomplished by having a photo-ID pilot certificate. I believe photo requirements for pilot certificates would make the certificate holder seem more credible. The certificate is a piece of plastic with information pertaining to the certificate holder such as name, address, certificate type, and birthday. In order to prove the certificate actually belongs to you, you\\'d need to show a government issued photo ID. With a photo on the holder\\'s certificate, this shouldn\\'t be an issue anymore. However, another issue does arise. The process in which students receive their certificates already takes a few months to come in the mail. With a photo ID added to the certificate, this would prolong the time period in which the student receives his/her certificate in the mail thus prolonging the time the student uses a temporary certificate which is even less credible and secure than the certificates pilots hold now.  The proposal to add a photo to a pilot certificate is redundant and unnecessary. Pilots are already required to carry a valid government issued photo ID whenever exercising the rights of their certificate. This already meets the intended purposes of the Intelligence Reform and Terrorism Prevention Act. Adding a photo to the pilot certificate does nothing to increase security nor safety. It only creates added cost and a burdensome process for submitting the photos.  I am very concerned with the impact this will have on student pilots. Many students will be ready to solo in less than the 6-8 weeks they must wait for a student certificate. Flight training is already going through significant struggles with low start and completion rates. Anything else that will negatively impact flight training must be avoided. The students should continue to obtain a photo-less student certificate from the AME. This is the easiest and least costly method for all involved. The student is consistently with their instructor who is already required to validate their identity. There is no reason to change the student certificate process.  If this wasteful regulation is implemented and photos are added to the pilot certificates, they should expire in 10 years just like a passport. The pilot should not bear the cost of this additional burden. If the FAA wants to implement redundant and meaningless regulations, they should absorb the cost for at least the initial issuing. This proposal is a burden on the FAA, pilots and the DPEs. Nothing is gained from this proposal (except more fees) and it should be abandoned. I am not opposed to a photo on the certificate.  However, it seems to me like a back-door method of increasing fees (whata bonus).  Whatever you do, when you redesign the certificate, INCREASE THE FONT SIZE for important fields like the certificate number.  The current certificate has tons of unused space, yet tiny impossible to read text.  Small text on a dark background is VERY difficult to read. In principle, I am in favor of including a photo on a pilot certificate, and removing the requirement of carrying a separate photo ID with the pilot certificate while exercising the certificate\\'s privileges. My concern is the fee for the ID processing. A reasonable fee comparable to a state\\'s drivers license renewal is acceptable. As with the aircraft re-registration and the associated re-registration fee, If this fee becomes a costly backdoor tax levied upon holders of pilot certificates and/or owners of aircraft particularly GA aircraft that\\'s another issue. I have no opinion one way or another on the requirement to go to the FSDO for the initial photo, as I reside a reasonable distance from the Indianapolis FSDO.  The FAA should work with the Department of Homeland Security and the Transportation Security Administration and allow this photo version of the FAA pilot certificate become acceptable as a form of \"government ID\" presentable for passage by TSA, and for TSA to consider holders of FAA pilot certificates as vetted and trusted for security purposes. I echo the AOPA\\'s sentiments this photo enhanced pilot certificate should be an acceptable credential for passage onto secured airfields in accordance with TSA security directive 8G. The current regulation is sufficient.  This new requirement would add cost to the government with no benefit.  I am a pilot and have never displayed my certificate to any official other than my flight instructor.  This regulation is a solution looking for a problem.  Thanks, CP Docket No. FAA-2010-1127  -  Photo Requirements for Pilot Certificates  Like most American’s I welcome security where it makes sense.  This makes no sense.    Assuming that the objective of recent security measures still is to reduce the access of terrorists to aircraft, someone of rational mind at 800 Independence Avenue should realize that there is essentially no relationship between a pilot certificate, with or without a picture, and a pilot flying an airplane any more than there is between having a drivers license and driving a car.  Terrorists who know how to fly have no need for pilot certificates with or without pictures.  How could anyone actually believe that a pilot certificate with a picture can limit a terrorist’s access to a an aircraft?  I can’t believe that adding a picture to a pilot certificate has anything to do with security.  There is nothing to be gained here by wasting the time and money of both the government and the pilot community on such an ineffective requirement. The CFI Certificate states that it is not valid, unless accomjpanied by the bearer\\'s Pilot certificate, which, according to this proposal would have the picture.  Therefore, there should be no reason to subject the CFI every two years to provide a picture, quadrupling the cost, visavis a Pilot Certificate (8 Years) and create the other expenses and inconveniencede involved, as well as the work load and expenses incured by the FAA in this totally unnecessary process. With respect to the proposed photo identification addition to the pilot certificate, I would strongly suggest that the well established 10 year expiration term of the Unites States Passport be used in lieu of the proposed 8 year expiration as proposed in the rule.  I would also strongly suggest that student pilot certificates be exempt from the requirement in their entirety as a means of encouraging a larger student population, suggesting that a valid state identification form such as a drivers license or a valid United States identification form passport or valid military Id is sufficient until such time as the pilot certificate is granted at the sport or private level.  Lastly I strongly suggest that the cost of exchanging a certificate to one with a photo or updating a photo on an existing certificate be limited to a one time processing fee not to exceed $25, and that no fee be charged when additional privileges or ratings are added to the certificate.  Thank you for your consideration  Michael Anthony  Damiano AOPA Member Number 05536058 Certificated Pilot ASEL I do not understand the reason for the requirement for a picture on the certificate.  I have been flying for over 46 years( Fix wing Commercial Rotor Wing / Instrument , A & P  IA) and have to show my certificate only one time and this was in Germany. Ther was an Airport check by the German Luftfart officials. What differance does if there is a picture onte piece of paper or not. Is it just because someone thinks that it would be cool to have it or is there some other reason. Should we also have it on our Mel\\\\dical and ever other piece of paper.  A & P Maintenance and the IA Certificate? What is the POINT? Just another cost for doing business.  Thanks  Cy Russum This rule does not address combining other certificates. All FAA authorizations, certificates, and licenses that a person may hold should be on one certificate to make it more cost effective. This rule should also include provisions for an Aviation Medical Examiner to update the Medical status electronically and do away with the paper medical certificate. When the FAA Certificate is swiped it can bring up the medical certificate of the holder. This rule does nothing to increase security or safety, but would make it more convenient for FAA certificate holders. Any physical certificate, anywhere, anytime can be forged. It also relies on too many people to be forthright in their intentions. A group with one legitimate person who happens to be a DPE could put forth anyone for a certificate. The DPE system is already corrupt enough without adding a National Security badge to their control. Student pilot certificates should remain as they are, and have specific expiration dates. This keeps small flight schools in business by keeping students coming back. Small schools cannot afford this burden. Most of the best ones are operating on a break-even basis in the first place. Considering that we recently changed from paper to plastic, removed our SSN\\'s to get a certificate number, and then documented english proficiency; these agencies can dream up any number of requirements to cause creation of a new certificate.  If required by the governing authority, use the existing tax base to fund it.  This is an end-around to another user fee - just like registration renewal.  As frequently as I am asked for my certificate (generally at Flight review time), I am also performing a transaction which requires an ID...which I already have.  This provides no added benefit.   As for neutral costs - $25-$50 out of my pocket for something that provides no additional benefit is a farce.  As for no additional expense to renew a certificate, it will cost me to drive to the FSDO office - or airport....and/or cost all of the taxpayers to provide FSDO offices at each airport - will we put FSDO offices at each overseas airport to support US certificate holders in foreign countries? Please consider deleting the proposed rulemaking requiring pilots to obtain a photo ID.  I believe that the current rule requiring individuals to carry a government-issued photo identification in addition to their pilot certificate is adequate. A photo on the pilot certificate is simply a duplication of effort, especially for those of us who hold multiple, unique certificates.  Thank you for your consideration,  Chris Reeder Lincoln, CA The present systerm of using a current  automobile drivers license with current picture along with the new plastic FAA issued airman certificate accomplishes the same purpose as getting a new pilot certificate with an expiration date.  Your present airman certificate expires with the expiration date of medical.    Avoid added cost with purposed ruling, FAA-2010-1127 The proposed cost to pilots\\'s from this rule does not address total associated costs which I believe will be much higher and lacks substantive benefits over the current requirement to have a valid photo id for current license to be valid.  In addition, the recurring costs for flight instructors to renew their photo-id licenses every two years is totally unnecessary and cost prohibitive. The CFI certificate is not valid without a pilot certificate so what is the benefit of having an additional photo on it ? If a valid photo id is good enough to board a commercial aircraft it should be good enough to pilot a private aircraft. The use of an \"FAA photo-id\" will not result in any increase in aviation safety. As a CFI I have to provide a valid photo id every time I renew and having three photo id\\'s in my possession (four if I have my passport) will do nothing to enhance safety but a lot to reduce my bank account. If we must have a photo on our pilot certificate why not have it done at the same time we renew our state drivers license ? There would be little increased cost to have state forward picture to FAA at that time and you would not need a third party to verify identity.  In any case please drop requirement for additional photo on CFI certificate.  Of course part of this problem would be minimized if you had followed up on past proposal to make CFI certificate perminate with log book renewal instead of cost of issuing new certificate every two years. This requirement (I understand that FAA is responding to a Congressional mandate) is a huge waste of time and money for no discernable return.  I suspect most pilots, myself included, have never been asked to show their pilot certificate except when testing for a new certificate or rating, or possibly during the investigation of an accident or incident.  Therefore, the first question that needs an answer regarding this rule is, \"Who will look at the picture on the new license, and for what purpose?\"  It seems to me the procedure in the current regulation will satisfy any reasonable need for identification of a pilot.  As a flight instructor and part owner of a small flight school, I believe the need for student pilots to comply with this regulation at the beginning of their flight training program will discourage more than a few students from beginning training.  Many of our students start training in order to determine whether they have the apptitude and sufficient interest to obtain a pilot certificate.  They don\\'t want to spend money for a student certificate they may need in six to eight weeks, or may never need.  (This will also be a problem for the FAA since they\\'ll have a significant number of these certificates on the books indefinitely--at least eight years--even though the students have long since abandoned their flying aspirations.)   Student pilot certificates ARE different.  If this rulemaking procedes, it makes no sense at all to require all these paper photos to be mailed about the country.  The FAA should, from the beginning, implement one of the options for digital submission to reduce the costs and to expedite the application process.  The requirement to add a picture to the pilot certificate adds nothing to safety or security over that which is required now- that a government issued picture ID be carried in addition to one\\'s pilot certificate.  The proposal simply adds an additional cost on pilots, more hassle obtaining a photograph, plus the cost of the certificate as well as the cost of the photo which I assume the pilot will bear also.  If law enforcement cannot determine identity under the current requirements, adding a picture to the pilot certificate will do nothing to enhance their ability to establish identity. It was suggested by The AOPA that I send this suggestion to you. I understand the need for a picture on a Pilot Certificate. But to me it would make more sence and Policed more effficantly if it was on the Medical Certificate. The Aviation Doctor would be responsable for any fraud, plus pictures would be up to date from six months to five years based on Medical Certificate length. Student pilots would also be covered. Along with any rapid aging of older pilots. But you must have the Medical to fly anyway. So the Medical card should turn into a plastic card. with all current info on the card with any futureinfo  additions to the Medical card. The state of U.S. aviation is very fragile.  The total estimated cost to the public of $718.7 Million over 20 years is unacceptable.  Furthermore, because the FAA cannot control what a contractor charges they cannot effectively estimate this final cost.    The ancillary effects of this regulation on new pilot starts, training costs and re-licensing time lost will be disastrous.  The added burden on FAA Flight Standards District Offices (FSDO) will likewise be untenable.  Large increases in FAA staff will be required, as will a new contractor bureaucracy to process photographs.     There is a more practical solution that is already in place - the pilot’s Medical Certificate.  It would be easier and cost-effective to incorporate the photo requirements of IRTPA Section 4022 into the annual pilot Medical Certification for the following reasons:   1.  The Airman’s Medical Certificate must be carried in persona and is, for all intents and purposes part of the pilot\\'s license documents.  Adding a photograph would satisfy the requirements of Section 4022 of the IRTPA.  2.  Unlike the Airman’s Pilot Certificate, the Medical Certificate renewal format has already been adopted electronically it would be relatively easy to include a digital photo, simply by installing a webcam on each Flight Surgeon’s computer.  3.  Because the subject pilot is personally known to the Flight Surgeon, no additional verification bureaucracy would be necessary.  4.  Finally, as presently constructed the paper Medical Certificate is easily tampered with and this added degree of securitization could be accomplished at little or no cost.  As a pilot and owner of a small business I ask you to please consider these comments.  I do not understand the reason for the requirement for a picture on the certificate.  I have been flying for over 46 years( Fix wing Commercial Rotor Wing / Instrument , A & P  IA) and have to show my certificate only one time and this was in Germany. Ther was an Airport check by the German Luftfart officials. What differance does if there is a picture onte piece of paper or not. Is it just because someone thinks that it would be cool to have it or is there some other reason. Should we also have it on our Mel\\\\dical and ever other piece of paper.  A & P Maintenance and the IA Certificate? What is the POINT? Just another cost for doing business.  Thanks  Cy Russum Do not fix something that is not broken at a high cost to FAA and pilots. Recommend using picture ID that is on drivers license, military ID, credits card etc to verify the holder of the pilot certificate when and if it is necessary AT NO COST TO ANYONE. In itself, the proposed rule making is not unexpected or unwarranted.  I just wanted to add that seeing as pilot certificate is being revamped, one should have an accurate representation of the major contributors depicted on the certificate, the Wright brothers were not solely responsible for the inception, development and eventual flight of their historic aircraft.  Charles (Charley) W. Furnas (1880 – 16 October 1941) actually built the engine that powered those early birds and it would be fitting to have him represented on the certificate along with the Wrights.  At the moment, pilot and mechanic certificates are the same and it would be fitting to commemorate both mechanic and aviator on said certificate. It is inappropriate to demand that individual pilots pay for a 2nd new Certificate, now requiring a photo.  Pilot certificates have been good for life at the current fee structure.  Now, pilots have been forced to obtain a plastic certificate, which I had to repolace because the ink rubbed of the certificate, making it difficult to verify my name.  Now, we will be required to pay for another certificate with a photo.  If the FAA wishes to demand this change to photo certificates, the governement needs to bear the cost burden for terrorosm protection, not individual pilots.  The cost of initial issue to those pilots already possessing a certificates should be paid by the FAA.  In addition, the cost of further replacement certificates because the design and materials of the new certificate are inappropriate for being carried in a wallet, should also be borne by the FAA since the FAA requires a pilot to have the certificate on his/her person. We feel that pilot certificate security is important in ensuring a safe aviation environment in the United States.  We do not feel that pilots and especially flight instructors should be subjected to unreasonable fees to amend a system that is currently working.  The FAA currently requires that pilots maintain a valid state issued driver\\'s license or other official form of photo ID.  Adding a photo to the pilot\\'s certificate is overkill.  Requiring that a picture also be added to to CFI certificates (which must be reissued every 2 years) is an undue burden on the flight instructor community.  If pilot certificates must bear a photo on them, at the very least, flight instructors certificates should not.  Since a flight instructor certificate is not valid without a corresponding pilot certificate (which would carry a photo under the provisions of this rule), there is no need to require that the flight instructor certificate also carry a photo.  If you have any questions please call or email.  Take care.  Be safe. The pilot certificate with photo is a great idea. I do believe that it is logical to have a photo with your pilot certificate to verify identity. Although it is probably just as effective to have a non-photo certificate and be required to carry a government issued ID. Having a photo on your pilot certificate may be slightly more convenient. My suggestion is that the fraud-resistant documents used to verify identification be a government issued ID or passport and birth certificate, or social security card. I think that 8 years is a good limitation on the duration of the photo on the pilot certificate with photo, especially since it matches the standard for the Real ID Act. I think that the best way to accept photos is to use the current passport standards, however if digital photos will be acceptable I think only those taken and provided by an approved agency should be accepted, such as: a knowledge testing center, DPE, or FSDO just to limit any chance of fraudulent photos being submitted. Charging pilot $50 for picture on certificate makes no sense. The costs to collect and report this additional tax will eat up any revenue.  As experienced government finance professional I\\'ve seen this time and again. Costs are not separately recorded so attempts to increase revenues frequently don\\'t accomplish that goal.  Please correct this false attempt to collect further revenue. Thank you. Although I don\\'t object to the photo certificate requirement in and of itself, I do object to the cost.  Let us keep using other photo ID, unless there is another reason for renewing a certificate, and don\\'t charge so much for them. I am opposed to this NPRM (Photo Requirements for Pilot Certificates (Document ID FAA-2010-1127-0001)) requiring photo ID\\'s for pilot\\'s. It is too costly, likely to lead to costs passed on to an industry that cannot afford it, and will not yield any increase in aviation security.   I have never in 40 years of flying been asked to produce a pilot certificate to a public official. How does the Federal government intend to use a pilot certificate photo ID? The NPRM does not address how this requirement will be used to address \"security issues\".  Will I be required to check my photo ID before I get in my General Aviation aircraft to make sure I am still me?   I am a retired military officer that possesses a military photo ID card, a driver\\' license with a picture ID and other forms of identification. What will this photo do that the currently required driver\\'s license photo not do, execept generate $445 million in revenue to the Federal government?  The Federal government says, \"Costs to pilots would sum to $445.8 million over the above 20 year period. This includes the costs of the pilots providing hard copy photos and a Form 8710-1 to a portal designee.\" Nearly a half a billion dollars for pilot to pay, for what public benefit? What is the justification for this? There is no justification for this NPRM and therefore it should be eliminated.    I have piloted aircraft for over 43 years and have been on every side of the certification process as a pilot, instructor, and pilot examiner. Adding an airman\\'s photograph to existing certificates as required by the Intelligence Reform and Terrorist Prevention Act (IRTPA) may be inevitable, but it needn\\'t be a bad thing.   The FAA\\'s overblown proposal as outlined in this NPRM, borders on the absurd and exacerbates a certification system that is already unmanageable.  Issuing pilot certificates with photographs is long overdue and should not require a complete rewrite of 14 CFR 61.  As outlined in this NPRM, the additional cost, time, money, and personnel resources would burden the current certification process as never before.  The ridiculous time frame currently required for receiving a certificate (usually months from its effective date) would increase exponentially and would entail the continued use of paper Temporary Certificates.  Wouldn\\'t this call into question any security benefit of having photographs on a permanent certificate.  Surely making things more cumbersome, less effective, less efficient, and not accomplishing the desired outcome was never intended by Congress when they wrote IRTPA. A simple low cost solution could be to issue a passport-like-document (in book form with similar dimensions) called an Airman Certificate for a period of 8 years that includes a photograph of the bearer.   This certificate could be issued to students, pilots, mechanics, and flight engineers, ranging from the most rudimentary to the most advanced certificates and would only be reissued every 8 years.   Additional certificate grades, privileges, ratings and even medical certificate stamps could then be affixed to the inside pages of the certificate by examiners or field office inspectors in the form of a difficult to copy sticker which lists the certificate grade, privileges, ratings, etc. and includes an and includes an imbedded computer chip.  The entire process could then be accomplished electronically in minutes rather than months and the airman registry database could be updated in real time. The airman could then hold the same certificate for 8 years and it would include all of his vital information, qualifications and ratings.      There would be a one-time cost for the airman every 8 years and eliminate the need for a complete rewrite of the regulation or an ever-increasing cost for every airman every time he renews his CFI, adds a certificate, or category or class or type rating. In addition, this type of certificate would satisfy long needed modernization of the certification process and reduce rather than increase costs. Temporary Certificates would no longer exist, and there would no longer be an inordinate wait between a practical test, medical exam, and a new certificate, rating or qualification.  This IRTPA requirement may actually be a blessing by overcoming inertia and providing an opportunity for meaningful change; a catalyst for long needed improvements in how the government (in this case the FAA) works.    I am opposed to the photo requirement for pilot certificates.  I have held a private pilot certificate since 1970 and I have never been asked to show it for identification purposes.  I never expect it will happen.  I already carry a photo ID in the form of a drivers license.  I expect all pilots have such photo ID.  The assertion that there will be no significant economic impact on the pilot community is absolutely incorrect.  There will be both significant economic impact and significant inconvenience to every pilot who must travel to a designated location and pay the fee to have the photo ID made.  Given that there will be no benefit to the pilot community and no real improvement to national security the addition of the photo ID to the pilot certificate seems like a total waste of time and money on the part of the pilots and the FAA.  A new pilot\\'s certificate containing a photo provides for no more usefulness or national security than the already existing requirement for a pilot to carry photo ID with his certificate.  This is yet another example of a bureaucratic requirement that costs to implement and maintain with no benefit other than to fulfill an administrative need.  The curent practise of carrying a photo ID with the certificate fulfills any practical need for identifying the pilot.  If a pilot\\'s identification is in question for practical reason, the responding authority will no doubt, need more than one form of identification in any case.   Considering the costs involved with implementing this system and the ongoing need to update photos due to both the 8 year renewal requirement and the progression of new certificate issuance, there are compelling reasons to reconsider this proposal.    Additionally, the requirement for photos to be used for the student pilot certificates would undoubtedly cause a significant financial impact to flight schools.  The enthusiasm displayed by prospective students to start their training could well dissipate in the length of time it would require to obtain a photo certificate.    I strongly recommend that the simple addition of words to the effect that the pilot certificate is not to be used for identification purposes or that when used for identification it must be accompanied by an approved photo identification would delete the necessity to include a photo on the certificate itself.   The plan to require pictures on pilot certificates creates an additional barrier to pilot certification and is not the best use of tax payer money.  “At this time, the FAA estimates that it could take up to 6 to 8 weeks for the FAA to issue a student pilot certificate.”    This is unacceptable as many students complete the private pilot training program in as short as 30 days.  This additional 6-8 weeks (42 to 56 days) is unreasonable.  It may take longer to process a certificate than it takes to earn it!– something wrong here.  DPEs provide temporary pilot certificates now (upon completion of a check ride).  Maybe that should be continued and applied to students as well.  Once a picture is required, the certificate is technically no longer a certificate but a license, as it will be time limited, and pilots will likely have to renew at some time period.  This is additional cost that provide limit increase in safety or security.  An additional government ID shouldn\\'t be required.  There are already enough ID\\'s.  Consider a valid passport in conjunction with the existing pilot certificate, or any other valid government issued photo ID (state driver license, etc.).  The Pilot Certificate could specify on it (by text) what photo ID has been elected (passport ID number, driver license ID number, etc. Requiring the replacement of existing plastic pilot certificates is unnecessary and redundant.  Virtually 100% of all pilots already carry a government issued photo ID in the form of a drivers license.   Simply require the pilot have in his or her possession their pilots certificate AND a government issued photo ID such as a drivers license in order to exercise the priveledges of that pilot certificate.   The additional cost to the FAA\\'s budget is not justified and no security enhancement will result from requiring a photo on a pilots certificate. This action will simply increase the burden on most existing and new pilots who wish to enjoy flying for recreation. This increased burden will further reduce the pilot population, participation and further hurt the United States aviation industry.     I am in favor of airmen certificates to include a photograph of the individual.  It is about time we make the pilot certificate look professional and not something out of a cereal box.  I agree it may have the appearance of a passport with a photograph, authorized certificate privileges, and ratings.  This should include category, class, and type of aircraft authorized to operate.  Please make it look professional and not some second thought.  Thanks for listening.  NPR Photo Pilot Certificates Docket FAA0-201-1127  Dear, Sir:   I believe that we should make things simple; if the NPR improves SAFETY or SECURITY then let’s implement the Rule change. This NPR does not improve either Safety and/or Security so it should be removed. I have never used (or been allowed to use) my pilot’s certificate to gain access to any secured area. I cannot think of any way that having my picture on my certificate would result in an increase in safety. If you know of examples were this change would improve Safety and/or Security please inform me of these examples.  Regards, Ken Lifland No provision has been made for low and moderate income certificate holders in this docket, and this should be corrected so as to provide equal access for all.  The intent of the legislation which spurred this photo ID requirement was to allow identification of all pilot and student certificate holders. To deny a segment over affordability of compliance is unfair and may even be illegal, and the FAA needs to consider this before the implementation of the program, and to introduce a system by which applicants may comply without creating financial hardship. Requiring a photo on a pilot certificate fails to meet the goal of this NPRM, and does not contribute to safety in any way.    Assuming that the goal is to prevent fraud by ensuring an applicant is who they say they are, this NPRM assumes that the simple inclusion of a photo would reduce that fraud.  However, if a person is misrepresenting themself in the first place, how does taking their photo prevent that?  Secondly, the NPRM assumes that someone willing to use an aircraft in support of terrorism would bother obtaining a pilot certificate in the first place.  The actions of the individuals on 9/11 would not have been prevented in any way shape or form by the actions proposed in this NPRM.    Lastly, presenting a pilot certificate (whether a photo is on it or not) is not a requirement to gain access to an aircraft in the overwhelming majority of scenarios.  If an FAA inspector were to 1) conduct a ramp check, and 2) note that on inspection of the pilot\\'s certificate that the photo did not match, I would agree that future nefarious actions would indeed be prevented, however the breach would have already occurred.  Considering the number of flights that occur every single day without the pilots having to prevent any pilot certificate, this would be a very rare success of the program indeed.    Efforts to prevent fraud in this manner would be far better employed by requiring a background check prior to issuance of any pilot certificate, however given the number of airports in the US where aircraft can be accessed without any identification of any kind makes this a partial solution at best. Pilots do not need an additional picture ID card. If we carry our FAA license, FAA medical (where applicable) and a government furnished picture ID card that should be sufficient.  Also, Make the CFI certificate with no expiration date as is are other pilot certificates. The CFI could only exercise privileges as a CFI only if they carried the no expiration FAA certificate for their CFI proof AND the most recent proof of completion of the FIRC. That way the CFI certificate does not have to be additionally renewed every other year, only reissued if additional ratings are added to the CFI pilot certificate.  If the picture in the pilot certificate requirement becomes law then require it ONLY on the pilot certificate and not on the CFI or other pilot certificates. Make the CFI unexpirable.  Jim Behrens In regards to the NPRM to have pilots include a photo of themselves on their pilot certificate: At the present time pilots are required to carry a government issued identification document that has a photograph of the pilot attached. I feel that this is sufficient to provide positive identification of the pilot and that no provision is needed to require pilots to have a pilot certificate with a photo of the pilot attached. The cost of issuing a pilot certificate is burdensome to pilots as well as the time and expense of getting a photograph and having positive identification of the pilot made. If the NPRM is enacted then there should be only a single deadline established to require all pilots to have their certificate issued with a photograph attached. That deadline should be set at 5 years from implementation of the rule. Having pilots visit FSDO’s, DPE’s or Knowledge Testing Centers to have photographs and positive identification of the pilot made is burdensome and costly for many pilots. Those pilots who do not live close to a city where a FSDO is located would be required to travel, at their expense, just to have a photo made and to have their identity verified costing much more than the $50.00 proposed fee. DPE’s and Knowledge Testing Centers are not located at every town and city in the USA, again requiring pilots to expend travel costs in excess of the $50.00 proposed FAA fee. Also, the DPE’s and Knowledge Testing Centers would charge for their services incurring more cost burdens on the pilots. I suggest that the FAA establish a method for submitting a digital photo though the internet and have the pilot’s identity verified by a state agency such as the State Driver Licensing agency or an by an agency that issues airport access cards. Since the duration of a passport is presently at 10 years and a pilot certificate is a national document, the duration for the pilot photo should also be 10 years. Student pilot certificates should be treated the same as o The photo requirement is not needed for all types of pilot certificates. The sport pilot should not have the photo because it specifically requires a driver’s license to validate its use. Few if any pilots using a Sport pilot certificate would have a third class medical, if the did they would most likely be private pilots using their sport pilot privileges. As this certificate is not for use outside the US, it does not need to be compliant with any international standards. In fact having the actual card different in appearance from a private pilot or higher, will prevent any confusion or misrepresentation. The same will be true of the Student pilot certificate. Even more so as these tend to be temporay in nature, due to students dropping out or completing their training.  There is no need to redo the pilot certificate to include a photograph.   FAR § 61.3 already requires a pilot to carry an acceptable picture ID when exercising his pilot privileges.    Isn\\'t there a government directive that says that we should not add to the government\\'s paperwork and expenses without serious justification?  Beyond satisfying a member of Congress, what justification is there for this rule?    Before I retired from a position as a FAA aviation safety inspector, I checked pilot certificates when inspecting airline operations.  While I didn\\'t check a photo-ID, the point is that the certificate was only looked at when doing an inspection.  I venture to guess that more than 95% of all airline operations are flown without the pilot ever being asked to show his pilot certificate.  Probably more than 99% of all aircraft are being flown without anyone having to show a photo ID.  Airline crews have company and airport ID\\'s with photos.  TSA has forced most FAR Part 139 airports to impose an ID card requirement with a photo.  How many forms of photo ID should a pilot carry?    Yes, at the direction of our Congress, the FAA can make this a new requirement.  However, what it does is create a  requirement for additional FAA Certification staff and more bookkeeping.  It will increase the cost of flying just to satisfy an order demanding a photo ID.  And then we can expect a requirement to update the photos after that.  All of this sounds like an old Army cliché about digging a hole and then going back and filling it.    The NPRM is saying that we need the photo, then it says that it incurs costs to handle that, and then we end up with an expanded bureaucracy.  And for what? The Student pilot certificate proposal will kill pilot starts.  The use of FSDOs to process photo IDs is insane as FSDOs require an appointment to enter the building. They are not geared to handle 750,000 pilots wanting an appointment.  There should be a requirement for the FAA to produce the photo certificate and send it to the pilot within a stated period, and while this is in transit the pilot should be able to exercise the privileges of their certificate.  A photo pilot certificate must serve as ID in all situations where required, not just for the FAA. As such it becomes a Federal ID card. Legislation to do this must be enacted as part of this change.  This entire proposal is one that will inflate government staff and expenditure in a time when the nation cannot afford it. A photo pilot certificate is unnecessary duplication.  The current procedure of using separately produced government photo ids together with a plastic pilot certificate would appear to be efficient and effective. This proposed rule is poorly thought out and incurs numerous fees and costs that are unwarranted. This will be the second time in recent years that the FAA has altered the requirements for the pilot certificate, and this time it is out of hand. The cost and process are excessive and the burden will be unrealistic whenever airmen are updating a certificate and/or adding a rating. In Regards to the NPRM, Require Pilot Certificate Photos. This proposed action is completely unnecessary. We currently have a requirement to carry another form of ID with a photo on it. I have no less then three Government photo ID\\'s I carry while flying. At the minimum I would say every pilot currently has a government Photo ID. The cost to set the program up, and the cost to the user is not justifiable! What about those with multiple certificates from the faa? would we be required to pay your fee fior every faa certificate  we have? A current pilot certificate (without photo) and a current government issued ID is sufficient! Since most states have your picture on your driver\\'s license I see no reason to have it on your Pilot Certificate if you are careing your driver\\'s license which everyone does that has one. This is just more expense that need not be. If you need to show your Pilot Certificate to the proper person you can produce your driver\\'s license with your Photo on it at the same time. The process of obtaining a pilot certificate and the training involved is already expensive enough. Despite there being relatively little (if any evidence) to the contrary, a blanket approach is being taken that imposes additional cost on pilots and student pilots. Instead of there being a photograph on a pilot certificate card, it could be required that a pilot carry in conjunction with existing pilot certificates a government-issued photo ID that is in the same name as that on the pilot certificate. It is already necessary to go through this process for passports and drivers licenses -- why require it on yet another document? A pilot certificate is a certificate of pilot privileges, not an identification document. It should not be made into one.       I recently learned of FAA-2010-1127.   Having read through the entire proposale,I do not agree with the assesment of the beniftits and the cost being considered insequencial.   I am not opposed to having my picture on my certificate.  I do not see the need or the benifit of it.  In the 17 yrs that I have had it,not one person has asked to see it.  In he proposal,the estimated  anual cost break was listed as $19.  This would be another of many costs that are being forced on us from a varitey of area\\'s (ex.  light rail tax,various phone taxes,recycling tax etc.)       Please drop this proposal.  Thanks,  Cory Lange          I do not keep track of what congress does from day to day(and who does?), so I had no idea about this. I heard something about it a few months ago, but quickly forgot about it. I just happened to look at a copy of \"General Aviation News\", and saw the story.   Why would congress implement a useless regulation to burden Pilots? Why did they do that? To be honest, I have no idea. It can\\'t be about safety! I never show my pilot certificate to anyone, except for employment purposes. At that point, I have to show a photo Driver\\'s License, so that has \"my picture\" on it and totally satisfies identification. Airlines all require a Valid Passport.   Another example of a complete waste of time in the next paragraph.  As a Flight Instructor, I have to keep a copy of a student\\'s \"Birth Certificate and Driver\\'s License\" just to satisfy the \"TSA\" because I am not capable of alone determining if someone is from a \"foreign\" country . That is a burden in itself, since there is a 101% chance the farmer from Cottonwood, California I am teaching to fly is a \"US Citizen\". If I teach my \"son\" to fly I have to this do this as well (to prove his citizenship of course), beyond totally ridiculous!   Now, you may ask...what is wrong with getting a picture on your Pilot Certificate? Answer: The cost...they want TAX Pilots. Pure and simple.  It is completly not warranted, and without justication to require a photo on a Pilot Certificate. There is simply no purpose for this requirement. NONE.  In a recent study, 93% of Pilots polled reported that they have never shown their Pilot Certificates to anyone except an FAA Inspector. The cost associated with implementing photos on Pilot Certificates is going to be $1000.00 per pilot over 20 years. That amounts to over $$$ a half-a-billion dollars to Pilots ....  I SAY NO to this rule....throw it out and leave things the way they are. Charging an airman $50 to put a picture on a certificate is outrageous.  It\\'s extremely rare for a pilot to be challenged for his/her certificate and probably nigh on impossible for that airman to also be without another form of government-issued ID.    The fact that anyone thinks this will result in better identification of airmen to reduce terrorist risks is laughable.  In an airline setting the crewmember also has their company ID which will have a picture on it.  The likelihood that this would drive a change to using the airman certificate is extremely low.  It would just be tucked away in the pilot\\'s wallet, purse, or ID holder with their medical certificate.  At an FBO the staff will check a drivers license before an aircraft can be rented.  If a person is not a US Citizen, they have to have a FBI background check before receiving flight training.  If they are a citizen that citizenship will be verified through a US passport or birth certificate.    Measures like this do not stop someone from stealing airplanes or trying to get through some type of security.  All it does is cost airmen extra money for something that gives no benefit.  If the FAA wants pictures on certificates they can lobby Congress for the funds or make it voluntary.  As a professional pilot I see no reason why this would drive an increase in security or safety.  Thank you for your time.   I strongly support this requirement not only for pilots but mechanics also (I am both) with the caveat that this new certificate also be valid for TSA and Homeland Security identification.  It is ridiculous that a duly certified pilot or mechanic needs an escort to be on the ramp of airports with scheduled airline service.   Because the certificate is not issued immediately upon application, the time-honored tradition of young aviators soloing on their sixteenth birthday will go away.  Is there any way to either have a temporary certificate issued immediately at a FSDO, to have someone apply for the certificate before the age of 16 and to have it issued but not valid until their 16th birthday (perhaps as a restriction), or some other plan to allow highly motivated people to exercise student pilot certificate privileges on their 16th birthday?  I support this to have a photo on the certificate.  This would then allow us to fly without both a pilot certificate and driver\\'s license in hand which would be much appreciated.  Great step forward to have it havea photo as long as the requirement for addtional government issued photo identifcation was then done away with. The FAA is proposing photographs on US pilot certificates.  The photograph is a good idea but it must be done properly.  Since the average fee for a state driver’s license with a photo is $20 the federal pilot certificate should also be that fee.  Also, the FAA should contract with the GSA or post office to process the paperwork for the certificates.  The post office already handles the paperwork for US Passports and the postal clerks have been trained in recognizing the proper identification required.  The idea of using designated pilot examiners and allowing them to charge a fee is stupid.  Student pilots can get a student certificate for free by visiting a FSDO but a designated examiner charges about $25 for the same certificate.  If there is a processing fee the US Government should get the fee for debt reduction and not some examiner who will just pocket the money and probably not report it on his/her income tax form. Again, the pilot certificate with photo should not cost more than $20 with no extra application or DPE fee. The student pilot certificate should be valid without a photo – just like the state issued learner driver permits. It seems redundant to require another ID with a photo. Would it not be simpler to require the pilot to carry a state issued photo ID, which we all already have, or a Passport. It appears this is just another revenue scheme the government is putting together to protect us from what? Is there some evidence that airplanes are being illegally flown because the pilot had a non-photo ID. How much will this rediculous requirement cost the taxpayers? I can\\'t rent a plane without first showing my passport, Pilot certificate, Pilot Medical and drivers license to the FBO. How on earth will the requirement of a photo pilot certificate make us, the american public, any safer?????            February 16, 2011    Docket Operations; MŒ30  U.S. Department of Transportation    1200 New Jersey Avenue SE    West Building, Ground Floor, Room W12-140    Washington, DC 20590-0001    RE: Docket No. FAAŒ2010Œ1127; Photo Requirements for Pilot Certificates    To Whom It May Concern:    The Air Line Pilots Association, International (ALPA ) represents 53,000 pilots who fly for 38 passenger  and all-cargo airlines in the U.S. and Canada. The Association has a vested interest in the improvement of  regulations related to aviation safety and security and is grateful for the opportunity to comment on the  above-referenced Notice of Proposed Rule Making (NPRM).      Section 4022 of the Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA) 1 requires the Federal Aviation Administration (FAA) to promulgate  regulations governing the issuance of improved  pilot licenses. In the NPRM, the FAA prescribes the inclusion of a photo of the bearer on the pilot  certificate, with the statement that ﬁ This rulemaking aids in preventing  terrorism and ensuring safety in  air commerce. ﬂ  After careful review and consideration of the informa tion contained in the NPRM, it is ALPA™s view that  the requirement for the inclusion of a photo on a p ilot certificate issued to pilots engaged in Part 121  airline operations, as defined in the Federal Aviation Regulations (FARs), will not contribute to security  in a meaningful way as regards FAR 121 airline pilots . We have reached this conclusion because, as is described below, all Part 121 pilots carry at least one  photo ID card issued by the airline and approved by  the TSA and FAA according to federal security  regulations, and most possess two such ID cards.  Furthermore, FAR Part 61 requires all pilots to have  in their possession or readily accessible an FAA pilot  certificate and at least one form of government-approved photo ID whenever they operate a U.S. civil  aircraft.    ALPA calls on the FAA to exempt airline pilots enga ged in Part 121 operations from a new requirement  for purchasing pilot certificates with photographs.    Background   Pilots engaged in Part 121 air carrier operations are required by government, airline and airport  regulations to carry a variety of identification to  validate their identity and confirm their employment  status. These forms of identification have for decades b een considered sufficient to permit pilots to access  the flight deck and sterile and secure areas of airports. Following is a brief description of the types of   identification carried by Part 121 airline pilots.                                                   1http://www.gpoaccess.gov/se rialset/creports/pdf/108 796/108 796_intel_reform.pdf  Air Carrier-Issued Crewmember Identification Cards   All airline pilots must maintain on their person  a valid, air carrier-issued identification card with  photograph during operations. The process for issuing air  carrier credentials is defined, regulated and monitored by the Transportation Security Administration (TSA) through an identification media control  program. That program requires airlines to follow stringent background vetting requirements prior to   issuing air carrier credentials to pilots.     In order to qualify for service as a flight crewmember  and be granted an air carrier identification card, a  pilot is subjected to: a government-required TSA Secur ity Threat Assessment (STA); a Federal Bureau of  Investigation (FBI) 10-year, Criminal History Records  Check (CHRC); drug testing; and, a review of the  airman™s entire training history as required by the P ilot Record Improvement Act (PRIA). Additionally,  prior to issuing an identification card, airlines conduct credit checks, peer reviews and perform other  background evaluations to verify the identity and  trustworthiness of crewmembers and to establish the  suitability of their character and fitness for duty.     Upon successful completion of this vetting process, an ai r carrier will issue the pilot an identification card  which, in compliance with TSA regulation §1544. 231, includes a full-face photograph and other data  identifying the individual as a flight crewmember.  This card must be prominently displayed on the  exterior of clothing above the waist whenever th e pilot is acting in an operational capacity in the  commercial aviation environment. It is separate and distinct from the FAA-issued pilot certificate which   is normally carried in a discrete fashion on the pilot™s person or within his/her immediate control.       The air carrierŒissued crewmember identification card is:    Examined at TSA airport security checkpoints to  establish the identity of a flight crewmember.  This examination is required to authenticate th e crewmember™s qualification for certain TSA- approved security protocols that are app lied only to uniformed crewmembers.    Relied upon by air carrier personnel who, per TSA re gulations, must verify the identity of flight  crewmembers before they are permitted to assume command of an aircraft.    Recognized as authentication of the pilot™s auth ority to traverse certain specific air operations  areas (AOA) of airports for which the pilot does not possess an airport-issued Security   Identification Display Area (SIDA) badge.    Utilized as the primary means of identification for the Cockpit Access Security System (CASS),  which electronically authenticates a pilot™s employme nt status and identity to make them eligible  to occupy the flight deck jumpseat  of off-line air carriers. In addition, airline pilots are required  to carry and display a second form of government issued photo-identification (normally a  passport) in order to qualify for CASS-approval.   Airport-Issued Security Identification Display Area (SIDA) Credentials    In addition to the background vetting that accompanies the issuance of  an air carrier identification card, most airline pilots are also subjected to additiona l, similar scrutiny conducted by at least one airport  operator, in order to qualify for receipt of an airport-issued SIDA badge. The SIDA badge signifies that the bearer has been authorized by the airport author ity to enter secure areas of the airport without an  escort.  The SIDA badge bears a photo of the pilot and is required to be displayed in the same fashion as  the pilot™s air carrier-issued identif ication card whenever the pilot enters SIDA-designated areas of the  issuing airport.    Passport  Per most air carriers™ policies, the majority of airline p ilots travel at all times with a passport so that they  may establish proof of their authority to occupy a  flight deck jumpseat and/or conduct international  operations. Among other industry-recognized forms of  identification carried by pilots, the passport  document can be relied upon by authorized individuals  to satisfy or resolve identity confirmation needs  associated with a pilot certificate.     The FAA-Issued Pilot Certificate   Airline pilots are rarely required to present their  FAA-issued pilot certificates for inspection or  identification purposes because the TSA-controlled airline ID card and/or SIDA card is used for that   purpose. Normally, FAA certificates are presented fo r examination during company sponsored training  events, during an FAA inspection, or in instances  when a pilot seeks permission from a pilot-in-command  to occupy a flight deck jumpseat. In  such cases, the pilot™s identity a nd employment status has been pre- established through a variety of standardized measures and other forms of recognizable photo-  identification as previously described.     An FAA-issued pilot™s certificate is not intended to be displayed for security purposes, but rather, is  designed to demonstrate a pilot™s aircraft type ratings,  skills and privileges. It is reflective of the bearer™s  documented training history and qualifications, records  of which are traceable and verifiable. As such, in  those very limited cases when a pilot certificate is ex amined by an authorized, inspecting authority, the  accuracy of the data it represents is verifiable.     What is most critical in the issuance of an FAA pilo t certificate from a security standpoint is the accurate  establishment of the pilot™s identity, background descr iptors, and qualifications.  If fraudulent data is  relied upon and incorporated in the FAA™s record-keepi ng system at the time of issuance, the process will  be flawed at inception. Presently, FAA does not ve rify the identity of the person requesting a pilot  certificate other than through visual inspection of the  individual™s driver™s license or passport. As such,  adding a photograph to the certificate will not incr ease the security attributes of the document because the  requesting individual™s true identity is not verified with a high degree of confidence.      Threat Mitigation  TSA enumerates 20 layers of US aviation security, 2 which include the previously described crew vetting process and the Travel Document Checker (TDC),  a person who scrutinizes government and/or airline- issued identification media presented by a crewmemb er seeking access to an airport™s sterile area. The  FAA-issued pilot certificate is not included in  that category of normally accepted identification.   Efficient security countermeasures are designed a nd implemented to mitigate a known threat of  meaningful consequence. Prior to implementation, such measures should be demonstrated to be   necessary, effective and cost-justified. We note th e lack of any supporting data in the NPRM which  indicates that the specific absence of a photograph on an  FAA-issued airline pilot™s certificate has created  or contributed to an actual aviation safety or security  threat or that it is indicative of an exploitable  vulnerability. ALPA would welcome the opportunity  to see such data, if it is available.    Facsimile Copies of Airman™s Certificate   ALPA agrees with that portion of the rulemaking wh ich continues the practice of allowing pilots to  request and receive a facsimile copy of their airman cer tificate in the event the original is lost or stolen.  Changing this practice would effectively limit the ability of  an airline pilot to remain gainfully engaged in  his/her occupation until a replacement is issued  and would have a detrimental impact on passenger  movement and the airline industry operations.                                                   2http://www.tsa.gov/what_we_do/layers/index.shtm  We would also submit that the FAA™s continuation of  the facsimile practice for lost/stolen certificates  affirms that in such cases, the air line industry has traditionally been  able to operate safely and securely  without depending on the possession of an original pilot™s certificate in order to:    1. authenticate the identity and qualifications-rela ted  information it is intended to represent  2. provide the pilot with needed access to airpor ts and aircraft in order to accommodate the  performance of his/her occupation and the flow of commerce     This fact, coupled with pilots™ possession of other fo rms of reliable identification which they must by  regulation carry with them in the commercial aviati on domain, contraindicates the need for an enhanced,  photo-bearing pilot certificate as applicable to airline pilots.    Conclusions    A threat-driven, risk-managed and cost-effec tive approach to ensuring aviation safety and  security should be employed in identifying a nd implementing meaningful countermeasures to  consequential vulnerabilities. ALPA is not aware  of any such process being used to develop the  requirements contained in this NPRM.     Relatedly, we respectfully disagree with the FAA™s assertion that ﬁ This rulemaking aids in  preventing terrorism and ensuring safety in air commerce ﬂ because we do not see  the need forŠor benefits fromŠ a costly change to a certificate that is never used by itself to establish identity.      A photo of the bearer on an airline pilot™s certifi cate will not facilitate the efforts of authorized  examiners to establish its authenticity or the iden tity and qualifications of the holder. Numerous,  alternative methodologies are available and currently  relied upon to effectively meet those needs.   Nor will such action improve airline security sin ce the pilot™s certificate is not, and cannot be,  relied upon as means of positively verifying  identity or confirming employment status.    The TSA already requires that airline pilots  possess one or more government-controlled, photo- bearing ID cards.  The airline ID card with ph otograph, unlike the proposed  FAA pilot certificate, is electronically verifiable via th e Cockpit Access Security System.     It is unnecessarily duplicative to require airline  pilots to pay for a third method of identity  verification when most, if not all, airline pilo ts already carry two or more government-regulated  photo ID cards which serve the intended purpose.    Recommendations   ALPA recommends that the FAA amend its proposal  by exempting FAR Part 121 and 135 airline pilots  from this rulemaking. As justification for doing so,  the agency can rightfully asser t that, for these pilots, it already meets the intent of the IRTPA™s Section  4022 as relates to issuance of improved pilot licenses  (i.e., today™s FAA-issued plastic pilot certificates) that are resistant to tampering, alteration and   counterfeiting.  When presented in combination with  airline ID cards, SIDA cards, and/or passports, as is  the case during airline operations, the FAA certificate  already provides the security features that are  needed for this application.  We further recommend that FAA establish a means fo r pilots to identify them selves to the agency as  airline pilots for purposes of exempting them from th e requirement to obtain a pilot certificate with a  photo. To this end, we would propose that the individual pilot request an exemption from the FAA by   completing and submitting a form designed for that  purposeŠwhich form would be signed by both the  pilot and the airline™s ch ief pilotŠconfirming that he or she is currently employed by an airline  conducting Part 121 or Part 135 operatio ns. A photocopy of the pilot™s airline ID would be attached to  this form as further evidence of the pilot™s employme nt status. Any airline pilot who may wish to have a  pilot certificate with photo would be able to obt ain one by submitting the requisite photo and fee.   Thank you for the opportunity to comment on this proposed rulemaking. P lease contact ALPA Aviation Safety and Security Specialist Greg Bergner ( greg.bergner@alpa.org , 703-689-4351) with any questions  or comments.    Sincerely,   Capt. Robb Powers, Chairman   National Security Committee              DhPARTMENTOF ^i^AMSPORWiON. . C.^H OPEBMIOMS US Department of Transportation 1200 New Jersey Avenue, SE, Room W12-140 West Building Ground Floor Washington DC 20590-0001 PO Box A3089 Chicago, IL 60690-3089 November 19, 2010 Dear Sir/Ms: The FAA is proposing photographs on US pilot certificates. The photograph is a good idea but it must be done properly. Since the average fee for a state driver\\'s license with a photo is $20 the federal pilot certificate should also be that fee. Also, the FAA should contract with the GSA or post office to process the paperwork for the certificates. The post office already handles the paperwork for US Passports and the postal clerks have been trained in recognizing the proper identification required. The idea of using designated pilot examiners and allowing them to charge a fee is stupid. Student pilots can get a student certificate for free by visiting a FSDO but a designated examiner charges about $25 for the same certificate. If there is a processing fee the US Government should get the fee for debt reduction and not some examiner who will just pocket the money and probably not report it on his/her income tax form. Again, the pilot certificate with photo should not cost more than $20. The student pilot certificate should be valid without a photo -just like the state issued learner driver permits. Sincerely, Rich Waienda Ł ^f !j ;i\\' .. : \\'. ^^J--.-t.  The University of Oklaho ma\\'\\' \\'Ł -\\'\\'^^0?^ DEPAHTMENT OF AVIATION ŁŁ:Ł\\'] r\\'-r -PENT OF 1 A I!: 31 Docket Operations, M-30 12-7-10 Department of Transportation 1200 New Jersey Avenue, SE, Room W12-14-, West Building Ground Floor Washington D.C. 20590-0001 Dear Sir, Following are comments on the NPRM for Photo Requirements for Pilot Certificates (Docket No. FAA-2010-1127; Notice No. 2010-16 The following inputs are in the form to answers to your seven questions at the end of the discussion on this NPRM (pages 20 -21) Question (1) (a) U.S. Citizens: These individuals have to prove they are U.S. i.:itiEens before starting training. At this time the TSA is satisfied that the individual demonstrates proof of citizenship by presenting an unexpired U.S. passport, birth certificate, or naturalization papers. In the case of btirth certificates and naturalization papers the individual must also present a government issued photo ID - state driver\\'s license, military ID, etc. If the TSA is satisfied with this methodology, then this should also work for the implementation of this rule. (b) Non-U.S. Citizens: For foreign national students the TSA conducts a background check. After completion of the back ground check and email notification to the flight school, this information, combined with the individual\\'s foreign passport/visa could work for identity verification. For foreign nationals that already have a pilot certificate and are upgrading to the pilot certificate with photo ID, their current pilot certificate, combined with passport/visa should be sufficient. (c) Note: The FAA and TSA should realize that very few of the persons/agencies suggested for processing pilot applications and verification of identity have thi; training and ability to detect forged identity documents. If an individual, sponsored by a terrorist group, wishes to obtain a photo ID pilot certificate using an alias, that individual will no doubt have the resources to obtain and present accurate and authentic looking verification documents which are complete forgeries. At the level of initial verification, DPE\\'s, FAA knowledge test personnel and even ASI\\'s at the FSDO will probably not be able to detect the forgery. 1700 LOKlngton St. Norman, Oklahoma 73069 PHONE; (-lOS) 325-72.; I FAX- (405) 325-013fl WWW.AVIATION.OU.RDU ® Question (2): No comment. Question (3): (a) In addition to the agencies mentioned (Knowledge Test Centers, DPE\\'s and FSDO\\'s) it is important that an Individual who is an Airman Certification Representative (ACR) also have the authority to accept pilot certificate applications and validate applicant identity for those students training in the Part 141 school for which that individuali is an ACR. (b) For states that have Tag Agencies the FAA should consider using TAG agencies for the purpose of processing exchanges of non-photo ID pilot certificates for photo ID pilot certificates. Question (4): The fact that time limits on photos are being proposed at all hits at the major weak point of photo identification. Whether the photo on the certificate is one day old or 8 years old is irrelevant. The relevant question Is if the photo on the pilot certificate doesn\\'t look like the individual presenting the certificate, will the \"presentee\" take the appropriate action to deny the individual access to an airplane? Hopefully (but doubtfully) the answer is yes. At the very least this will represent a \"trigger\" to tell the pilot to get an updated photo pilot certificate. For example, initially the pilot\\'s photo shows him clean shaven snd skinny. A year later he has shoulder-length hair, a full beard and has gained 100 pounds. He doesn\\'t look anything like the picture on his pilot certificate. However, based on what\\'s proposed in the NPRM the photo is still good. If, on the other hand, 15 years down the road the pilot is still skinny, clean shaven and looks like the picture on his pilot certificate, why should he have to get a new one? Based on the above rationale, recommend the duration of the photo be at least ten years if not 15 years. Question (5): (a) The procedures for student pilot certificates should remain unchanged. Rationale: Student solo pilots are under much greater control and supervision thar other pilots. A student pilot can only gain access to an airplane through his/her school, or through his/her flight instructor. As mentioned previously the TSA already has procedures in place to ensure that student pilots are either U.S. nationals, or if foreign nationals have been properly vetted. Although the proposed procedures might prevent an individual from using a ^forged student pilot certificate from soloing, passing a practical test and earning a temporary private pilot certificate, it would not prevent the individual from learning to fly. Dual instruction would proceed without the student pilot certificate. Indeed, the individual wouldn\\'t even have to submit the application for the student pilot certificate - they could just tell their instructor they had submitted the application. Twenty or thirty hours dual instruction while waiting for a student pilot certificate that was never applied for is plenty of time to master the fundzfmentals of flying an airplane into a building. (b] As reported by industry 80% of the students who start trainlrtg never complete their training and earn a pilot certificate. Adding a procedure which could delay their first solo flight just adds another obstacle to training. Question (6): (a) The FAA should accept either hard copy or digital photos, but must accept digital photos from day one. One company that provides passport photos indicates that it can also provide these photos in digital format. Additionally, for foreign national students the TSA requires a digital photo of the student be uploaded into the student\\'s file. The TSA does not appear to have a provision for sending In hard copy photos. (b) On Page 14 of the NPRM it states, \"At this time the FAA is prepared to accept only a hard copy of a photo ... In the future the FAA anticipates accepting a digital photo.\" If we understand this correctly this means that until the FAA says oth<-:;rwise all applications would have to be submitted via paper 8710. If this is the case than the! costs of creating and operating lACRA would be wasted until such a time as the FAA decides to .iccept digital photos. The term \"Iin the future\" is very ambiguous and open ended. At this time our flight school and every DPE in the OKC FSDO area of responsibility uses lACRAfor processinf; airman applications. In fact the OKC FSDO mandated that we must use lACRA. lACRA has simplified processing of airman applications, minimized the time required to receive a permanent certificate and saved countless man hours In industry, individual FSDO\\'s and in Airman Records. To revert back to paper 8710\\'s until some point \"in the future\" would be a giant Step backward. WHEN THIS RULE IS IMPUMEfMTED THE FAA MUST HAVE A iVIECHANISM IH PLACE TO ACCEPT DIGITAL PHOTO\\'S IN lACRA AND TO CONTINUE TO USE lACRA FOR PRQCESSING AIRMAN APPLICATIONS! (c) If a pilot can submit a paper photo to the FAA well in advance of submitting an airman application via lACRA and the photo and application were then \"married\" at Airman Records for creation of the permanent pilot certificate, this would allow continued use of lACRA, but this seems to be much more cumbersome than simply uploading a digital photo on lACRA. Question (7) (a) Ideally an applicant should be able to upload a self-captured photo. This will be cheaper for the applicant and less burdensome then creating photo capability at testing centers, FSDO\\'s and with DPE\\'s and ACR\\'s. The disadvantage is that a self-captuired photo may not meet the requirements stated in NPRM (passport photo). In this case it would be up to the DPE, ACR or FSDO ASI processing the application to require the applicant to obtain a new photo. (b) Another alternative: As stated earlier at least one business (which is nation-wide) has the capability to take a passport photo and put it on a flash drive, t should be possible to download this digital photo into lACRA. Although the DPE, ACR or FSDO ASI who Is processing the application hasn\\'t physically taken the photo these individtiials can still verify that the photo \"looks like\" the person standing in front of them and verify the identity by examining the proscribed documents. Bottom line: If the capability for capturititg digital passport-like photos already exists don\\'t reinvent the wheel by recreating the capabililcy with individuals or organizations that aren\\'t doing it now. Thank you for the chance to comment. )AVID A. MCCLURKIN Chief Flight Instructor Aviation Department University of Oklahoma \\'afh^cAJ--   SAFE, Inc. 80 Valley Grove Cove, Cordova, TN 38018    www.safepilots.org    Docket Operations, M-30 U.S. Department of Transportation  1200 New Jersey Avenue, SE., Room W 12-140, West Building Ground Floor  Washington, DC 20590-0001    Re:   Docket Number FAA-2010-1127     17 January 2011  Dear Sir/Madam:  I write on behalf of the Society of Aviation and Flight Educators (SAFE).  SAFE represents more than  500 of the industry™s top aviation educators, including numerous local and national General Aviation Award winners in the flight instructor, avia tion maintenance, avionics, and FAA Safety Team  categories. SAFE is also chairing the GA Pilot Training Reform Symposium in Atlanta, GA on May 4-  5, 2011. SAFE understands that the FAA is mandated to include photographs on pilot licenses under the terms  of the Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA) P.L. 108-458.  We believe that the requirement to add photographs to certi ficates provides no additional protection to the  American public over the current requirement to  possess government-issued photo identification while  exercising the privileges of an airman certificate.  Many of our members describe this effort as \"security  theatre,\" putting a photograph on a document that authorities never ask for.  Our poll indicated all opposed.  Eighty-four percent are strongly opposed.  We  are addressing this over-arching concern to the Senate Committee on Homeland Security and Governmental Affairs.  SAFE understands that the price for an airman certificate may be mandated as previously described in  H.R. 1586 amending 49 USC §45305. This increase would affect all airmen, including mechanics, flight attendants, and control tower operators.  Our comments below with respect to the unfair burden  placed on flight instructors will also be addresse d to the House Transportation and Infrastructure subcommittee. SAFE believes that the photo process proposed by F AA-2010-1127 is not ﬁin the interest of reducing  burdens on the certificate holder...ﬂ  SAFE questions whether the FAA has used good security and program methodology to develop a plan that it projects will cost $718.7 million over twenty years.  This  cost projection amounts to almost $1000 per pilot.   We address our specific program concerns to the Office of Management and Budget.   SAFE presents specific objections to the NPRM and provides alternatives for consideration. Purpose of the Certificate  SAFE believes that the FAA should strive for continuous improvement, with or without a statutory  requirement to put photos on certificates.  The FAA should return to first principles and consider the use of the airman certificate.  At what points in an ai rman™s career should he or she expect to show the  credential to a representative of the FAA or other authorized person?   FAA-2010-1127      17 January 2011 Page -2-     SAFE polled its members, who have held certificates as  long as fifty years.  Ninety three percent report  that they have never shown a pilot certificate except  to an FAA inspector.  When they did so, they also  showed another form of government photo ID.  Three percent of our members have reported being asked by Customs and Border Protection or police for a pilot™s license.  SAFE members ask the FAA if  there has ever been reported a security incident associ ated with a pilot certificate that would have been  avoided by a photo of the pilot. SAFE is in favor of any certificate initiative that will increase the nation™s security commensurate with or exceeding the cost of such a program.  However, SAFE sees no additional security provided by a  photo on the certificate as long as the certificate is presented alongside another government-issued   photo ID.   Recommendation : SAFE recommends that the proposed rulemaking be discontinued.   Paperless Submission  The NPRM describes a process that mandates paper photographs and a return to paper-based certificate applications.  This approach is contrary to President Obama™s statements at the White House  Forum on Modernizing Government 14 January 2010 when he said, ﬁNone of this is acceptableŠ particularly at a time when we™re experiencing such economic difficulty and so many people are struggling.  We™ve got to get the best bang for every single dollar that the government has in its  possession.  And when Washington lags a generation behind in how we do business that has real and serious impact on people™s lives.  When we waste billions of dollars, in part because our technology is   out of date, that™s billions of dollars we™re not investing in better schools for our children, in tax relief  for our small businesses, in creating jobs and funding research to spur the scientific breakthroughs and   economic growth of this new century.ﬂ Moreover, the Transportation Security Administration in  its parallel system to track alien applicants for pilot certificates only allows the submission of digital images though its web site  www.flightschoolcandidates.gov.  Recommendation : SAFE advocates a paperless submission system. Verification of Images  The NPRM describes a process in which the applicant would get a photograph at a commercial  establishment, FSDO, Knowledge Testing Center, or from a Designated Pilot Examiner.  The   requirement for a 2ﬂx2ﬂ paper photograph is obsolete.  Only artists produce silver prints in 2011.  The  original image of all photographs today is digital.  To create a digital image, convert it to paper for  conveyance to the FAA, who will in turn digitize it again, is a waste of resources.  If the applicant has the option to supply the photo, then there is no security gain.  The photograph must be verified by  someone. Recommendation : SAFE recommends that an applicant be ab le to upload an image on-line using the existing paperless IACRA system.  The applicant co uld print his or her own temporary certificate with photo.  The image would be verified by an instructor prior to endorsing the certificate for solo flight.  The photo attached to an IACRA application for any other certificate would be verified by the  designated pilot examiner (DPE) or FAA Inspector (A SI).  This is not substantially different from the  current process in which the DPE or ASI examines the applicant™s passport, driver™s license, or other government issued ID.  The temporary certificate  could easily include the photographic image. SAFE, Inc. 80 Valley Grove Cove, Cordova, TN 38018   www.safepilots.org    FAA-2010-1127      17 January 2011 Page -3-     Good v Expired  SAFE observes that it is a semantic difference only to say that a pilot certificate is good until  ﬁsurrendered, suspended, or revokedﬂ if the certificate may not be exercised when the corresponding photograph has expired.  In practice, this rulemaking will result in the expiration of a certificate.  The   FAA has chosen to expire photographs at eight years.  The Department of State, by contrast, has determined that a passport photo is good for ten years.    If a pilot certificate is to expire when a photograph is stale, then the standard term should be aligned with the passport policy.    Recommendation : Make the term ten years. $50 per Certificate The NPRM suggests a fee of $22 per certificate.  Supplemental document FAA-2010-1127-0004.1  describes a higher fee proposal of $50 for a new cer tificate and $25 for replacement certificates.  The SAFE membership objects to the fee generally, citing  the existing and adequate funding for the FAA from aviation fuel taxes.  Recommendation : No fee should be charged by the FAA for certificates.  Burden on Flight Instructors  The NPRM describes the issuance of photo certificates to flight instructors.  The proposed language for §61.19(a)(1) indicates that the FAA considers that th e flight instructor certificate is a pilot certificate, ﬁExcept for a student pilot certificate or flight in structor certificate issued with an expiration date, a  pilot certificate is valid unless it is surrendered, suspended, or revoked.ﬂ  One may logically conclude  that the FAA intends to apply the photo requirement  and all of its fees to instructor certificates.  On the other hand, a flight instructor certificate is invalid without an accompanying pilot certificate.    This implies that a flight instructor certificate is not  a pilot certificate.  There is no reason therefore to assume that IRTPA is mandating photos for flight instructors. Flight instructor certificates expire every two years.   This makes instructors the most adversely affected  group of airmen under the NPRM.  The FAA estimates the total cost of a certifi cate to an applicant at $210.35.  Furthermore, a young, career-oriented pilot will typically earn several certificates in quick succession: Commercial single-engine, Commercial mult i-engine, Flight Instructor Single engine, Flight  Instructor Multiengine, Flight Instructor Instrument Airplane.  This amounts to a thousand dollars just  in certificate costs at initial issuance, followed by reissuance at recurring cost every two years for the flight instructor.  Recommendation : SAFE advocates issuance of flight instructor certificates without charge as currently  obtains.  Flight instructor certificates do not requi re photos or other biometric data.  This is in compliance with IRTPA.  Student Pilots The FAA proposes that student pilots apply for a photo certificate six to eight weeks prior to the date  of intended first solo.  Students, flight schools, and instructors are urged to plan accordingly.  Insofar as an accelerated curriculum may allow a student to prog ress from first flight to practical test in fourteen  days, this is an impediment to the flight training in dustry for the convenience of the FAA.  Fifty states are able to issue driver™s licenses on demand.  The Department of State can issue a passport on the  same day, if you visit a passport office.    Recommendation : SAFE recommends that a student pilot app licant be able to upload an image on-line  using the existing paperless IACRA system.  The applicant could print his or her own provisional  SAFE, Inc. 80 Valley Grove Cove, Cordova, TN 38018   www.safepilots.org    FAA-2010-1127      17 January 2011 Page -4-     certificate with photo.  The image would be verified  by an instructor prior to endorsing the certificate for solo flight.  The agency should issue student  pilot certificates ﬁnot valid beforeﬂ the student™s  sixteenth birthday.  This would allow for the traditional first solo on the sixteenth birthday.  This would  be a benefit to students who must wait until the morning of their sixteenth birthday to get a medical certificate.  Today, those students who have a birt hday that falls on a day when the doctor™s office is  not open are precluded from soloing. Knowledge Testing Centers  The FAA asserts that knowledge testing centers will process certificate applications for $42.50 each.   Testing centers are profit-seeking organizations, whose prices are not under the control of the FAA.   There are only two authorized testing companies,  whose prices reflect conscious parallelism.  Earlier  this year, the prices of FAA tests increased 50%, well above the rate of inflation.  There can be no assurance to pilots that the price for application processing will not increase substantially above the estimate of $42.50.  Recommendation : SAFE advocates a paperless application process that does not include testing centers  or paper photographs. Likely Cost of Production  The FAA is entitled under statute to increase the pr ice of certificates up to the cost of production, currently estimated at $54.25 per certificate.  In the NPRM, the FAA estimates contractor costs of $5.2  million to implement secure photo certificates with biometric capability.  A similar program in the  maritime industry, TWIC, which provides biometric ID cards for 1.2 million port workers, has seen its  costs increase to $132 per issuance.  SAFE believes that the costs of photo certificate production will  far exceed the current estimates and specifically  the $5.2 million budgeted for contractor work.   CERTIFICATES ONLY  TWIC ExperienceFAA Estimate  FAA Likely Experience Per Certificate Cost  $132.50$54.25$132.50Population 1,200,000740,000740,000Initial Issuance  $159,000,000.00 $40,145,000.00 $98,050,000.00Twenty Year Issu ance 4,403,5404,403,540Twenty Year Cost  $239,655,257.00 $583,469,050.00  Recommendation : SAFE recommends that the proposed rulema king be delayed until the budget cost numbers can be verified, using the DHS TWIC program as a precedent for study.  Biometrics  In November 2001, under the provisions of P.L. 107-71 Congress established a requirement for credentialing of pilots requiring access to an airport.  This biometric ID is the Transportation Worker  Identity Credential (TWIC).  IRTPA also describes  biometric features on a pilot™s license.  The NPRM describes no provisions for biometric identification.  If the FAA subsequently decides to implement  biometric features, this would represent a third ov erhaul of the airmen certificate in ten years.    SAFE believes it would be a waste of society™s resources to change airmen certificates three times in ten  years.  The certificate issuance process described in the NPRM is incompatible with the secure collection of biometric data.  SAFE, Inc. 80 Valley Grove Cove, Cordova, TN 38018   www.safepilots.org    FAA-2010-1127      17 January 2011 Page -5-     SAFE, Inc. 80 Valley Grove Cove, Cordova, TN 38018   www.safepilots.org    Recommendation : SAFE supports the concept of an airmen certificate with smart card and biometric  features provided this same credential could be  used for airport access compliant with TSA Security  Directive 1542-04-08G in the same way that the TWIC card allows unescorted access to seaport  facilities.  This would reduce the burden on airmen who are required to possess a separate ID for each airport and FBO they visit regularly.   Aeromedical Examiners  SAFE disagrees that collecting a photographic image is burdensome on an aeromedical examiner (AME).  A digital image is simply another form of bi ometric data, just like weight, height, and eye color.   If it is burdensome to collect a picture, then it is similarly burdensome to collect eye color, a bodily  attribute that does not have anything to do with the  health of the candidate.  If the AME is the logical party to collect biometric data, as the AME does already , this is an option that must be investigated and not summarily dismissed.  SAFE believes that if the FAA intends to spend close to a half-billion dollars  on this effort, the procedure should be designed by experts, and not a patchwork based on whatever is   easiest at the moment.  It is pointless to simply substitute the pilot™s photo for the Wright Brothers™ and call it a day. Recommendation : SAFE recommends that the rulemaking be  delayed until the FAA has developed a workable business process for issuance of airmen certificates that is:  (a) secure, (b) cost effective, (c) anticipates technological developments, and  (d) provides operational benefits to airmen. Doing it right the second time  The Pilot Photo ID program needs to be well thought out, as the implementation of TWIC in the maritime industry was not.  The maritime industry  learned many lessons that the FAA should consider before engaging it its second certificate overhaul in ten years.  Failure to do so with proper forethought  will result in a third overhaul, with all of its attendant effort and expense again, before this program is  complete. The FAA has the opportunity to plan properly and do a job that could make ever yone™s life easier: the pilot, the FAA, and all of the DHS agencies who want photos, fingerprints, and demographic data for   their dossiers.  Recommendation : Stop the process now.  Take the time to th ink this out from first principles. Engage the input and assistance of the aviation community.  Then do it right.  SAFE stands ready to help your staff develop a st atement of requirements and a workplan for success if  you so desire.  Sincerely The Society of Aviation and Flight Educators  Doug Stewart, Chairman  Mr. Terry Sweat. 419 Brierhedge Rd .Ł Covington, TN 38019 Ł (901) 476-9470 December 27,2010 TO: Docket Operations, M-30 U. S. Department of Transportation 1200 New Jersey Avenue SE Room W12-140 West Bldg Ground floor Washington, DC 20590-0001 Ref: Rule making -Photo Pilot certificate I W 1] Ld co ..D It has come to my attention that the FAA is proposing to put a photo on the certificate of all pilots in the US. This after we just got thru changing out all our paper certificates for a plastic one. Neither of these changes will do anything to enhance security. I have never known a pilot that had to show their pilot certificate to fly an airplane. This will cost a lot of money and further burden pilots in America with only the elusion of security. This is just another intrusion into the lives of American citizens by a large government bureaucracy with no gain. We need to stop allowing terrorist to dictate policy for our government. If you are truly interested in keeping airplanes out of the hands of terrorist, then the checking should be done before the certificate is issued not after. Sincerely  01/18/2011 18:49 5302734058 MCGREW 8, ASSOCIATES PAGE 02 Response to NPRM [Docket No. FAA-2010-l 127; Notice No. 2010-161 S^^ OF NPRM Question #1: \"(Vhik this proposal does not outline specific identity verification standards and[>roc\\'isMiA%KytM may include such standards and processes in a final rule. The FAA seeks comment on standards that-sho^fd he used for identity verification to issue pilot photo certificates, either in person or remotely Should the FAA requifiiappt^carMt (r>^^ produce Jraud-rcsisiani documents to verify identity? If so. which documents or other identity verification procedure\\'s sMb^i^ the FAA implement to ensure a high level of confidence in the verification process?\" \\\\) TheTSA(Part Vof49CFR part 1552) already requires thai a Flight Schools / Flight Training pruvider must determine whether an individual is a citizen or national of the United States with either a passport or a birth certificate. 2) It is both duplicative and wasteful for the FAA to require the same thing that the ISA requires. Undoubtedly, the FAAS wording, tracking, and documentation requirements would be different than the TSA\\'s; which would result in both confusion and wasted lime. 3) In addition; this requirement in general is useless as the vast majority of flight training providers are NOT trained to recognize falsified, altered or forged documents. Nor should they be. 4) SUGGESTION FOR IDENTIY VERIFICATION AT THE FLIGHT TRAINING PROVIDER LEVEL: a) Any government issued photo identification should be allowed for identity verification. b) The names of the individuals should be given to the TSA using the process that already exists (web based input into their data-base) so the TSA can perform their function of identity / citizenship verification. NPRM Question #2; \\'\\'Should the FAA consider an alternative implementation approach to the \\' \\'trigger\\'\\' and \\' \\'non-trigger \\' Ł approach set forth in the proposal? Should the FAA set one deadline, regardless of certificate level, for pilots to have a pilot certificate vith photo to exercise the privileges of that certificate rather than implement the phased \\' \\'non-trigger\\'\\' approach set forth in this proposal? What is the basis and supporting data for a single deadline? If the FAA were to implement a single deadline, what time period for conversion to a pilot certificate with photo adequately balances the FAA \\'s need to comply with the statutory mandate and the burden on certificate holders? Would lengthening the implementation period significantly reduce burden on a pilot? What is the basis and supporting data for a longer time period? \" 1) If adopted, the least costly and intrusive answer would be to adopt a \\'non-trigger\\' only approach. Current pilot licenses have been issued and used and should be valid for the time as is currently established. If/ when a pilot must obtain a new license, for any reason, THEN is when the new format should come into place. This would allow for absorption of costs as well as minimize impact on the flying community. NPRM Question #3: \\'\\'Currently, the FAA envisions using Knowledge Testing Centers. DPEs, and FSDOs to accept pilot certificate applications and validate applicant identity. Are there alternative, potentially less burdensome, methods for pilots within the U S. and outside of the U. S the FAA should consider? In addition, what should the FAA consider when des ignatlng .service providers with identity verification authority? \" \\\\) Service providers are not trained 10 recognize falsified, altered or forged documents. Nor should ihey be. 2) Any form of government issued, photo identification should the standard for training providers\\' identification verification. 3) The names of the individuals should be given to the TSA using the process that already exists (web based input into their data-base) so the TSA can perform their function of identity / citizenship verification. 4) Neither DPF,\\'s nor KTC\\'s should be forced or held accountable for identity verification at the level thai is implied by the FAA\\'S NPRM. This is the job of the TSA and, as such, DPE/KTC\\'s should only be required to provide the names to the TSA for identity verification and threat analysis. 01/18/2011 18:49 5302734056 MCGREW & ASSOCIATES PAGE 03 NPRM Question #4: \"Is the proposed 8-year duration for the photo, based on the photo duration for state driver s licen.ses under ihc Rea IID Act, a reasonable period of time that balances the security needs expressed in IRTPA and the burden on certificate holders? Are there other standards or guidance for photo accuracy the FAA should consider? What is the basis and supporting data for a shorter or longer duration? \" 1) When issued, an 8-year photo duration is reasonable. NPRM Question #5; \"\\'Is there any reason why student pilot certificates should not be treated like other pilot certificates for the purposes of meeting the IRTPA requirements? What is the basis and supporting data for your response?\\'\\' FAA Students pilots should NOT be required to obtain pUstic/photo ID student pilot certificates: 1) Provides no additional identification or security verification: Certified Flight Instructor\\'s (CFI) / flight schools must already have verified the student\\'s identification with both a photo ID and either a binh certificate or passport. Additionally, students must already carry a government issued photo ID, A plastic / photo student ID. which is temporary in nature, will do nothing to improve neither the identification nor security processes. 2) Wasteful for the government: As is currently stated (in the NPRM), the $22 fee does not cover the cost of this plastic, photo ID card. Further, this is a temporary privilege whereby the student is flying under the CFl\\'s authorization. Even when the fees go up, it is likely the costs will still not be covered. This will be a large, unnecessary cost burden on the government for something that is unnecessary. 3) Costly and wasteful for the student: The student certificate could be used for as little as a few weeks and then, when the student completed his/her training, he/she would be forced to pay yet another fee for yet another plastic certificate. Also, as stated, the student must provide the picture - this forces him/her to obtain a digital camera of high enough quality to provide this photo. a) An additional barrier to pilot training: The U.S. already has a high dropout rate (80% per the last AOPA convention), this is an additional nuisance and nuisance fee that will in no way help this statistic. b) Forcing students to obtain a plastic, photo, temporary certificate is a waste of materials, money, lime and assets. It unduly burdens the student, training provider, and government. 4) DO NOT TAKE AWAY THE ABILITY FOR AMES AND DPE\\'S TO ISSUE STUDENT CERTIFICATES: The wording of the proposal makes it such that the ONLY ways to obtain a student pilot certificate are either by going to the FSDO or by application through a DPE. a) There are only 96 FSDO\\'s country wide, they are NOT open on the weekends, holidays or after hours, it is during these \"after hours\" times that the vast majority of students obtain their student certificates, because the vast majority of student pilots have a job. This not only severely limits the ability to obtain student certificates; it also places the majority of the burden on DPE\\'s. b) DPE\\'s will, undoubtedly charge a fee for the process of receiving an application, photo and processing to the FAA. This is yet another financial burden on the student. c) One of the primary functions of an AME is to ensure the person seeking a pilot medical / student pilot certificate is to perform a cursory assessment of the applicants\\' mental stability. As a matter of convenience, most students obtain their student certificate at the same time as the pilot medical. The result of this scenario is that most students obtain their medical early in the training process - which means they are also subjected to the AME\\'s scrutiny. Forcing a process that not only eliminates the AME from this cycle, but actually discourages this early examination puts the CFI, the student and the general populace (that the student is flying over) at a higher risk. 5) SUGGESTION FOR STUDENT PILOT CERTIFICATES: a) Keep the current student \\'paper\\' certificate process in place. b) Also retain the current requirement for the CFI / Flight School to verify identification with both a government issued photo ID and either a passport or birth certificate. 01/18/2011 18:49 5302734056 MCGREW a ASSOCIATES PAGE 04 c) Since the person\\'s name is already submitted to the FAA for the student certificate, aimplv ensure the FAA transmits these names to the TSA for risk evaluation using the TSA\\'s already existing process. d) The cost for this is $0 NPRM Question #6; \"With respect to the photo that is placed on the pilot certificate, should the FAA accept only hard copy photos, only digitally-captured photos, or either hard copy or digitally-captured photos? What is the basis and supporting data for your response? \" 1) Only digitally-captured photos should be allowed. In today\\'s world of technology, it is cumbersome and costly to handle paper copies. 2) HOWF,VF,R; the TSA already has a process for submitting these photo\\'s which dove-tails into their identity verification process for foreign students. 3) The FAA should simply use the same data-base as the TSA for both identity and the ID photo. This would be both time and cost effective and would also ensure that the information on file with the TSA is the same as that with the FAA. NPRM Question #7: \\'\\'if the FAA accepts digitally-taptured photos, what are the advantages and disadvantages of the following methods of acquiring the photo: (a) An applicant uploading a self-captured phoco to the lACRA subsystem; (b) a FSDO capturing the photo when the application Is submitted; (c) a Knowledge Testing Center capturing the photo when an application Is submitted; and Cd) a DPE capturing the photo when an application is submitted? What is the basis and supporting data for your response?\" 1) Forcing an applicant to go to a FSDO (which is only open during business hours) or anywhere is costly and cumbersome. Applicants should be able to upload a digital photo. However, it should be required that any other state/federal \"agency\" verify the photo matches the person\\'s name. This could be any CFI, Flight School, AME, KTC, DPE, FSDO and even a DMV office or photo\\'s already on file with the TSA). ALSO, it should be allowed thai the applicant submit any other form of government issued photo identification (simply scan and attach). This would, obviously, be the primary method for out-of-country pilots-2) The simple and most cost effective answer is to allow a digital photo to be uploaded by any means (applicant, flight training provider, DPE, KTC, AME or FSDO). And then the photo is verified by the agency / person submitting the application (CFI, DPE, KTC representative, AME or FSDO) through the current 1 ACRA process. 3) Again, the TSA already uses a process for photo submission and identity verification. An even better answer would be to have the TSA accomplish the entire identity verification and threat assessment. Then, the other agencies (FAA) would use the same database as the TSA for license photo attachment and administration. PROPOSED AMMENDMENTS TO \\'FAR\\' CHAPTERS: 1, REGARDING THENPRM\\'S RECOMMENDED CHANCE TO PARAGRAPH 613 (\"Requirement for certificates, ratinge, and authorizations.\"): As currently stated the recommended wording for sub-paragraph (a) (v) states that, \"... a person may not serve a.<! a required pilot flight crewmemher of a cml aircraft of the United States, unless that person . . . (v) When operating; an aircraft within a foreign country, has a pilot license issued by that country. \" a) This seems to say, for example, that a pilot could not fly a civil aircraft to Mexico unless he/she has a Mexican pilot\\'s license. b) If so, it is unreasonable for the U.S. FAA to levy requirements of how to operate in a different country - isn\"t that that the prevue of that country to dictate its own rules? If Mexico allows pilots to operate U.S. registry aircraft with a U.S. issued pilot\\'s license - why are we trying to dictate otherwise. c) ALSO - this has the potential to absolutely CR1.1SH such charitable organization as Doctor\\'s Without Borders and the Mission Aviation Fellowship. d) Recommend eliminating that paragraph: (a) (v) 01/18/2011 18:49 5302734056 MCGREW & ASSOCIATES PAGE 05 ADDITIONAL COMMENTS: 1) While adding a photo to the pilot\\'s license is generally a good idea, the prohibitive costs and time consumption necessitate a slow, methodical implementation. The least intrusive for everyone involved is to simply have the NEXT pilot license application result in a license with a photo (using processes mentioned). 2) Identification verification should remain the responsibility of the TSA and not rammed down the throats of training providers and others who are neither equipped nor trained. The exception to this is to allow the training provider to verify that the submitted photo is that of the applicant (which the TSA already uses). 3) CFI licenses already require it to be accompanied by the CFI\\'s pilot license...so there should be NO PHOTO requirement on the CFI license itself Authorts): Dennis K. Pearson; CFI/CFII/MEI, Flight School owner Contact: dennis.k.pearson@gmail.com v^.V^/^;? TJT^^^  FROM :PRAIRIE flIR SERUICE FRX NO. :316 778 1712 Feb. 17 2011 03:46PM PI ŁjhPARTMENTOF Prairie Air Service, Inc. \"\\'\\'\\':\\'.o-\\'npTA7inM 3481 S.W. Shady Lane Benton, KS 67017-9154 (316)778-1712 ŁB OPERATIONS :\":!! FEB !1 P U^ 2 b February 17, 2011 Subject: Docket Number FAA-2010-1127, Notice No. 2010-6 To Whom It May Concern: I consider the proposed changes to 14CFR 61.3 and the new part 61.6 unnecessary and extremely detrimental due to the delay in the issuance of new pilot certificates. 14CFR61.3(a)(1)&(2) as presently in effect provides an easy method of positive identification of pilots. However, it is my understanding that this proposed regulation is driven by a congressional requirement and that the FAA may not have much choice in the matter, similar to the ELT requirements being imposed by congressional edict in the early 1970s. Even though I oppose the proposed regulations I am submitting the following comments and suggestions to eliminate the potentially adverse effect which the new rules have in their proposed fonri. The major concern I have is the delay in the issuance of new initial pilot certificates. I operate a small flight school specializing primarily in advanced flight instruction, and am very concerned at>out this anticipated 6 to 8 week delay. The proposed regulations do not directly address pilot certificates issued on the basis of a foreign pilot license as per 14CFR61.75. However, it appears that the requirements of the proposed 14CFR61.6(c) apply the issuance of a restricted pilot certificate as per 61.75 and would cause the same delay as the initial issuance of a student pilot certificate. Many foreign pilots receive a 61.75 certificate to rent planes while vacationing in the United States or to add a rating. At the present time foreign pilots already have to submit license verification to the FAA before they can be issued a 61.75 certificate. An additional delay of 6 to 8 weeks would be completely unacceptable and disastrous. Since most foreign pilots would not be able to submit a FAA Form 8710-1 at a FAA FSDO in their native country, they would in effect have to travel to the USA twice; First, to submit the Form 8710-1 at a FSDO, and then a second visit after issuance of their 61.75 certificate to exercise the privileges of that certificate, either rental or training to add an additional rating. This would have an extremely adverse effect on businesses providing aircraft rental or training to foreign pilots. This could be addressed in 2 ways: (1) Treat newly issued temporary certificates (student pilot through ATP) like a facsimile airman certificate issued under 14CFR 61.29(e), except with a validity of 120 days and valid only when accompanied by a government issued picture identification as per the present 14CFR61.3(a)(2). (2) Provide space on the temporary certificate form (revised version of Form 8060-4) to add a photograph. Many FBOs and flight instuctors own \"3 in 1\" scanner-copier-printer equipment or basic photocopiers. The easiest method would be to affix a photo to a completed but not yet FROM :PRftIRIE flIR SERVICE FAX NO. :316 778 1712 Feb. 17 2011 03:46PM P2 Signed Form 8060-4, and then make a photocopy. Thereafter the original and the photocopy are signed by the DPE or inspector and applicant. The applicant is issued the copy (with original signatures), and the DPE (or inspector) submits the original with the attached photo, along with the Form 8710-1 and other supporting documents to the FAA for processing. This could also be done for an lACRA generated Form 8060-4, with a provision to upload a photograph. At the present time many individual flight instructors and flight schools are equipped to photograph foreign citizen flight students and are familiar with uploading the photos to TSA. These individuals or schools would be able to provide the same services to all pilots, and upload the photos to the FAA (for a nominal fee). A photo upload should be an option when a temporary pilot certificate is issued utilizing lACRA. Uploading of photographs should be limited to individuals other than the applicant himself, such as CFIs, DPEs, AMEs or FSDO inspectors. For a temporary certificate even a black and white copy on any old photocopier should suffice. This would still be a better quality image than the temporary drivers licenses presently issued by Kansas and printed on cash register type thermal paper. Alternatively, a Form 8060-4 (present or revised version) could be scanned, a digital photo could be pasted onto \"it using Photoshop or similar software, and the combined image could be printed twice, and then signed by the FAA inspector or DPE, with the applicant receiving one copy and the other copy submitted to the FAA. In the absence of a photocopier a photograph could be affixed to the applicant\\'s copy of the Fonm 8060-4(or later version), and authenticated by the DPE\\'s or inspectors signature placed on the photograph. As far as the cost of issuance of a new photo pilot certificate is concerned, I consider It to be negligible. It will be a minor cost increase for a pilot who rapidly progresses from student pilot to commercial with instrument and multiengine ratings, as many of our customers do. Including a new photo type temporary student certificate, these individuals would be issued as many as 6 photo pilot certificates in rapid succession, which would cost a total of $ 132.00 at the proposed fee as per 14CFR61.6(d). Considering the total cost of the flight training, this amount is a negligible percentage. For lACRA applications there needs to be a provision for credit card payment. Concerning the other pnDvisions of the proposed rules, such as trigger events, replacement, etc., these would not pose a significant burden on active pilots, but may cause \"occasional\" pilots to completely drop out of flying instead of obtaining a photo pilot certificate. This may especially be the case in rural areas v^ere DPE\\'s are not readily available to process applications for new photo pilot certificates. Sincerely, Herbert Pello ATP-ASMEL. CFI-ASMEI  February 2, 2011 ŁF^ARTMENTOF ;(AMSPORW!ON ::KriOFER/Vr!ONS ;0I! FEB 10 P 3- 05 Docket Operations, M-30 U.S. Department of Transportation 1200 New Jersey Avenue, SE, Room W12-140, West Building Ground Floor Washington, D.C. 20590-0001 Re: Docket Number FAA-2010-1127 Gentlemen: As a private pilot since 1967, it is my sincere belief that the proposed rule for photo ID pilot certificates will not accomplish any greater security for our country, but will only further damage the very fragile general aviation community, thereby further damaging our national economy and national transportation system. It is my feeling that the current FAA-issued (tamper-proof) pilot certificate, along with any government-issued photo ID, such as a state driver\\'s license or a state-issued photo Concealed Carry Permit is more than adequate and is properly documented. The proposed rule is extremely complex, expensive, and difficult to comply with, and will cause much confusion. I urge you to leave the pilot certificate (as just recently changed) as it is. Sincerely, Jeanette Hoynacki 1652 Indian Point Road Branson, MO 65616 417 338-2225 jan@hoynacki.com  This   Photo Requirements for Pilot Certificates    proposal is unnecessary. The current  system is adequate to ensure positive ID of all pilots.    This proposal goes about implementation of the addition of photographs to a pilot  certificate in a way that makes   it labor intensive, complicated and inconvenient to  everyone involved.   This  FAA photo certificate  proposal, if it were to be implemented, means it is time to  make the switch to a 100% IACRA   based airman certificate issuance policy.    For those  reading my c omments and   I ntegrated  A irman  C ertification and  R ating  A pplication.  https://iacra.faa.gov/iacra/        the only way to implement the   photo certificate   proposal  in a cost effective way.   The FAA has a lot of time and money invested in IACRA. Everyone I talk to who uses  IACRA likes IACRA. It only makes sense to fully utilize IACRA to implement this  proposal.  It will actually save money elsewhere in the FAA certifica te processing system  as no more paper pilot applications would be accepted for any reason.    I know that some reading this will feel that going to a 100% IACRA system of pilot  application processing is outside the scope of this FAA proposal, but it really i  because it helps to implement the photograph requirements  proposed in Docket ID  FAA - 2010 - 1127 in a cost effective manner.    the switch to 100%  IACRA  c ould result in NO   NEED TO CHARGE $22.   Regarding collection   of fees by the FAA:   Th e   fee collection   an d  verification  should only be allowed by submission of the $22 fee  at the time the application for the airman certificate is filled out using the IACRA system.  There can be a process added to the application to make a  charge to a credit or debit  card, electronic check, and for those people who do not wish to pay that way, alternate  methods like mailing in a payment prior to filling out or completing the IACRA  application prior to submission to the Designee/Inspector, wi th a receipt number that  could later be associated with a IACRA application in order to complete the application.  (similar to the current method of associating of a written test ID number to a IACRA  application)   FAA Inspectors and Designees should not be e xpected to collect or forward fees to the  F ederal Aviation Administration   on behalf of applicants. Keep them out of the   government   fee collection process.   Regarding the  methods of adding   photographs   to FAA Pilot Certificates:   If this proposal were to go fo rward, it needs to be modified in order to minimize cost and  complexity to the pilot s   and to the FAA. In order to keep costs as low as possible this  rule should not be implemented until the photos can be handled 100% digitally.    When one looks at what the  states do for photographs on  driver l icenses, it is  clear   that  they take a   digital   photograph;  it is  then printed directly on the license. There is no  handling of a paper photograph.  It is instantly incorporated into the state driver license  database.   The  states do not process paper photographs for driver licenses. They  went  digital  more than   a decade ago .   Clearly, t his proposal should not be implemented using paper photograph   submissions .   As a Designated Pilot Examiner, I do not see a significant cost to m e or the pilot  applicant associated with the submission of a digital image to an IACRA based pilot  certificate issuance.   I rarely issue Student Pilot certificates but I anticipate that I would begin to process  more of these types of certificates if the  FAA   Designated Aviation Medical Examiner  is  no longer allowed to do so.    I  do   charge a  small  fee for processing Student Pilot certificates  but it would not make  much difference to me in time or cost if  a  photograph   was required to be submitted  and  it   was dig ital and the entire process was handled through the IACRA system.     Processing paper airman files and paper photographs would be more burdensome and  would cost more for the applicant.   Since the proposal is to treat Student Pilot certificates like all other  pilot certificates, the  FAA should allow the Designees to process the  Student Pilot  IACRA applications,  submit the digital photos and issue temporary Student Pilot certificates just  as they do   for  all other grades of pilot certificates.   Student Pilot Certi ficates  should also   be treated  the same as other pilot certificates with regard the 120 day expiration of a temporary  paper certificate.    The process for a student pilot to get a certificate issued should be as simple and  painless as possible. These people   are  so  not familiar with the FAA and their  processes.    to wait 6   to 8 weeks   to get a plastic pilot certificate back from the FAA before they can  solo an airplane. Steps need to be   taken to make people want to learn to fly, not  discourage them.   If  a   Student Pilot certificate  is   treated like all other  types of  pilot certificates,  it   w ould   also  make the development costs for the  software  modifications to the IACRA system lower  since t he rules for processing the applications would be similar for each type of pilot  certificate.   When it is time for the   application for and/or   issuance of any  FAA  Pilot Certificate  (including the Student Pilot Certificate) ,   this should only be done through t he use of the  IACRA system. The IACRA system can be slightly modified to allow the upload of a  digital photo, one that was either taken by the FAA Inspector, the Designated Examiner  (or other FAA designee),   uploaded to the IACRA system by the applicant (fo r those who  are computer savvy)  or was provided to  the FAA inspector o r   Designee   in person by the  p ilot  a pplicant using a digital storage medium such as a USB stick (and of course the  applicant  s  image would be verified by the FAA Inspector or Designee). This will res ult  in little  or no  cost to the applicant for the pilot certificate.    Since   the FAA would only be  electronically receiving,  storing and manipulating digital  image files for placement on the pilot certificates, it would be easy to place the image on  the tem porary Airman Certificate at the time it is printed out  by the FAA Inspector or  Designee .   There would be no doubt that the temporary certificate belongs to that  individual.   Exercising Student Pilot solo privileges  using a paper temporary certificate  for t he  relatively short interval of 120  days from issuance of the paper temporary certificate to  the issuance of the plastic certificate is not  contrary to the intent of the proposal   since  the paper copy  c  printed on 8.5 x 11 in ch paper   so there is plenty of room on the temporary certificate to  print a picture of the student pilot on it .  T he FAA could even require the carrying of an   alternate  approved  photo ID during the use of the paper temporary certificate, even  when  i ssued as a temporary replacement for a lost or stolen certificate.    Refraining from following the way the State Department processes US Passports   would  eliminate the   need  for   the FAA to hand process photographs and airman files , saving  pilots and taxpayers millions of dollars.   The IACRA system is perfectly positioned to handle photographs on pilot certificates   in  a cost  consciou s, efficient   manner.   If this is   proposal is   really going to  move forward ,  this is an opportunity   for the FAA to implement this proposal at the lowest cost and  burden possible   to the pilots and taxpayers .     To the specific questions asked in the proposal:   1.   The FAA should  require/ use the current methods of ID verification for the initial  application for a Pilot certificate; Governm ent issued photo ID, etc.     2.   The phase in, if there must be one, should be one  just like the way  plastic  certificates   were phased in .  As they are issued   going forward , put a photo on  them and then have a  one  final cutoff date.  There are people with Commercia l   to get a new pilot certificate sooner than a Private pilot?     3.   All of these entities are either FAA employees or Designees. They are already  trusted with the issuance of certif ication documents, so they are the logical  choices for accepting the photos. Using others outside the FAA system is adding  complexity and oversight cost.     4.   Duration: A US Passport is good for 10   years.   Why not use that interval instead  of 8   years ?     5.   I includ ed my thoughts on the Student Pilot certificate changes in my comments  above. The Student certificate should be treated as all others with the exception  that the student pilot should be allowed to operate with a temporary certificate  using the submitted di gital image of themselves   that would be printed on the  temporary certificate   and an alternate ID   (as the FAA requires of pilots today) ,  until such time they receive the plastic certificate from the FAA or 120 days,  whichever comes first .     6.   As stated above,  only digital p hotos.  Cost savings to the pilot and taxpayers is  obvious. Make it .jpg format only. This is probably the most common image  format in the world.  Accepting a paper photograph that would need to be  scanned electronically by someone at the FAA t o convert it back into a digital  format makes no sense   to anyone outside of government .     7.   As discussed above ,   a ny method of capture of the photo is acceptable as long as  there is an opportunity for the FAA Inspector  ( or Designee )   to look at it and verify  it   before the issuance of any temporary certificate.       Sincerely,     William Baumheuter   Designated Pilot Examiner #CE03153    *- / -PARTMENT OF \\' Ł\\' ^- KSPORTATION Frank Brooks Black ;Ł .\\'^~t OPERMIONS 2955 NE 19\"\\' Street Pompano Beach, Fl. Łm FEB -3 A 10 UU 33062 January 28,2011 Docket Operations M-30 US Department of Transportation 1200 New Jersey Avenue SE Room W12-140 West Building Ground Floor Washington, DC 20590-0001 Docket No. FAA-2010-1127 Notice No. 2010-16 Gentlemen: I thought the issue of a photo pilot certificate was resolved years ago by using a government issued photo identification. As a Designated Pilot Examiner, I may accept a USA driver\\'s license, a USA Armed Forces identity card or a passport to verify the identity of an applicant. If the photograph must appear on the pilot certificate there are several questions that need to be resolved. What should be the standard for verification of the photo? It should be a color photograph, in focus, that clearly shows the pilot\\'s facial features. A passport photograph should be the photo standard. The pilot must sign the back side of the photograph in black ink. The person accepting the photograph with the application for a pilot certificate must verify that the applicant is the person in the photograph and indicate such on the application. Another checkbox in the Examiner\\'s Report on page 2 of the 8710 application should suffice. What should be considered when giving DPEs identity verification authority? We already have the authority. We verify the applicant\\'s identity with a USA driver\\'s license, US Armed Forces identity card or a passport. If the applicant shows one of these and the photograph is that of the applicant, then we should be allowed to proceed with the application for a photo .pilot certificate. Should only hard copy photographs be accepted? In the beginning only hardcopy photographs and paper applications should be used. It is too easy to attach a digital photograph to the wrong file. Correcting such an error would be a nightmare. Should the applicant be allowed to upload his digital photograph in lACRA? Absolutely not. Many applicants have trouble completing their lACRA application now. Adding the task of their photograph would be too much for them. It would be better for the uploading to be done by the FAA Inspector or the DPE when verifying the applicant\\'s identity. Will the issuance of a temporary Private, Commercial or ATP pilot certificate allow the pilot to fly for up to 120 days without a photo pilot certificate? When I complete an lACRA checkride I disable the superseded pilot by cutting out the DOT seal. When I complete a paper application checkride the superseded pilot certificate is attached to the file sent to Oklahoma City for review by the Document Examiners. What about Student Pilots? Waiting 6-8 weeks to receive a photo Student Pilot certificate is too long. A student will be ready to solo withing 10-15 hours of instruction. This could be done in two weeks. Then the student will tread water waiting for his photo Student Pilot certificate so he can solo. This will have a big negative impact on flight schools and student training. I suggest exempting Student Pilots fi-om having a photo pilot certificate. They are tightly controlled by their instructors and their flight schools as to when they fly, dual or solo. If exempted, then the current policy of having AMEs issue a combination medical and student pilot certificate can continue. Is the photograph stapled to the application or enclosed? The photograph should be stapled to the application. Over the years files and pages fi-om files have been lost in Oklahoma City. I recommend that the photo pilot certificate have a life of ten years as is the case with passports instead of eight years as proposed. For a pilot having a 40 year career this would eliminate the cost of one renewal. Thank you for considering my thoughts. Sincerely, Frank Brooks Black DPE SO19-1790169  NationalAssociation ofFlightInstructors730GrandSt.Allegan,MI49010 866.806.6156February 15, 2011 Docket Operations, M-30 U.S. Department of Transportation  1200 New Jersey Avenue, SE  West Building Ground Floor, Room W12-140  Washington, DC 20590-0001   Subject: Docket No. FAA-2010-1127-0001 Photo Requirements for Pilot  Certificates  The National Association of Flight Instructors (NAFI) appreciates the opportunity to represent our membership and take part in the rulemaking process, with the end goal of  improving security in aviation operations.   In response to the Notice of Proposed Rulemaking issued November 19, 2010, entitled  Photo ID Requirements for Pilot Certificates , NAFI respectfully submits the following  remarks. I. Introduction to NAFI   The National Association of Flight Instructors (NAFI) is an international organization  dedicated to raising and maintaining the professional standing of flight instructors. NAFI is the largest flight instructor association with over 5,000 active members and unique and specific represents the interests of the over 90,000 flight instructors in the United States. NAFI has served as the voice of aviation education since inception in 1967 and serves the full spectrum of the flight instructor community. Now, more than ever before, we are moving to enhance this original commitment. The association™s efforts focus on the needs of its members. While members benefit in  different ways from NAFI membership, the most important reason for being a part of NAFI is supporting the flight instructor™s responsibility to all of aviation and commitment to professionalism. II. The Position of the National A ssociation of Flight Instructors NAFI understands and appreciates the ever-changi ng nature of threats to security and the need to mitigate and manage such risks in aviation, not simply the flight training  industry. Therefore, NAFI fully supports a  proposal to enhance pilot certificates which conforms to Public Law 108-458, the Intelligence Reform and Terrorism Prevention Act   (IRTPA) of 2004. NAFI further supports and re cognizes the FAA™s prerogative to make  ﬁmodifications to the airman certification syst em to make the system more efficient in  serving the needs of those enforcing laws related to combating acts of terrorism by  2 ensuring verifiable identification of indi viduals applying for airman certificate,ﬂ1 and that the provisions of this NPRM represent the  first positive attempts at additional security measures in the future. III. Concerns NAFI believes the spirit of the IRTPA was a good faith effort  to enhance and modify the multifaceted security concerns in the United States. Unfortunately, the sections of the act specifically cited in the NPRM as the basis for compliance, namely section 4022, have yet to be executed according to the deadl ines set forth by the act. The IRTPA was signed into law December 17, 2004. According  to the aforementioned section, the act tasked the FAA with implementing the initial issuance of new pilot certificates that ﬁare  resistant to tampering, alteration, or counterfeiting; include a photograph of the individual to whom the certificate is iss ued; and are capable of accommodating a digital photograph, a biometric identifier,  or any other unique identifierﬂ2 to all certificated airman within one year after its passage.   NAFI™s support of security enhancements to the airman certificate does not indicate that NAFI is without some questions relating to  the implementation of  the effort. NAFI understands that the apparently expedited nature of this NPRM may be due, in part, to congressional pressure.3 Nevertheless, while NAFI supports the FAA™s efforts to meet the requirements of the public law and the demands of the legislature, there are specific proposals contained within the NPRM which NA FI is compelled to address on behalf of the membership.  One of the primary concerns that NAFI has with this notice is that it does not appear to  meet the requirements of the IRTPA to include a biometric identifier on the new photo ID airman™s certificate. The notice does acknowledge this mandate and cites the law in  its ﬁbackgroundﬂ section, but no further mention of accommodation for a biometric identifier is present in the rest of the document. Representative John Mica recently recognized the current state of non-compliance in a letter to the FAA, TSA, and the Department of Homeland Security, expressing his distress over the missed deadline for implementation. Most importantly, t hough, a spokesman for Congressman Mica confirmed that the legislature would be decidedly unsatisfied with any final rule which did not contain provisions for a biometric identifier. 4 Though the FAA is allowed some latitude by the Regulatory Flexibility Act, NAFI  believes that it is important to ﬁget it right the first time,ﬂ and concurrently find a cost  effective solution which imposes a minimum financial burden on airmen. NAFI is not   able, without context, to speculate whether or not the biometrics requirements were  omitted in an effort to curb costs to airmen.   If the biometric identifier provision is not addressed in the final rule, the new certificates will not be incompliance with IRTPA  1 Docket No. FAA-2010-1127; Notice No. 2010-16 (ﬁNPRMﬂ)  2 IRTPA Sec 4022.  Note: for the rest of this response, th e term ﬁbiometric identifierﬂ will shall mean any of the  requirements of IRTPA Sec 4022 (b)(3).  3 Freye, 2011.  ﬁFAA Issues Proposals for Pilot Photo IDs.ﬂ  www.aviationnews.us  4 Ibid.   3 requirements.  While a timely response to this mandate is necessary, to avoid future rulemaking and additional cost to the FAA and airmen, NAFI strongly recommends that any final rule must meet all prescribed requirements of P ublic Law 108-458.  Effect on Student Pilots The nature of this legislation will have an  effect on the training provision by flight  instructors who NAFI represents.  Based on this vested interest and the knowledge of potential effects, NAFI regularly provides input on legislation and/or rulemaking which pertains to the flight training industry. With respect to this proposal, NAFI is first  concerned about the ramifications of this NPRM upon student pilots. The NPRM  specifically identifie s student pilots as a community included in the requirement for a  Photo ID. The reason that student pilots are provided such a specific emphasis is  because of a significant shift in protocol suggested by this NPRM.  The implication that  a student pilot would be required to have a photo based pilot certificate prior to solo flight, which according to the NPRM is esti mated to take at least 6-8 weeks, would represent a barrier of timing in flight traini ng.  An additional barrier or cost would be present, requiring an additional step in the  process, the requirement of a medical certificate and a student pilot certificate, two items at  are currently done by one individual, which would now  require two separate certifying individuals to complete. Though the NPRM™s analysis determines that it  would ﬁnot have a significant economic  impact–,ﬂ NAFI disagrees with this statement. The first solo flight is a significant a moment in the training process as the first time in a  student™s training when they are acting as the Pilot in Command of the aircraft. While in theory it is possible for a student to receive dual instruction without possessing a student pilot certificate in the period prior to the first solo flight, this practice does not  represent the industry norm. Student pilots generally obtain a certificate prior to beginning flight training.  A problem is expected related to the turnaround time between application and certificate issuance as estimated by this NPRM. In an economic climate where flight training is  continuously becoming more expensive, one wa y students often reduce costs of flight training is to increase the frequency of their training. This prevents the degradation of valuable skills and knowledge, and will sa ve the student money otherwise wasted on  reviewing previously taught content.5 It is no stretch of the imagination nor any extraordinary circumstance that an individual dedi cated to their flight training could well have completed ground school, passed the required pre-solo test(s), received dual instruction, and be ready to solo well inside of the 6 to 8 week window estimated by the FAA. There exists the potential for indirect costs to student pilots who must wait until they are issued a student pilot certificate in order to solo, but require remedial training once the certificate is issued due to delays. NAFI views this delay in the issuance of  student pilot certificates as strong potential hindrance, economically and educationally, to both student pilots and flight schools.   5 Miller, ND. ﬁGuaranteed best way to cut the cost of flight training.ﬂ  http://www.bobmillerflighttraining.com   4 Effect on Flight Training Industry Very often, prospective students undergo an airman medical examination and subsequently obtain a student pilot certificate on a speculative basis prior to committing to a flight training program. This benefits not only the individuals, but also the flight training industry. It allows students to determine if they are medically fit to fly, and flight schools to administer introductory flights and the first few hours of instruction to gauge the individual™s level of interest and aptit ude. This analysis is quantified by supporting  data from derived from the FAA website, which indicates that that since 2000, the  issuance of student pilot licenses steadily in creased while the certification of private  pilots from 1999 to 2009 precipitously declined 6. . There exists a larger percentage of individuals who demonstrate a legitimate interest in  flight training yet fail to become certificated airmen. Again, NAFI is not able to speculate on the specific reasons for attrition, but finds the 70-80% rate of attrition of student pilots  extremely disconcerting.  A poorly constructed application or certification process to  meet photo or biometric identif ication standards could potentially increase this attrition  rate or even serve as a barrier to initial entry to the profession and/or hobby. Economic Impact The economic impact upon the flight training industry beyond initial certification must not be understated. Students pursuing a career as a professional pilot would theoretically need to be re-issued a pilot certificate on, at the very least, six separate occasions (eg. Student Pilot Certificate, Private Pilot Certificate, Instrument Rating, Commercial Multi Engine, Commercial Single Engine, ATP).  The CFI and CFII certificates are not necessarily addressed, but if included woul d add additional instances. In many cases,  these certificates may be followed by the next succeeding rating or certificate prior to  even receiving the previous certificate based  on processing times, resulting an applicant  or pilot paying for a certificate that is superseded by a new one before even receiving the previous one.  This represents a wasted and unwarranted cost.    NAFI must further recommend that a definite cost schedule be forthcoming prior to the issuance of the final rule. From a purely  observational standpoint, NAFI posits that  response from the aviation community has been overwhelmingly negative, but also   largely speculative apparently due to incomplete analysis of the text of the NPRM. 7 The text of the notice specifically references the original legislative vehicle for the FAA Reauthorization Act, HR 915, which was  introduced last year in the 111th congress. HR 915 would have given the FAA authority to increase the proposed fee for issuance from a $22 maximum to $50. While HR 915 did not pass the 111th congress, it remains a priority in the 112th,8 with the language remaining largely t he same as the original text of  6 See Appendix A for supporting data.  7 2011. ﬁFeds Wrong ŒPilot Photo ID NPRM IS ‚Economically Significant™ﬂ  http://aero- news.net/news/genav.cfm?ContentBlockID=1B27C30F-1A1A-44EF-80C3-7923FE2DF262&Dynamic=1  8 NATA, 2011.  ﬁFAA Reauthorizatio n Legislation.ﬂ  http://www.nata.aero/data/files/gia/2011whitepape rs/2010faareauthorizationlegislationwp.pdf   5 the bill. NAFI therefore does not believe that accurate direct cost-to-pilots estimates can be made given the history of delays9 in reauthorization legislation.  Effectiveness for Security This NPRM is similar in structure to the Transport Workers Identification Credential (TWIC) which was mandated by the Transportation Security Administration for maritime workers and truck drivers. The TWIC has been a cause for complaint not because it   does not conform to IRTPA, but because there currently exists little to no processes for  identification verification, nor infrastructure such as card readers installed at security checkpoints. Traditionally, in practice, the airman certificate has not been used as a form of identification. Rarely are pilots asked to present their certificate as a credential, especially because most pilots  operating at air carrier airports or in the air carrier environment also possess another photo ID iss ued by their employer or the airport which verifies they™ve received a background check and/or security training. While the cost estimates contained within the NPRM pertain only to the cost issuing the certificate itself, it does not address the potential economic impact upon both the government and private sectors for the installation of  hardware compatible with an enhanced airman certificate, nor any new security processes designed to implement and augment the new certificates.  If no designation of funds to verify use the newly proposed ID are  additionally paired with this  effort, then the overall implementation of the overall implementation is without utility and only repr esents a requirement to comply that will  not be verified in the field.  IV. NAFI Recommendations  NAFI Recommends allowance of non-photo  temporary student pilot certificates. NAFI recommends that Student Pilot certificates be allowed to continue to be used for solo operation as currently, in accompaniment with a government issued photo identification.  The st rong oversight relationship that an instructor has with a training student further offers verification of students during their operational periods when they fly under solo conditi ons.  The nature of a student pilot certificate requires a flight instructor to authorize each individual solo flight, offering additional opportunity for verification of identity that is not required once a pilot has been certificated and operates on their own. If the status quo for student pilot certificates is not a viable option, NAFI recommends allowing a short-term temporary paper certificate for student pilot privileges.  The certificate should be issued by the pilot certificate application  acceptance facility at the time the photo certificate is applied for and should have   a 90 day expiration date.  This will allo w uninterrupted flight training while  satisfying the requirement of having pilot photographic identification on file.  Because of the supervised nat ure of flight training, NAFI does not foresee any  additional security risk by allowing tempor ary paper certificates for student pilots   9 Freye, 2010.  ﬁProgress on FAA Reauthorization Unlikely during Lame Duck Session.ﬂ   www.aviationnews.us   6 that would be alleviated by  requiring a photo certificate.  NAFI recommends that the  IRTPA-compliant pilot certificate be issued separate from  an ﬁoperating privileges and limitationsﬂ certificate.  NAFI believes that the FAA™s cost analysis in the NPRM grossly underestimates the financial burden on professional pilots.  The NPRM estimates the financial burden to be $19 per year, based on a renewal every 8 years.  While this may be true for pilots flying for recreational purposes, professional pilots and flight students seeking a career in aviation have certificates reissued on a much more  regular basis as they add operating privileges.  NAFI recommends having a pilot ID card that needs to be issued every 8 years in line with the Real ID Act.  Operati ng privileges should be on a separate non-photo certificate which is only valid with the accompanying photo ID card, similar to the way an instructor certificate requires an accompanying pilot certificate.   This non-photo certificate may look similar to the current pilot certificate and may be reissued as often as needed for changes in operating privileges while   minimizing the financial and logistical burden on airmen, DPEs, and the FAA.  NAFI recommends that flight instructor  certificates are not considered ﬁpilot certificatesﬂ for the purposes of the NPRM. It is unclear if flight and ground instruct or certificates are included under the  provisions of the NPRM.  While it is la rgely an issue of semantics, instructor certificates are neither included nor excluded in the proposal. A flight instructor certificate already contains the limitation that  it is only valid when accompanied by the associated pilot certificate.  Requiring a photo instructor certificate is redundant and places an unnece ssary financial burden on instructors who must renew their certificate every 24 calendar months.  NAFI recommends leaving instructor certificates unchanged.   NAFI recommends that a user friendl y and manageable process for providing any photo for a certificate be established. Specific recommendations are addressed later in this response. V. NAFI direct responses to NPRM ﬁComments Invited.ﬂ  (1) While this proposal does not outline spec ific identity verification standards and processes, the FAA may include such standards and processes in a final rule. The FAA seeks comment on standards that should be used for identity verification to issue pilot   photo certificates, either in person or remotely. Should the FAA require applicants to produce fraud-resistant documents to verify identity? If so, which documents or other identity verification procedures should the FAA implement to ensure a high level of  confidence in the verification process?   7 In the process of identity verification, NAFI feels that the most logical solution is to follow the framework currently used by the Transportation Security  Administration™s identity verificati on standards for the issuance of a Transportation Worker Identification Credential (TWIC) card (Appendix B). Because this protocol has been established and implemented in the application process for a similarly issued government  photo ID, NAFI encourages the FAA to adopt this proven standard. NAFI believes  that the documents and/or certificates which meet the aforementioned requirement constitute a reasonably fraud-resistant document with which identity verification can be made.  (2) Should the FAA consider an alternative implementation approach to the ‚‚trigger™™ and ‚‚non-trigger™™ approach set forth in the proposal? Should the FAA set one deadline, regardless of certificate level, for pilots to have a pilot certificate with photo to exercise  the privileges of that certificate rather than implement t he phased ‚‚non-trigger™™ approach set forth in this proposal? What is  the basis and supporting data for a single deadline? If the FAA were to implement  a single deadline, what time period for conversion to a pilot certificate with photo adequately balances the FAA™s need to comply with the statutory mandate and the burden on certificate holders? Would lengthening the implementation period significantly reduce burden on a pilot? What is the basis and supporting data for a longer time period?  NAFI agrees with a ﬁtriggerﬂ event process for the first time issuance during the  transition period to a photo certificate.  Once issued, NAFI suggests that a more permanent photo ID be used as noted above in  our comments.  If an individual does not have a trigger event during the period of implementation, a deadline may be applicable.  NAFI supports a single deadline for ﬁnon-triggerﬂ reissuance  of pilot certificates.  A precedence was previously set with the change to plastic pilot certificates from traditional paper certificates in the  past.  A single deadline simplifies the communication process and understanding for airmen, especially those who don™t have regular interactions with the flight training industry or FAA representatives.   NAFI proposes the deadline should be set at three years for all airmen.  All active airmen will have a ﬁtrigger eventﬂ or a flight review prior to the three year deadline where the transition can be highlighted.  This will ensure adequate and streamlined communication for the new certificate requirement through flight  instructors, training centers, and/or DPEs. NAFI does not support the phased ﬁnon-triggerﬂ proposal.  While we appreciate and respect the desire for minimal in convenience to airmen, the phased approach is contrary to the security concerns that the IRTPA addresses.  Many ATP-certified pilots operate in a SIDA environment and/or already possess company/airport photo identification.  Making them the top priority for photo certificates does not further enhance security.  Additionally, the phased system may lead to increased expense for publicity and undue confusion for airmen.  8 (3) Currently, the FAA envisions using Kn owledge Testing Centers, DPEs, and FSDOs to accept pilot certificate applications  and validate applicant  identity. Are there alternative, potentially less bur densome, methods for pilots  within the U.S. and outside of the U.S. the FAA should consider? In addition, what should the FAA consider when  designating service providers with  identity verification authority?  NAFI agrees that FSDOs should be provided the resources and training to be able to accept pilot certificate applications and validate applicant identity.   Additionally, FSDOs should be provi ded the equipment to take digital  photographs and upload the photograph to an appropriate FAA system for inclusion in a pilot certificate processing effort.  NAFI believes that the IACRA syst em should be modified to include an appropriately uploaded photograph as provided by the applicant that would meet  standards to be established.  A DPE could verify the picture based on review of a  digital application and an in person review of corresponding documents to verify   applicant identity.  The ability for an app licant to upload their picture with an  application has already been approved for use in the Alien Flight Student Program training approval process used by  the TSA for training international  students.  This would add only one additional step to current guidance for DPEs, the verification that the photo uploaded with the applicant™s digital package along  with the traditional verification of identity based on government issued photo identification. An appropriate solution would additionally  need to be addressed in the event that a paper application for certificate be required.  A simple answer to this would be that if a paper application is required, that the applicant  be required to submit a passport photo with the certificate application. NAFI believes the additional policymaking  and infrastructure required to utilize  Knowledge Testing Centers as application acceptance facilities will lead to  additional cost and startup delays to t he program.  Knowledge Testing Centers do not represent an appropriate solution at this time.  Currently these centers do  not have the resources to take and upload photographs to be used in this process or are provided access to airman records to effectively conduct the airman certification processing as required by this NPRM without significant  changes to their infrastructure and access to airman records.  This would require additional designation of ability and authorization to access the airman records   by the FAA.    9 (4) Is the proposed 8-year duration for t he photo, based on the photo duration for state driver™s licenses under the Real ID Act, a r easonable period of time that balances the security needs expressed in IRTPA and th e burden on certificate holders? Are there other standards or guidance for photo accuracy the FAA should consider? What is the  basis and supporting data for a shorter or longer duration?  NAFI agrees with the 8 year duration to  keep alignment with the Real ID Act. Furthermore, upon application, the FAA or other such entities which have been  delegated authority to accept applications must use identity verification data10 as currently used by the Transportation Security Administration for the issuance of  the TWIC card (Appendix B). This would allow the FAA application process to conform to similar standards. A similar photo standard could be used for FAA  application processes or the standards for a passport photo could alternatively be used. (5) Is there any reason why student pilot certificates should not be treated like other pilot certificates for the purposes of meeting the IRTPA requirements? What is the basis and  supporting data for your response?  In the opinion of NAFI, if student pilot certificates must conform to the IRTPA requirements without special provisions, the ensuing time needed to process applications and produce the  certificates will present and undue hardship on the  flight training industry. The supporting dat a comes directly from the NPRM itself, which predicts a protracted application and  issuance process. Within such time, a  student pilot could very conceivably be prepared to make the ﬁfirst soloﬂ flight, which would required a student pilot certificate. NAFI could find no credible data referencing the average time it takes a student pilot to solo, the association™s opinion remains that most reasonable instructors and entities within the flight  training community would concur that a dedicated student could be ready well within the 6-8 week turnaround time. Furthermore, it is an industry accepted norm that the frequency of training flights has a direct impact on cost. Therefore  NAFI believes that requiring student pilots to undergo the same process as certificated airmen would impose a financial burden in both direct and indirect costs which would adversely affect the flight training industry.  NAFI recommends allowing temporary student pilot certificates as previously  stated in this response. (6) With respect to the photo that is placed on the pilot certificate, should the FAA accept only hard copy photos, only digitally- captured photos, or either hard copy or digitally-captured photos? What is the basis and supporting data for your response?  NAFI supports the FAA accepting digita lly submitted photographs for electronic  (IACRA) applications and hard copy photographs for paper (Form 8710) applications.  10 TSA, 2010.  ﬁRequired Documentation for U.S. Citizens Œ Tr ansportation Worker Identification Credential  (TWIC) Enrollment.ﬂ  http://www.tsa.gov/assets/pdf/approved_twic_identification_docs.pdf   10 Because the NPRM requires pilots to apply in person for identity verification, at the time of application for a certificate a DPE or FSDO could verify the picture provided with relation to additional government issued photo identification for identity verification. An airman provided digital photo (potentially uploaded with an IACRA  application) would have to meet set photo standards to be considered usable.    Similar standards to the TSA™s TWIC or  the State Department™s passport photo requirements could be applied.  (7) If the FAA accepts digitally-capt ured photos, what are the advantages and disadvantages of the following methods of acquiring the photo: a) An applicant uploading a self-capt ured photo to the IACRA subsystem;  Applicant submitted photographs are most su sceptible to potential tampering of photo content prior to upload.  This disadvantage can be minimized by the requirement to review the photo in relation to the applicant™s identity when verifying identity in person for the certificating event.  At that point, the FSDO or DPE could also have the option of uploading a new photo (if they had a method of capturing digital photograph present) or to decline proc essing of the certificate  if they believe the photo provided does not meet established guidelines or that it is the person appearing for the certificate event. An additional disadvantage could be that  if the applicant does not provide a  photo that appropriately meets photo guidelines, the application process may be delayed to such a time that the applicant can provide an updated photo or have a facility take such an appropriate photo. The advantage to an applicant providing a se lf photo is that would allow for the applicant to require less travel or specialized service provision to provide the photo that would be used. b) FSDO capturing the photo when  the application is submitted;  The advantages of a FSDO taking a phot o would include greater degree of  consistency of meeting  photo guidelines, ability to obtain an acceptable photo on  the spot at the time of application, and staff that w ould be knowledgeable in the process. The disadvantage could include travel to a FSDO for an Airman.  c) A Knowledge Testing Center capt uring the photo when an application is submitted;  NAFI does not consider the use of a Knowledge Testing Center an appropriate  option at this time.  11 d) A DPE capturing the photo w hen an application is submitted?  Advantages of a DPE capturing a photo when an application is submitted could  include the ability to take or replace a photo on the spot at the time of application and/or replace an unacceptable applicant provided photo.  Disadvantages could include the need or the  examiner to provide and travel with the equipment to take and upload photos, av ailability of a suitable background for the photo, lack of availability of photo editing software for appropriate cropping of images for size, and the training required for an examiner to provide appropriate photos. Additionally, in locations where inte rnet access is not present, the use of an examiner providing a digital image would be negated. On behalf of the members of the National Association of Fli ght Instructors, I would like  to thank you for the opportunity to provide input and comment into these proposed rulemaking changes.  I am certain that your work with the comments provided by NAFI and other organizations will result in improved  safety and increased efficiency in the  flight training areas these proposals affect. Respectfully,  Jason E. Blair Executive Director  12 Appendix A  Pilot Certificates Issued  Category of Certificates 1990 1991 1992 1993 1994 1995 1996 1997  Pilot--Total 156,955 161, 009 143,532 129,718 116,0 79 106,082 101,398 100,429         Student E 88,586 82,205 78,377 69,178 66,501 60,497 56,653 60,898         Recreational 29 87 74 58 73 57 71 60         Sport NA NA NA NA NA NA NA NA         Airplane Œ Private 41,749 49,580 39,968 39,060 32,787 28,333 24,714 21,552         Airplane - Commercial 15,500 16,869 14,354 12,645 9,237 9,133 10,245 8,988         Airplane - Airline Transport  8,013 8,437 7,699 6,126 5,360 5,965 7,444 7,045         Rotorcraft (only) 2,700 3,344 2,684 2,310 1,801 1,724 1,638 1,385  Flight Instructor Certificate  7,071 8,164 7,151 6,328 3,970 4,513 4,459 3,958  Instrument Ratings  NA NA NA NA NA NA 4,514 8,392   Pilot Certificates Issued  Category of Certificates 1998 1999 2000 2001 2002 2003 2004 2005  Pilot--Total  NA  NA 106,517 108,000 113,583 98,643 99,416 91,446         Student E 63,037  58,278 58,042 61,897 65,421 58,842 59,202 53,576         Recreational 69 83 93 61 77 48 47 57         Sport NA NA NA NA NA NA NA 133         Airplane - Private 26,297 24,630 27,223 25,372 28,659 23,866 23,031 20,889         Airplane - Commercial 10,042 9,737 11,213 11,499 12,299 9,670 9,836 8,834         Airplane - Airline Transport 7,547 6,721 7,715 7,070 4,718 3,892 4,255 4,750         Rotorcraft (only) 1,530 1,514 1,776 1,698 2,073 2,013 2,736 2,917  Flight Instructor Certificate  4,647 4,697 5,386 5,781 6,221 5,012 5,044 3,654  Instrument Ratings  9,737 9,538 11,148 11,552 12,626 10,069 10,452 9,482   Pilot Certificates Issued  Category of Certificates 2006 2007 2008 2009  Pilot--Total 99,792  108,019 100,555 93,861         Student E 61,448 66,953 61,194 54,876         Recreational 41 48 39 48         Sport 784 1,147 628 684         Airplane - Private 20,217 20,299 19,052 19,893         Airplane - Commercial 8,687 9,318 10,595 11,350         Airplane - Airline Transport 4,748 5,918 5,204  3,113         Rotorcraft (only) 3,569 4,073 3,639 3,648  Flight Instructor Certificate  4,506 4,667 4,415 4,348  Instrument Ratings  9,559 10,318 11,480 12,403  *Data in this appendix compiled by NAFI from multiple source pages on FAA.gov detailing  pilot certification statistics.   13 Appendix B  TWIC Identity Verification  Requirements for US Citizens  Required Documentation for U.S. Citizens Œ Tran sportation Worker Identification Credential  (TWIC) Enrollment *As of August 31, 2010*  U. S. Citizens (or U.S. Nationals) born  inside the United States   If you are a citizen of the United States (or its outlying possessions) and you were born inside the  United States (or its outlying possessions), you must provide one document from column A  or two  documents from column B. If you present two documents from column B, at least one of them must  be a government-issued photo ID, such  as a state-issued driver™s license, military ID card, or state  identification card.    Note: U.S. Mariners who hold or intend to apply for U.S. Coast Guard issued-credentials should note  that they may be required to provide the Coast Gu ard with copies of additional proof of nationality  and/or citizenship. Information on this can be found at http://www.uscg.mil/nmc/ldcr_sips.asp, in the  \"General Information\" package.    List A Œ one document    Ł Unexpired U. S. passport book or passport card    Ł Unexpired Merchant Mariner Document (MMD)     Ł Unexpired Free and Secure Trade (FAST) Card    Ł Unexpired NEXUS Card     Ł Unexpired Secure Electronic Network for  Travelers Rapid Inspection (SENTRI) Card    Ł Unexpired United States Enhanced Driver™s License (EDL)    Ł Unexpired Enhanced Tribal Card (ETC)     List B Œ two documents (with one of the two being a government-issued photo ID)    Ł Unexpired driver™s license issued by a Stat e or outlying possession of the United States     Ł Unexpired ID card issued by a State or outlying possession of the United States. Must include a  State or State agency seal or logo (such as st ate port authority ID or State University ID)    Ł Original or certified copy of birth certificate issu ed by a State, county, municipal authority, or  outlying possession of the United States bearing an official seal     Ł Voter™s registration card    Ł U. S. military ID card  or U. S. retired military ID     14 Ł U. S. military dependent™s card    Ł Expired U. S. passport (within 12 months of expiration)    Ł Native American tribal document (with photo)     Ł U. S. social security card    Ł U. S. military discharge papers (DD-214)     Ł Department of Transportation (DOT) medical card   Required Documentation for U.S. Citizens Œ Tran sportation Worker Identification Credential  (TWIC) Enrollment *As of August 31, 2010*    Ł U.S. civil marriage certificate    Ł Unexpired Merchant Mariner License (MML) bearing an official raised seal, or a certified copy    Ł Unexpired Department of Homeland Security (DHS) / Transportation Security Administration   (TSA) Transportation Worker Identification Credential (TWIC) Card    Ł Unexpired Merchant Mariner Credential (MMC)   Required Documentation for U.S. Citizens Œ Tran sportation Worker Identification Credential  (TWIC) Enrollment *As of August 31, 2010*    15 U. S. Citizens (or U.S. Nationals) born  outside the United States   If you are a citizen of the United States (or its outlying possession) but you were born  outside the United States (or its outlying possessions), you must provide one document from column A  or two  documents from column B. If you present two documents from column B, at least one of them must  be a government-issued photo ID, such as driver™s li cense issued by a State or outlying possession of  the United States, military ID card, or identification card issued by a State or outlying possession of  the United States. One of the documents you provide must demonstrate that you are a citizen of the  United States.   Note: U.S. Mariners who hold or intend to apply for U.S. Coast Guard issued-credentials should note  that they may be required to provide the Coast Gu ard with copies of additional proof of nationality  and/or citizenship. Information on this can be found at http://www.uscg.mil/nmc/ldcr_sips.asp, in the  \"General Information\" package.    List A Œ one document    Ł Unexpired U. S. passport book or passport card Œ  demonstrates U. S. citizenship    Ł Unexpired Merchant Mariner Document (MMD) Œ  demonstrates U. S. citizenship if indicated on  the MMD   Ł Unexpired Free and Secure Trade (FAST) Card Œ  demonstrates U. S. citizenship   Ł Unexpired NEXUS Card Œ  demonstrates U. S. citizenship    Ł Unexpired Secure Electronic Network for  Travelers Rapid Inspection (SENTRI) Card Œ  demonstrates U. S. citizenship    Ł Unexpired United States Enhanced Driver™s License (EDL) Œ  demonstrates U. S. citizenship    Ł Unexpired Enhanced Tribal Card (ETC) -- ) Œ  demonstrates U. S. citizenship    List B Œ two documents (with one of the two being a government-issued photo ID, and one must  demonstrate U. S. citizenship).    Ł U. S. Certificate of Citizenship (N-560, 561) Œ  demonstrates U. S. citizenship    Ł U. S. Certificate of Naturalization (N-550 or 570) Œ  demonstrates U. S. citizenship    Ł U. S. Citizen Identification Card (I-197) Œ  demonstrates U. S. citizenship     Ł Expired U. S. passport (within 12 months of expiration) Œ  demonstrates U. S. citizenship    Ł Consular Report of Birth Abroad (FS-240) Œ  demonstrates U. S. citizenship    Ł Certification of Report of Birth Abroad (DS-1350) Œ  demonstrates U. S. citizenship    Ł Unexpired driver™s license issued by a Stat e or outlying possession of the United States    16 Required Documentation for U.S. Citizens Œ Tran sportation Worker Identification Credential  (TWIC) Enrollment *As of August 31, 2010*    Ł Unexpired ID card issued by a State or outlying possession of the United States. Must include a  State or State agency seal or logo (such as stat e port authority ID or State University ID).    Ł Voter™s registration card    Ł U. S. military ID card or  U. S. retired military ID    Ł U. S. military dependent™s card    Ł Native American tribal document (with photo)     Ł U. S. social security card    Ł U. S. military discharge papers (DD-214)    Ł Department of Transportation (DOT) medical card     Ł U.S. civil marriage certificate    Ł Unexpired Merchant Mariner License (MML) bearing an official raised seal, or a certified copy     Ł Unexpired Department of Homeland Security (DHS) / Transportation Security Administration  (TSA) Transportation Worker Identification Credential (TWIC) Card    Ł Unexpired Merchant Mariner Credential (MMC)    17 Appendix C  The National Association of Flight Instructors included comments and discussion for a number of members in consider ation of the issues and questions in this NPRM.  The members of this committee include backgrounds in airline operations, flight instruction environments, simulator environments, and ground training environments.  The wide  variety of experience and knowledge of this committee allowed NAFI to consider the issues and questions from a variety of perspectives, all of which have relation to these questions.  While the comments herein have been collectively agreed for submission by  the members of the committee, they do not supersede or otherwise take the place of  any individual comments the members of  the committee may submit under separate response.    Brief biographical descriptions of the NAFI  ANPRM Committee members are as follows:   Jason Blair Œ Executive Director of the National Association of Flight Instructors, an  active CFI, NAFI Master Flight Instructor and FAA Designated Pilot Examiner, and the owner of a Fixed Based Operator that offers flight instruction, he also uses general aviation travel as his primary means of commuting to work.  His FAA DPE activities  include both part 61 and part 141 environment involvement.   Brian Boardman Œ Brian Boardman holds an ATP certificate with three type ratings, a CFI certificate with single engine, multiengi ne, and instrument airplane ratings, and an  IGI certificate.  He has provided flight  instruction and conducted stage checks under FARs 61 and 141.  He has also acted as a flight crewmember for corporate and charter operations under FARs 91,  135, and 121 Supplemental.  He has served on initial certification teams for several Part 121, 125, and 135 operators and has extensive  experience with ensuring regulatory compliance through air carrier manual systems.    Jonathon Freye Œ  A commercial single- and multi-engine pilot with a Bachelor of Science degree from Western Michigan Univ ersity™s College of Aviation and is a  graduate of the Jet Equivalency Training program. He has also worked as a Certified Flight Instructor, has experience in Part 135 and Part 91 flight departments, and is certified as a CFII/AGI. Freye closely follows and engages with transportation regulations within the industry and at the  Congressional level, and his policy analysis has been published in NAFI™s m onthly publication and online. He  serves as a Michigan Aeronautics Commissioner.     Robert Meder - Robert Meder is a CFI with single- and multi-engine and instrument privileges.  Robert is the St. Louis FSDO 2009 CFI of the year, the Lincoln 2010 FSDO  CFI of the year, and the 2010 Central Region CFI of the Year.  He has been a check airman for a 141 operation, an active FAASTeam Lead Rep,   He is active in volunteer  activities at EAA AirVenture each year.   Robert sits on the board of the National Association of Flight Instructors and is also an operating department manager with one of the largest railroads in the United States.   18    Harry Riggs  Œ Mr. Riggs has extensive experience  in handling aircraft litigation, on behalf of both plaintiffs and defendants and has litigated cases in numerous states, including Alaska. He specialized in aviation and products liability and represented several aviation insurance companies in  defense matters. Mr. Riggs has represented  numerous pilots, mechanics, and both corporate and airline flight departments in FAA enforcement related actions. In addition, he has represented Part 121 air carriers in regulatory and compliance matters plus several Part 135 operators.   He has held numerous offices in various aviation and legal associations and is past  president of the National Transportation Safety Board Bar Association. He has lectured extensively on behalf of the Aircraft  Owners and Pilots Association and the Experimental Aircraft Association and is curr ently Chairman of the EAA\\'s Legal Advisory  Council. In addition, Mr. Riggs is a forme r member of the NBAA\\'s Tax Committee and has lectured extensively on regulatory and enf orcement issues affecting corporate and fractional aircraft owners and operators He was one of the original founders and developers of the AOPA three-day ground schools which were taught throughout the United States and Europe. He previously  served as a pilot on a DC-3 owned and operated by the Prairie Aviation Museum of Bloomington, Illinois.    He is one of the original founders of NAFI an d has been active in its operations since its inception. He currently serves on it™s Board of Directors. Harry holds an Airline  Transport Rating and is type rated in a Cessna 500. He served as a flight instructor and course supervisor in the AOPA Flight Training Clinics held throughout the United States during the ‚60s, ‚70s and into the ‚80s. He was also on of the founders of the AOPA™s Private and Commercial Pilots Written Exam courses taught on weekends during that  same period of time. In addition, he also holds instrument and ground instructor ratings. He has owned and operated a Piper Comanche 260, Beechcraft Travel Air and a Piper Aztec.  Docket Operations, M - 30 M^HnlriT^M \\'^^ ^^^ 2011 U.S. Department of Transportation prnp?:p/ifi^\\'\\'^^ 1200 New Jersey Avenue, SE Ł \\' \\' \\' \\' West Building Ground Floor Washington, DC 20590-0001 iN!0 ° \\'-Ł P 1-03 Subject: NMPR on \"Photo Requirements for Pilot Certificates\" 1. The FAA has issued a proposal that require all pilots and student pilots to transition to a pilot certificate with a photograph over a five year period. A. This new requirement is necessary because the current policy (14 CFR 61.3(a)) of requiring pilots to carry a govemment-issued photo ID along with their pilot certificate has met the requirement and has not had any difficulties since implemented on NOV 2001 bytheATSA. B. This effort was designed to enhance the security-enhanced certificates of the nations 650,000 active pilots . (1) On 28 FEB 2008, the Drug Enforcement Assistance final rule required that all pilots, except Student Pilots obtain a new tamper-proof license by 31 MAR 2010 which we did. (2) This new initiative is redundant, unnecessary and expensive both in dollars to pilots, but also exhaustive to DPE\\' s, FSDO\\'s and AME\\'s with little or now Improvement In security. 2. If security is the primary concern than other methods of documentation should be used as in the past. A. Any supplemental govemment issued document should satisfy the requirement, such as: (1) Drivers License as in the past (2) TSA Required Airport Badges (A New Requirement) (3) U.S. Passports (4) Military ID B. The Homeland Security\\'s TSA should establish a universally recognized a secure identification that facilitates access at all airports. (1) Separate the security for background checks to the FBI, INS, CIA and TSA. (2) Our current Airport Badge requires a FBI Background Check which includes finger-printing and a photo. (3) The TSA should be the central repository for all intelligence information of the FAA. At the moment we have FBI, CIA, TSA, FAA and other Govemment agencies with no one in charge. 5 K, I n 3. Student Pilot Training If this is a primary concern than thought should be given to stopping \"Foreign Personnel\" from obtaining Pilot training In the USA. (1) All of the terrorist in 2001 were undergoing various phases of Pilot Training In the U.S.. (2) This wouki prevent access to aircraft and flight training of individuals with unknown backgrounds. The proposed 5-8 weeks delay in obtaining a proposed certificate is unrealistic from a training stand-point. B. The current requirements to obtain a Student Pilot Certificate from an AME is a proven and acceptable approach. C. Proficiency could be lost with weeks of delay before and individual can solo. This would to lead to more dual time and higher cost to the individual. \" D. The proposed NPRM requiring that a Student Pilot obtain a Plastic Certificate is unnecessary since it is usually a short time until the Student Pilot obtains a Sport, Recreational or Private Pilot Certificate. E. The AME\\'s or DPE\\'s shouki continue to issue the Student Pilot Certificates. F. To insure Security, the prospective Student Pilot should obtain a TSA Airport Badge, before starting training. This would insure that he has the required FBI Background Check. 4. Summary, Recommend the following initiatives: A. Eliminate the requirement for photo\\'s on their Pilot Certificates B. Require that the Pilot Certificate be accompanied by a Govemment Photo Identification when exercising the privileges of a pilot certificate. C. Eliminate the requirement to update the Photo each eight years. D. Establish a requirement for standard TSA Airport Badge to Improve identification, credentialing and security vetting of aimnan certificate holders and applicants for airman certificates. E. Require Student Pilots to obtain a TSA Airport Badge prior to starting flight training. 5. I have been a Flight Instructor since 1964 and have been flying in both military and civilian environments and am interested in both safety and security of the general aviation industry. I also have a Masters Degree in Safety Management. Thank you for your time. EugSie H. Boortz ^ 1491455CFI. xp12/11 1442 Freedom Lane Fort Collins, CO 80526-1705 (970) 490-1033 _tf^Alii.    1 [4910-13] DEPARTMENT OF TRANSPORTATION   Federal Aviation Administration   14 CFR Parts 61 and 183  Docket No. FAA-2010-1127; Notice No.   2010-16  RIN 2120-AJ42   Photo Requirements for Pilot Certificates  AGENCY:  Federal Aviation Administration (FAA), DOT.  ACTION: Notice of proposed rulemaking (NPRM).  SUMMARY:  This action would require a person to carry a pilot certificate with photo to  exercise the privileges of the pilot certificat e.  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 furt hers 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 phot o. Student pilot certificates would also have  the same duration as other pilot certificates .  Additionally, because of the new photo  requirements, this proposal modifies the appli cation process and the fee structure for pilot  certificates.    DATES:   Send your comments on or before [Ins ert date 90 days after date of  publication in the Federal Register ].   ADDRESSES:   You may send comments identified  by Docket Number FAA-2010-1127  using any of the following methods:    2 • Federal eRulemaking Portal :  Go to http://www.regulations.gov  and follow the  online instructions for sending your comments electronically.  • Mail:  Send comments to Docket Opera tions, 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.  For more information on the rulemaki ng process, see the SUPPLEMENTARY  INFORMATION section of this document.  Privacy:   The FAA will post all comments received, without change, to  http://www.regulations.gov , including any personal information you provide.  Using the  search function of our docket web site, anyone  can find and read the electronic form of all  comments received into any of our dockets, in cluding the name of the individual sending  the comment (or signing the comment for an a ssociation, business, labor union, etc.).  You  may review DOT\\'s complete Privacy Act Statement in the Federal Register published  on April 11, 2000 (65 FR 19477-78) or you may visit  http://DocketsInfo.dot.gov .  Docket :  To read background documents or comments received, go to  http://www.regulations.gov  at any time and follow the online instructions for accessing the  docket, or, go to the Docket Operations  in Room W12-140 of the West Building Ground    3 Floor at 1200 New Jersey Avenue, SE, Washington, DC, between 9 a.m. and 5 p.m.,  Monday through Friday, except Federal holidays.   FOR FURTHER INFO RMATION CONTACT:  For technical questions concerning this  proposed rule contact Lance Nuckolls, Cer tification and General  Aviation Operations Branch, AFS-810, Flight Standards Serv ice, Federal Aviation Administration,   800 Independence Avenue SW, Washingt on, DC 20591; telephone (202) 267-8212;  facsimile (202) 267-5094, e-mail  lance.nuckolls@faa.gov.  For  legal questions concerning  this proposed rule contact Robert Hawks,   Air Traffic and Airman/Airport Certification  Law Branch , AGC-240, Office of the Chief Counsel,   Federal Aviation Administration,   800 Independence Avenue SW, Washingt on, DC 20591; telephone (202) 267-7143;  facsimile (202) 267-7971, e-mail  rob.hawks@faa.gov.  SUPPLEMENTARY INFORMATION:  Later in this preamble under the Additiona l Information section is a discussion of  how you can comment on this proposal and  how the FAA will handle your comments.   Included in this discussion is related informa tion about the docket, privacy, the handling of  proprietary or confidential  business information, and accessing related rulemaking  documents. Authority for this Rulemaking    The FAA™s authority to issue rules on aviati on safety is found in Title 49 of the United  States Code.  Subtitle I, Section 106 describe s the authority of the FAA Administrator.   Subtitle VII, Aviation Programs, describes in more detail the scope of the agency™s   authority.                                                                                                                                          4  Under Subtitle VII, Part A, Subpart iii,  Section 44703(b)(1)(C), the FAA may define  the terms of an airman certificate the FAA Administrator finds necessary to ensure safety   in air commerce.  Additionally, Subtitle VI I, Part A, Subpart iii, Section 44703(g)(1)  permits modifications to the airman certification system to make the system more efficient   in serving the needs of  those enforcing laws related to combating acts of terrorism by   ensuring verifiable identification of individuals  applying for airman certificates.  In Section  4022 of the Intelligence Reform and Te rrorism Prevention Act of 2004 (IRTPA), 1 Congress required the FAA to promulgate regu lations for the issuance of improved pilot  licenses.     This rulemaking is within the scope of  that authority because it prescribes the  inclusion of a photo of the pilot on the pilot certificate in accordance with the IRTPA  mandate. This rulemaking aids in preventing  terrorism and in ensuring safety in air  commerce by issuing certificates that conform to the IRTPA requirements.    Background  On March 12, 1990, the FAA published the Drug Enforcement Assistance notice of  proposed rulemaking (55 FR 9270).  That NP RM proposed changes to requirements for  registration of aircraft, certification of p ilots, and certification violations.  The FAA  intended this proposal to correct  deficiencies in the FAA™s aircraft registration and pilot  certification systems identified in the Fede ral Aviation Administration Drug Enforcement  Assistance Act of 1988 (ﬁthe DEA Actﬂ). 2   After the close of the comment period, the  FAA determined that technological improve ments could accomplish most requirements of  the DEA Act. The FAA withdrew the NPRM on December 5, 2005 (70 FR 72403).                                                             1 Pub. L. 108-458, 118 Stat. 3638 (Dec. 17, 2004).  2 Pub. L. 100-690, 102 Stat. 4181 (Nov. 18, 1988).    5 As part of the technological improveme nts, the FAA discontinued issuing paper  certificates and began issuing plastic airman  certificates in 2003.  The plastic certificates  are of high quality plastic car d stock and have micro printing  that contains certain words  and phrases, a hologram, and an UV-sensitive layer to resist tampering, altering, and   counterfeiting.  On January 5, 2007, the FAA published the Drug Enforcement Assistance notice of  proposed rulemaking (ﬁthe 2007 DEA NPRMﬂ)  (72 FR 489).  That NPRM proposed  changes to the airman certification and aircraft  registration requirements to comply with the  mandates of the DEA Act that could not be  completed without rulemaking.  Among other  requirements, the NPRM proposed requiring holde rs of pilot certificates and other airmen  certificates to hold a plastic certificate to exercise the privileges of that certificate.    While the FAA was developing the  2007 DEA NPRM, IRTPA became law and  added to the FAA™s obligations regarding  pilot certificates.  Section 4022 of IRPTA  requires the FAA to issue improved pilot certificates that (1) are resistant to tampering,   alteration, or counterfe iting; (2) include a photograph of the individual to whom the  certificate is issued; and (3) are capable of accommodating a digital photograph, a   biometric identifier, or any other unique  identifier the FAA Administrator considers  necessary.  On February 28, 2008, the FAA published the Drug Enforcement Assistance final  rule (ﬁthe DEA final ruleﬂ) (73 FR 10662).  In  that rule, the FAA required all pilots, except  student pilots, to obtain a plastic certificat e by March 31, 2010.  After that date, pilots  without plastic certificates may not exercise  the privileges of their certificates. The FAA  continued the use of paper temporary pilot ce rtificates and student pilot certificates. The    6 DEA final rule also satisfies the IRTPA requirement to issue pilot certificates that are  resistant to tampering, alte ration, and counterfeiting.    Other Airman Certificate-Re lated Rulemaking Activity  Currently, the Department of Homeland  Security™s Transportation Security  Administration (TSA) is engaged in ongo ing efforts to improve identification,  credentialing, and security vetting of persons  involved in transportation (49 USC 44903).   Under existing FAA programs, the TSA uses information from the Airman Registry to  crosscheck certification records against a variety of terrorism-related databases.  Currently,   the TSA is considering a rulemaking to improve security vetting of airman certificate   holders and applicants for airman certificates .  In the interest of reducing burdens on the  certificate holder and government, the FAA will continue to consult and collaborate with  TSA and other Federal agencies to reduce pot ential redundancies or  duplication in Federal  certification, vetting, and credentia ling processes.  If the TSA i ssues a final rule regarding  airman security vetting, the FAA may issue conforming requirements in any final rule   resulting from this proposal, subsequent to  a supplemental notice of proposed rulemaking,  or as part of a new rulemaking project, depending on the scope and timing of the TSA™s  actions.  Discussion of the Proposal  The FAA proposes to further fulfill the re quirements of section 4022 of the IRTPA  by requiring a photo of the pilot on all plastic  pilot certificates.  This proposal also requires  student pilots to have a plastic certificate with photo in order to exercise student pilot   privileges.  The FAA would continue to allow  the use of a paper temporary pilot certificate  when upgrading a pilot certificate (such as going  from a student to a sport, recreational, or    7 private pilot certificate) or adding a rating (s uch as an instrument rating). However, the  temporary paper certificate evidencing the a dded authority must be accompanied by the  underlying pilot certificate with photo.     The FAA proposes a 5-year phased impleme ntation schedule.  This schedule  includes a ﬁtrigger-basedﬂ approach to issu e pilot certificates with photos to people  interacting with the FAA durin g the implementation period.  The schedule also includes a  ﬁnon-trigger-basedﬂ approach  that requires pilots to obtain a pilot certificate with photo  during a 3-, 4-, or 5-year peri od depending on the type of certificate.  This proposal would  not revoke or otherwise cancel a previously issu ed paper or plastic certificate.  It simply  would require the pilot to have a pilot certif icate with photo to exercise pilot privileges.  The FAA proposes to add a new § 61.6 to prescribe the requirements related to a  pilot certificate with photo.  This proposal al so amends the application process in § 61.85  to require submission of a photo with an application for a pilot certificate.  The FAA also  proposes to modify the fee structure related to  an application for a pilot certificate with  photo to recover some costs associated with  issuing a pilot certificate with photo.  The  FAA also proposes to amend § 61.3 to remove  the requirement to carry a separate  government-issued photo identification for pers ons carrying a pilot certificate with photo.  The FAA has determined two photo identifi cations are unnecessary and do not serve a  safety or security interest.  However, pers ons with special purpose pilot authorizations,  foreign pilot licenses, or limited-term f acsimile pilot certificates still must carry  government-issued photo identification.  Fi nally, the FAA proposes minor editorial  changes, including some changes to sec tion numbering, to improve ease of use.    8 The following sections discuss in greater  detail the proposals related to the fees for  issuing or replacing a pilot certificate with  photo, the implementation approach, applying  for a pilot certificate with photo, photo requirement s, duration of pilot privileges for pilot  certificates with photos, student p ilot certificates, and other issues.  Fees for Issuing or Replacing a Pilot Certificate with Photo  Currently, the FAA charges a $2 fee to  replace a lost or destroyed airman  certificate. There is no charge for issuing, upgrading, or adding ratings to an airman   certificate.  14 CFR 61.29(a).  Although the FAA  has statutory authority to charge a fee for  issuing a pilot certificate, the FAA previously  has not exercised that authority.  49 U.S.C.   45302.  That authority permits the FAA to charge a maximum fee of $22.00 ($12.00   adjusted according to the Consumer Price Index of All Urban Consumers published by the   Secretary of Labor).  49 U.S.C. 45302(b)-(c).  Congress required the FAA to change from issuing paper pilot certificates to issuing  plastic certificates with photos  and other security measures. 3  The cost of issuing these new  certificates is substantial. To recover some of  these costs, the FAA proposes to exercise its  statutory authority to collect a fee when issuing a pilot certificate with a photo and other   security features.    Specifically, the FAA proposes to  charge a $22 fee to process an application for: (1)  exchanging an existing certificate without a phot o for a certificate with photo; (2) issuing a  new pilot certificate or student pilot certificate;  and (3) replacing a pilot certificate with  photo whenever a replacement certificate is requ ested by a pilot or required by regulation.   Examples of events which would require  a replacement certificate include renewing  expired photos, achieving new ratings or certifi cate levels, changing name or citizenship    9 information, and replacing lost or destroyed  certificates. As shown in the regulatory  evaluation, the $22 fee does not recover fully th e cost of issuing pilot certificates, but the  FAA may not exceed its statutory authority  to recover costs. Accordingly, the FAA  proposes to include this fee schedule for a  pilot certificate with photo in the new § 61.6.  The FAA also proposes to adjust this fee  periodically to correspond with changes in  the Consumer Price Index, as permitted by  49 U.S.C. 45302(c).  Any fee adjustment would  not occur more than once a year and would not exceed the FAA™s cost for issuing a   certificate.  Any calculation of issuance cost  would be performed in the same manner as  that performed for this proposed rule.    The Federal Aviation Administration Reaut horization bill (H.R. 915), if enacted as  passed by the House of Representatives  on May 21, 2009, would provide authority to  increase fees for airman certificates.  This legislation would allow the FAA to recover the   costs related to airman certifi cation, and the legislation sets  the fee for issuing an airman  certificate at $50 and for issuing a replacem ent airman certificate at $25.  Once the  outcome of the reauthorization legislati on is known, the FAA would decide whether  additional rulemaking is necessary.  Since this proposal would require in-person identity verification, the FAA  anticipates allowing designees to accept and verify applications for pilot certificates with   photos to lessen the inconvenience to certific ate holders and new applicants.  The FAA  anticipates that designees would charge a fee, in addition to the fee charged by the FAA, to   accept and verify the applications.  The FAA cannot set or limit fees charged by designees.    This fee likely would be independent of any fe e charged by a designee for testing services  provided to the applicant.                                                                                                                                                                                   3 IRTPA § 4022(b).    10 Implementation Approach   The FAA would begin issuing a pilot cer tificate with photo to an applicant for a  new pilot certificate once the rule becomes eff ective. For the FAA to comply with IRPTA,  it must reissue all existing pilot certificates w ith a pilot certificate with photo.  To minimize  the burden of reissuance on certificate holde rs, the FAA proposes a concurrent ﬁtrigger- basedﬂ and ﬁnon-trig ger-basedﬂ implement ation approach.   Many pilots already would interact with the FAA during the implementation period  of this proposed rule because of a ﬁtriggering  event.ﬂ They would be required to apply for a  pilot certificate with photo as a result of that  interaction.  One triggering event would be  applying for a new pilot certificate or rating, in cluding a student pilot certificate.  A pilot  obtaining a new flight instructor  certificate or renewing a flight instructor certificate would  also be required to apply for a pilot certificate with photo for the underlying pilot   certificate.  The FAA does not propose requiri ng all persons requesting replacement pilot  certificates during the impleme ntation period to apply for a pilot certificate with photo.  However, replacement activity requiring an  in-person interaction with the FAA (for  example, change of name, citizenship, date of bi rth, or gender) would be a triggering event.   The FAA proposes to require pilots interacting  with the FAA during one of these triggering  events to provide a photo with the application.   These pilots would not be subject to the proposed phase-in requirements because they  would already comply with the proposed  rule. Because not all pilots will have a triggering event during the implementation  period, the FAA proposes a phased approach fo r requiring an application for a pilot  certificate with photo.  A pilot with an airline  transport pilot (ATP) certificate would have 3    11 years after the final rule becomes effective  to obtain a pilot certificate with photo. A person  with a commercial pilot certificate would have  4 years after the effective date of the final  rule. Finally, a private, recreational, or s port pilot certificate holde r would have 5 years  after the effective date of the final rule.   Pilots who do not obtain a certificate with photo  during the appropriate period woul d not be able to exercise pilot privileges after the cut-off  date.  The FAA chose different cut-off dates based  on certificate level to provide the most  time for private, sport, and recreational pilots. Those pilots are the least likely to have   regular contact with the FAA. ATP and commercial pilot certificate holders usually have   more regular contact with the FAA than other types of pilots.     The FAA believes that these periods are reasonable to allow for the timely  replacement of pilot certificates. The phased  implementation approach balances the FAA™s  ability to receive and process applications fo r replacement certificates and to maintain the  FAA™s existing range of services.  The FAA a ssumes that applications would be evenly  spread throughout the implementation period.  If  all pilots wait until close to the end of the  period to apply for the certificate, there undoubt edly would be delays in processing and  receipt of the new certificate. A pilot may  apply for a certificate with photo after the  specific implementation period e nds, but he or she would not  be able to exercise pilot  privileges until he or she has  a pilot certificate with photo.  The FAA proposes to add this  implementation schedule to § 61.19.     Applying for a Pilot Certificate with Photo  The FAA would require a pilot to submit an application for a new or replacement  pilot certificate with photos in person in certain  cases. For these in-person applications, a    12 pilot must appear at a FSDO or other FAA de signee (such as a Knowledge Testing Center  or designated pilot examiner (DPE)).  All certificate holders applying for a pilot certificate   for the first time would submit that application in person for purposes of identity  verification. After a person holds a pilot cer tificate with photo, there would be certain  situations for which an in-person application  is required. If the photo would expire within  90 days of the application, a pilot would sub mit the application in person. A pilot changing  vital information on the certificate, such as name, date of birth, citizenship, or gender,   would still be required to apply in person so the FAA could verify the applicant™s identity.  Finally, a pilot who upgrades his or her certif icate or adds a rating would still apply for a  new certificate in person.   A pilot who wants to add or update the photo on the certificate may do so using one  of two methods. The first method would be  to submit a paper photo with a paper 8710-1  Airman Certificate and/or Rating Applicati on form. The second method would be to use  the Web-based Integrated Airman Certificat e and/or Rating Application (IACRA) form.   However, regardless of the method used, a pilot  must appear in-person to either a FSDO or  any authorized FAA-designee to have his  or her photo and identification validated  whenever a photo is required as part of th e application.  Currently, the FAA operates 96  FSDOs in the U.S. and has approximately  2,700 designees worldwide that can process  applications for pilot certificates with photo.  A  pilot residing outside of the U.S. must use  an FAA-designee who is authorized to service his or her area.  Alternately, the pilot may   come to the U.S. and use any FAA-designee or FSDO.    In some cases, the FAA would allow a pilot to submit an application for a pilot  certificate with photo by mail. These instances  would not require an in-person application    13 because the pilot has established his or her id entity with the FAA, and the changes to the  certificate do not affect the pilot™s identity. For example, a pilot could submit an   application to replace a lost or destroyed  certificate with photo without an in-person  interaction. Additionally, a pilo t could notify the FAA of a change of address by mail or via  the FAA website. Although not required by regulation, the pilot could request a   replacement certificate when making the change of address. When requesting a   replacement pilot certificate with photo in thes e situations, the pilot must have a photo on  file that does not expire with in 90 days of the application.  Photo Requirements The FAA proposes a new § 61.6 to prescr ibe the photo requirements for pilot  certificates.  The FAA would require an app licant to submit a 2 x 2-inch photo with the  application.  The photo must be unretouched and  in color.  The photo must be of only the  applicant and must have been  taken within the last six months. It also must show a full  front view of the applicant™s face in such a way that the area from the bottom of the   applicant™s chin to the top of the applicant™ s head (including hair) covers more than 50  percent but not more than 75 percent of the  total area of the photo.  The photo must show  the applicant in front of a plain light-colored  background and in normal street attire.  If an  applicant chose to wear a pilot uniform, the  FAA would consider that applicant to be  wearing normal street attire, provided the photo  did not show the applicant wearing a hat,  head covering, or dark glasses as prescribed  in § 61.6.  These requirements are consistent  with Department of State guide lines for passport photos.  Therefore, an applicant for a pilot  certificate with photo should be able to obt ain the required photo from any passport photo  vendor.   14 At this time, the FAA is prepared to accept only a hard copy of a photo, similar to  the Department of State™s pa ssport model.  In the future, however, the FAA anticipates  accepting a digital photo.  The FAA would revi se its guidance material as technology  advances and additional  methods are available for photo submission.    Currently the FAA is considering three me thods of acquiring a digital photo.  One  way would be for an applicant to upload a digital photo into FAA™s Integrated Airman   Certificate and/or Rating Application (IACRA) sub-system.  IACRA is an Internet-based   database program providing a fu lly-electronic method of applying  for an airman certificate  or rating.  IACRA can accommodate  submission of digital images.     The second method to acquire a digital photo  would be for an applicant to go to a  Knowledge Testing Center, which is a logical venue for verifying identity and taking   digital photos.  Currently there are two major  testing companies that are authorized to  perform knowledge testing for the FAA via Kn owledge Testing Centers.  These testing  centers are located to serve a wide ge ographic range (approximately 960 nationwide  centers and 9 international loca tions).  Usually, people do not have to travel more than 100  miles to get to a testing center.    The third method to acquire a digital photo  would be for an applicant to go to a  DPE or a FSDO that has the capability to take  digital photos.  Currently, FSDOs have this  capability, but DPEs do not. However, the FAA anticipates they would have this capability   in the future.    Duration of Pilot Privileges for  a Pilot Certificate with Photo  Because the accuracy of a photo degrades over time, the FAA proposes to include a  photo expiration date on the pilot certificate  with photo. As under current regulations, the    15 actual pilot certificate would not expire but  would remain valid  unless surrendered,  suspended, or revoked.  However, the pilot may no t exercise the privilege of the certificate  after the photo expiration date. Therefore, th e pilot must renew the photo in order to  continue to exercise the pilot privileges of  the certificate past the photo expiration date.  The FAA considered different photo dura tions, specifically an 8-year duration  (similar to that required by the Real ID Act) and a 10-year duration (similar to that used for   passports).  The Real ID Act of 2005 4 imposes certain security, authentication, and  issuance procedure standards for state driver\\'s licenses and identification cards for them to   be accepted by the federal government for of ficial purposes.  The FAA acknowledges that  the Real ID Act does not require the FAA to set any specific duration with respect to a pilot   certificate with photo.  The Department of State traditionally ha s issued passports that are  valid for 10 years.  This practice was established well before the Real ID Act became law   and was established in response to different c oncerns than those to which the Real ID Act  responds.  The FAA proposes an 8-year duration.   This duration is consistent with the Real ID Act, which is Congress™s latest expre ssion on the appropriate period of validity for  government identification.  The FAA proposes to amend § 61.19 to prescribe a photo   expiration date of 8 years after the month in which the FAA issues the pilot certificate.  The   FAA also proposes to place the photo expirati on date on the pilot certificate with photo to  remind certificate holders of when  a new photo must be submitted.    Under this proposal, it would be the pilot™ s responsibility to apply for a replacement  certificate and provide a new, current photo  before the photo expiration date.  It is  important to note that the issuance of a pilot  certificate with photo could take up to 6 to 8  weeks.  Therefore, a pilot should plan to  submit an application, with a new photo, well    16 before the photo expiration date on the current pi lot certificate.  If the photo expiration date  passes before the pilot receives a replacemen t pilot certificate with photo, the FAA would  not issue temporary privileges, and the p ilot could not exercise pilot privileges.  For applications received in the 180 days before the photo expiration date, the FAA  would issue a certificate with a photo expirati on date that is 8 years from the previous  certificate™s photo expiration date.  If a pilot re quests changes to a certificate, such as  changing the certificate level or adding a rating, the FAA would issue a new certificate   with the current photo on file.  That certifi cate would have the same  photo expiration date  as the certificate that it is replacing.  However, if a pilot wishes to submit a new photo, the  FAA would issue a certificate with a photo ex piration date of 8 years from the month of  issue.  If the photo would expire within the  next 90 days, the pilot must submit a new photo  with the application for a certificate.     Student Pilot Certificates   The FAA includes student pilot certificates  in this proposal to meet the IRTPA  requirements that apply to all pilot certificates.  The Drug Enforcement Assistance final   rule, which required plastic pilot certificates,  did not include student pilot certificates.   Therefore, the FAA proposes to require all stude nt pilot certificates to be made of plastic  and include a photo of the certificate holder.   As a result, only the FAA™s Airman  Certification Branch (AFS-760) woul d issue student pilot certificates. The FAA proposes to discontinue use of  an Aviation Medical Examiner (AME) for  the application and issuance of a student pilot certificate.  Currently, AMEs may issue both   a medical certificate and a student pilot certificate (often referred to as a combination   certificate). Except in the case of glider, ball oon, and light sport aircraft, a student pilot™s                                                                                                                                                                                  4 Pub. L. 109-13, 119 Stat. 231 (May 11, 2005).    17 first contact with the FAA usually is through an AME because of the medical certificate  requirement. It is convenient for a student pilo t to apply for a student pilot certificate at the  same time as for a medical certif icate. However, under this  proposal, student pilots must obtain a student pilot certificate with photo. Because an AME™s principal function is to  perform the medical evaluation, the FAA has dete rmined that it is inappropriate to burden the AME with information-gathering and phot o-verification duties.  Accordingly, under  this proposal, a person wishing to obtain a  student pilot certificate would still obtain a  medical certificate from an AME; however, th at person may not apply for a student pilot  certificate with an AME. A student pilot woul d obtain a student pilot certificate with photo  that is issued by the FAA Airman Certifica tion Branch (AFS-760) prior to conducting solo  flights.    The FAA proposes to amend §  61.85 to prescribe the application process for  student pilot certificates and § 183.21 to re lieve AMEs from issuing student pilot  certificates.  Also, under this proposal, Designated P ilot Examiners (DPEs) no longer would  issue student pilot certificates.  However,  DPEs would be authorized to accept an  application for a student pilot certificate.   In addition, designated knowledge testing  centers, designated airmen certification representatives, local Flight Standards District   Offices (FSDOs), and International Field Offices would be authorized to accept an   application for a student pilot certificate.     Because the student pilot certificate w ould be issued by the FAA™s Airmen  Certification Branch instead of by Aviation  Safety Inspectors or FAA designees, student  pilots, instructors, and pilot schools shoul d plan accordingly for the additional time it  would take to receive a plastic  student pilot certificate with photo.  At this time, the FAA    18 estimates that it could take up to 6 to 8 weeks for the FAA to issue a student pilot  certificate.  As under the current regulations,  students still can receive instruction, but they  may not engage in solo flight before receiving a student pilot certificate.      Currently, a student pilot certificate expire s either 24 or 60 calendar months after  issuance depending on the age of the student pilot or on the rating sought.  Because of the   proposed change in procedure to obtain a st udent pilot certificate, the FAA proposes to  issue student pilot certificates th at do not expire. Like other pilot certificates, a student pilot  certificate would remain valid unless surre ndered, suspended, or revoked. However, the  student pilot certificates would have a photo ex piration date of 8 year s after the month of  issuance.  This duration is consistent with  the duration of other pilot certificates because  the FAA has concluded there is no purpose to tr eating student pilot certificates differently  from other pilot certificates.   A student pilot w ould not be able to exer cise the privileges of  the certificate after the photo expiration da te unless he or she submitted a new photo.  A student pilot certificate issued prior to the effective date of this rule would  continue to be valid until the expiration date shown on the face of that certificate.  If a   person wishes to obtain a replac ement student pilot certificate, he or she may apply for a  student pilot certificate with photo.  Because stude nt pilot certificates currently expire after  either 24 or 60 months, all student pilots w ould be using a student pilot certificate with  photo before the end of the 5-year implementa tion period established by this proposal for  obtaining a pilot certificate with photo.    The FAA also proposes to make conforming changes regarding the placement of  solo flight endorsements on stude nt pilot certificates.  Because it is not possible to make the  currently-required solo flight endorsements on  a plastic student pilot certificate, the FAA    19 proposes to amend §§ 61.87, 61.93, and 61.133 to requi re that those endor sements be made  in only the student pilot™s logbook.  The FAA also proposes to amend §§ 61.189 and   61.195 to require flight instructors to place t hose endorsements in onl y the student pilot™s  logbook. The FAA proposes to amend § 61.13(a)(2)(i)(A) so that it would apply to an   application for a student pilot certificate because  student pilot certificates would be issued  only by the FAA Airman Certification Branch (AFS-760).       Other Issues   Currently § 61.29(e) allows a person to  obtain a facsimile ai rman certificate5 if the  original certificate is lost or destroyed.   The FAA Airman Certification Branch issues  facsimile certificates so that an airman may continue to exercise privileges until a   replacement pilot certificate is issued.  This facsimile is valid for 60 days.  Although this  facsimile does not meet the IRTPA requirement s, the FAA proposes to leave the facsimile  provision unchanged.  The replacement of a p ilot certificate with photo would take up to 6  to 8 weeks during which time a pilot eff ectively would be grounded.  The FAA has  concluded that grounding a pilot for an ex tended time period is unnecessary.  The FAA  would treat the facsimile pilot certificate as a  special purpose pilot authorization that may  be used in conjunction with a government -issued photo identification under § 61.3. This  treatment would allow a pilot whose identity has  been certified by the FAA to continue to  exercise pilot privileges while allowing security agencies to verify the pilot™s identity   against a government-issued identification.    Comments Invited                                                             5 Currently, the Airman Certification Branch issues a paper temporary certificate, a faxed temporary  authority, or an e-mail temporary authority.     20 The FAA is specifically interested in receiving comments on the following  questions:  (1)  While this proposal does not outline specific identity verification standards and  processes, the FAA may include such standard s and processes in a final rule.  The FAA  seeks comment on standards that should be us ed for identity verification to issue pilot  photo certificates, either in person or remote ly.  Should the FAA require applicants to  produce fraud-resistant documents to verify id entity?  If so, which documents or other  identity verification procedures should the  FAA implement to ensure a high level of  confidence in the verification process?   (2)  Should the FAA consider an alte rnative implementation approach to the  ﬁtriggerﬂ and ﬁnon-triggerﬂ a pproach set forth in the proposal?  Should the FAA set one  deadline, regardless of certificate level, for p ilots to have a pilot certificate with photo to  exercise the privileges of that certificate ra ther than implement th e phased ﬁnon-triggerﬂ  approach set forth in this proposal?  What  is the basis and supporting data for a single  deadline?  If the FAA were to implement a single deadline, what time period for   conversion to a pilot certificate with photo adeq uately balances the FAA\\'s need to comply  with the statutory mandate and the burden on  certificate holders?  Would lengthening the  implementation period signific antly reduce burden on a pilot?  What is the basis and  supporting data for a longer time period?  (3)  Currently, the FAA envisions using  Knowledge Testing Centers, DPEs, and  FSDOs to accept pilot certificate applications and validate applicant identity. Are there   alternative, potentially less burde nsome, methods for pilots within the U.S. and outside of    21 the U.S. the FAA should consider?  In a ddition, what should the FAA consider when  designating service providers with identity verification authority?  (4)  Is the proposed 8-year duration for the photo, based on the photo duration for  state driver™s licenses under the Real ID Act,  a reasonable period of time that balances the  security needs expressed in IRTPA and the burden on certificate holders?  Are there other   standards or guidance for photo accuracy the FA A should consider?  What is the basis and  supporting data for a shorter or longer duration?      (5)  Is there any reason why student pilot  certificates should not be treated like other  pilot certificates for the purposes of meeting the IRTPA requirements?  What is the basis   and supporting data for your response?    (6)  With respect to the photo that is  placed on the pilot certificate, should the FAA  accept only hard copy photos, only digitally-captured photos, or either hard copy or   digitally-captured photos?  What is the ba sis and supporting data for your response?  (7)  If the FAA accepts digitally-captured photos, what are the advantages and  disadvantages of the following methods of ac quiring the photo: (a) an applicant uploading  a self-captured photo to the IACRA sub-syst em; (b) a FSDO capturing the photo when the  application is submitted; (c) a Knowledge Te sting Center capturing the photo when an  application is submitted; and (d) a DPE cap turing the photo when an application is  submitted?  What is the basis and supporting data for your response?  Paperwork Reduction Act  This proposal contains the following revi sions to existing information collection  requirements.  As required by the Pape rwork Reduction Act of 1995, the FAA has    22 submitted the information requirements associated with this  proposal to the Office of  Management and Budget for its  review. See 44 U.S.C. 3507(d).   Title:  Photo Requirements for Pilot Certificates   Summary:  This action would require a person to  carry a pilot certificate with photo to  exercise the privileges of the pilot certificat e.  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), and after Marc h 31, 2010, all pilots must carry a plastic  certificate.  This proposal furthers the fulf illment 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 and treats  student pilot certificates equally with other  pilot certificates for durational purposes.  A dditionally, because of the photo requirement  on pilot certificates, this proposal modifies the process for obtaining a pilot certificate and  the fee structure for processing an appli cation for a pilot certificate with photo. This  revision affects the existing information  collection requirements of FAA Form 8710-1  ﬁAirman Certificate and/or  Rating Applicationﬂ (OMB  Approval Number 2120-0021).    Use of:   This proposed rule is in direct response to section 4022 of the  Intelligence Reform and Terrorism Prevention  Act (IRTPA). This request for clearance  reflects requirements  necessary under Title 14  CFR part 61 to require a person to carry a  pilot certificate with photo to exercise the priv ileges of the pilot certificate.  The FAA will  use the information it collects and reviews to ensure compliance and adherence to   regulations and, where necessary, to take  enforcement action on violators of the  regulations.    23  Respondents (including number of):   The FAA estimates there are 740,442  pilots who would be required to provide info rmation in accordance with the proposed rule.   The respondents to this proposed information  requirement are pilots regulated under part  61.     Frequency:  The FAA estimates certificate holders will have a one-time  information collection, and will then collect or  report information occasionally thereafter.    Annual Burden Estimate:  This proposal would result in a 20-year recordkeeping and  reporting burden as follows:  Summary of time and costs (20-year):  The following table sums up the costs and time:     24   Total cost Annual co st Total time Annual time  Pilot-related costs       Trigger - Initial  Registration  $4,221,982 $211,099 82,923.34 4,146.17  Non-Trigger - Initial  Registration $191,555,276  $9,577,764 3,521,734.67 176,086.73  Non-Trigger - Renewal $149,053,511  $7,452,676 2,740,341.74 137,017.09  Additional/Replacement $9,654,806  $482,740 363,509.25 18,175.46 Portals       KTC $10,100,840  $505,042 655,048.00 32,752.40  DPE $17,545,925  $877,296 233,945.67 11,697.28 FAA Contractor $5,328,284  $266,414 N/A N/A TOTAL $387,460,624  $19,373,031 7,597,502.66 379,875.13 The agency is soliciting comments toŠ  (1) Evaluate whether the proposed inform ation requirement is necessary for the  proper performance of the functions of the agency, including whether the information will   have practical utility;   (2) Evaluate the accuracy of the agency\\'s estimate of the burden;   (3) Enhance the quality, utility, and clarity of the information to be collected;  and   25  (4) Minimize the burden of collecting in formation on those who are to respond,  including by using appropriate automated, elect ronic, mechanical, or  other technological  collection techniques or other form s of information technology.    Individuals and organizations may se nd comments on the information collection  requirement by [INSERT DATE 60 DAYS AFTER PUBLICATION IN THE   FEDERAL REGISTER ], and should direct them to th e address listed in the Addresses  section at the beginning of  this preamble.  Comments also should be submitted to the Office of Information and Regulatory Affa irs, OMB, New Executive Building, Room  10202, 725 17th Street, N.W., Washington, DC  20053, Attention: Desk Officer for FAA.  According to the 1995 amendments to the Paperw ork Reduction Act (5 CFR            § 1320.8(b)(2)(vi)), an agency may not collect or  sponsor the collection of information, nor  may it impose an information collection require ment unless it displays a currently valid  OMB control number.  The OMB control numbe r for this information collection will be  published in the Federal Register , after the Office of Manageme nt and Budget approves it.  International Compatibility   In keeping with U.S. obligations under the Convention on International Civil  Aviation, it is FAA policy to comply with  International Civil Aviation Organization  (ICAO) Standards and Recommended Practices to the maximum extent practicable.  The   FAA has determined that this rulemaking is consistent with ICAO Standards and   Recommended Practices.    26 Regulatory Evaluation, Regulatory Flexib ility Determination,  International Trade  Impact Assessment, and Unfunded Mandates Assessment   Changes to Federal regulations must unde rgo several economic analyses.  First,  Executive Order 12866 directs that each Federal  agency shall propose or adopt a regulation  only upon a reasoned determination that the bene fits of the intended regulation justify its  costs.  Second, the Regulatory Flexibilit y Act of 1980 (Public Law 96-354) requires  agencies to analyze the economic impact of regulatory changes on small entities.  Third,   the Trade Agreements Act (Public Law 96-39) prohibits agencies from setting standards  that create unnecessary obstacles to the fo reign commerce of the United States.  In  developing U.S. standards, this Trade Act  requires agencies to consider international  standards and, where appropriate, that they be  the basis of U.S. standards.  Fourth, the  Unfunded Mandates Reform Act  of 1995 (Public Law 104-4) requires agencies to prepare a  written assessment of the costs, benefits, and other e ffects of proposed or final rules that  include a Federal mandate likely to result in the expenditure by State, local, or tribal  governments, in the aggregate, or by the  private sector, of $100 million or more annually  (adjusted for inflation with  base year of 1995).  This por tion of the preamble summarizes  the FAA™s analysis of the economic impacts of this final rule.  The FAA suggests readers   seeking greater detail read the full regulatory  evaluation, a copy of which is in the docket  for this rulemaking.     In conducting these analyses, FAA has determin ed that this rule:  (1) has benefits  that justify its costs, (2) is not an ﬁeconomic ally significant regulatory actionﬂ but is a  ﬁsignificant regulatory actionﬂ for other r easons as defined in section 3(f) of Executive  Order 12866, (3) is ﬁsignificantﬂ as defined in  DOT\\'s Regulatory Po licies and Procedures;    27 (4) would not have a significant economic impact on a substantial number of small entities;  (5) would not create unnecessary obstacles to the foreign commerce of the United States;   and (6) would not impose an unfunded mandate on  state, local, or tribal governments, or on  the private sector by exceeding the thres hold identified above.  These analyses are  summarized below.   Summary  In this analysis, the FAA estimated future costs for a 20-year period, from 2010  through 2029.  All costs in this analysis are in 2008 dollars.    There are currently about 740,000 pilots and 93,000 CFIs that would be covered by   this proposal.  Given future projected grow th in all pilot categories and given the  requirement to renew every 8 years, the FA A anticipates that the FAA would process 4.40  million photo IDs from 2010 to 2029.    Costs to pilots would sum to $445.8 milli on ($235.8 million, present value) over the  above 20-year period.  This includes the costs of  the pilots providing hard copy photos and  a Form 8710-1 to a portal designee, either a  Knowledge Testing Cent er, Designated Pilot  Examiner, or Flight Service District Offi ce.  These portals would incur costs of $33.2  million ($17.6 million, present value) to proce ss this information and pass it on to the  Airman Registry at the  FAA.  The FAA would incur costs of $239.8 million ($126.7  million, present, value) to process the certific ates.  Total costs, over 20 years, sum to  $718.7 million ($380.1 million, present value).    This proposal responds to IRTPA by requiring digital photos on all pilot   certificates.  Congress has manda ted that the FAA improve pilot licenses by including a  photo on the license.  The proposal requiring owne rs to personally appear before authorized    28 persons and to produce proof of identity  including photo identification would be a  significant help in the prevention of  fraudulent and fictitious registration.  Initial Regulatory Flexibility Determination   The Regulatory Flexibility Act of 1980  (RFA) establishes ﬁas a principle of  regulatory issuance that agencies shall endea vor, consistent with the objective of the rule  and of applicable statutes, to fit regulatory  and informational requirements to the scale of  the business, organizations, and governmental  jurisdictions subject to regulation.ﬂ  To  achieve that principle, the RFA requires agencies to solicit and consider flexible regulatory   proposals and to explain the rationale for thei r actions.  The RFA covers a wide-range of  small entities, including small businesses, not-for-profit organizations and small   governmental jurisdictions.    Agencies must perform a review to dete rmine whether a proposed or final rule will  have a significant economic impact on a substantial number of small entities.  If the   determination is that it will, the agency must prepare a regulatory flexibility analysis as   described in the RFA. However, if an agency determines that a  proposed or final rule is not expected to  have a significant economic impact on a substantial number of small entities, section   605(b) of the 1980 act provides that the head of the agency may so certify and a regulatory   flexibility analysis is not required.  The certif ication must include a statement providing the  factual basis for this determination,  and the reasoning should be clear.   A number of commercial pilots are empl oyed as crop dusters, as passenger and  freight charter operators, in aerial photograph y and mapmaking businesses, in sightseeing  businesses, and/or in flight schools, many of which are sma ll businesses.  The FAA does    29 not have data as to how many  such pilots are employed in each of these businesses.  While  in a rural setting, the entire process may take half a day, the pilot would have large latitude   in choosing which day to get the certificate.   These types of small businesses are often  seasonal, meaning that in almost all cases, th e pilot would not have to miss a day of work  in order to get a pilot certificate with photo.    The cost impact to any one pilot and to any business would not be large.  The   average cost to a pilot in a ﬁnon-triggerﬂ event is  higher than that of a ﬁtriggerﬂ event as the  time and mileage needs to be take n into account as well as the portal costs.  The average  cost for a ﬁnon-triggerﬂ event is about $175.   These commercial pilots would have a phase- in period of 4 years and then would have to  renew every 8 years.  Thus, over a 20-year  period, such a pilot would have to get 3 pilot certificates, for a cost of about $375; the   average annual cost is $19, which is not a significant impact.    Therefore, the FAA certifies that this  proposed rule would not have a significant  economic impact on a substantial number of small entities.  The FAA solicits comments   regarding this determination.   International Trade Impact Statement  The Trade Agreements Act of 1979 (Public Law 96-39), as amended by the  Uruguay Round Agreements Act (Public Law  103-465), prohibits Federal agencies from  establishing standards or engagi ng in related activities that create unnecessary obstacles to  the foreign commerce of the United States.  Pursuant to these Acts, the establishment of   standards is not considered an unnecessary obs tacle to the foreign commerce of the United  States, so long as the standard has a legitimate domestic objective, such the protection of   safety, and does not operate in a manner that  excludes imports that meet this objective.     30 The statute also requires consideration of in ternational standards  and, where appropriate,  that they be the basis for U.S. standards.  Th e FAA has assessed the potential effect of this  proposed rule and determined that it would  have only a domestic impact and therefore  would not create unnecessary obstacles to the foreign commerce of the United States.    Unfunded Mandates Determination  Title II of the Unfunded Mandates Reform  Act of 1995 (the Act) requires each  Federal agency to prepare a written statement  assessing the effects of any Federal mandate  in a proposed or final agency rule that may  result in an expenditure of $100 million or more  (adjusted annually for inflation) in any one year  by State, local, and tribal governments, in  the aggregate, or by the private sector; such a mandate is deemed to be a ﬁsignificant   regulatory action.ﬂ  The FAA currently uses  an inflation-adjusted value of $136.1 million  in lieu of $100 million.               This proposed rule does not contain such  a mandate.  The requirements of Title II  do not apply.   Executive Order 13132, Federalism   The FAA has analyzed this proposed rule  under the principles and criteria of  Executive Order 13132, Federalism.  The FAA has  determined that this action would not  have a substantial direct effect on the St ates, on the relationship between the national  Government and the States, or on the distri bution of power and responsibilities among the  various levels of government , and, therefore, would not  have federalism implications.  Environmental Analysis  FAA Order 1050.1E identifies FAA actions  that are categorically excluded from  preparation of an environmen tal assessment or environmen tal impact statement under the   31 National Environmental Policy Act in the absence of extraordinary circumstances.  The  FAA has determined this proposed rulema king action qualifies for the categorical  exclusion identified in paragraph 312f and  involves no extraordinary circumstances.   Regulations that Signific antly Affect Energy Supply, Distribution, or Use  The FAA has analyzed this NPRM under Executive Order 13211, Actions  Concerning Regulations that Significantly Af fect Energy Supply, Distribution, or Use   (May 18, 2001).  The FAA has determined that it  is not a ﬁsignificant energy actionﬂ under  the executive order because it is not likely to have a significant adverse effect on the   supply, distribution, or use of energy.  Additional Information  Comments Invited  The FAA invites interested persons to participate in this rulemaking by submitting  written comments, data, or views on any issue raised in this rulemaking.  The FAA also   invites comments relating to the economic, environmental, energy, or federalism impacts   that might result from adopting the proposals in this document.  The most helpful   comments reference a specific portion of the proposal, explain the reason for any   recommended change, and include supporting data.   To ensure the docket does not contain  duplicate comments, please send only one copy of written comments, or if you are filing   comments electronically, please submit your comments only one time.  All comments received will be filed in the  docket, as well as a report summarizing  each substantive public contact with FAA pers onnel concerning this proposed rulemaking.  Before acting on this proposal, the FAA will consider all comments it receives on or before    32 the closing date for comments.  The FAA will consider comments filed after the comment  period has closed if it is possible to do so w ithout incurring expense or delay.  The FAA  may change this proposal in light of the comments received.   Availability of Rulemaking Documents  You can get an electronic copy of rulemaking documents using the Internet byŠ  1. Searching the Federal eRulemaking Portal ( http://www.regulations.gov ); 2. Visiting the FAA™s Regulations and Policies web page at  http://www.faa.gov/regulations_policies/; or  3. Accessing the Government Printing Office™s web page at  http://www.gpoaccess.gov/fr/index.html.   You can also get a copy by sending a request to the Federal Aviation  Administration, Office of Rulemaking,  ARM-1, 800 Independence Avenue S.W,  Washington, DC  20591, or by calling (202) 267-9 680.  Make sure to identify the docket  number, notice number, or amendm ent number of this rulemaking.  You may access all documents the FAA cons idered in developing this proposed  rule, including economic analyses and techni cal reports, from the internet through the  Federal eRulemaking Portal referenced in paragraph (1).  List of Subjects in 14 CFR Parts 61  and 183  Aircraft, Airmen, Aviation sa fety, Reporting and recordkeep ing requirements, Security  measures.  The Proposed Amendment  In consideration of the foregoing, the Federal Aviation Administration proposes to  amend Chapter I of Title 14, Code of  Federal Regulations, as follows:    33 PART 61 CERTIFICATION: PILOTS, FLIGHT INSTRUCTORS, AND GROUND  INSTRUCTORS  1. The authority citation for part 61 continues  to read as follows:   Authority:  49 U.S.C. 106(G), 40113, 44701-44703, 44707, 44709-44711, 45102-45103, 45301-45302.    2.         Amend §61.3 by revising para graphs (a), (d)(2)(iv), and paragraph (l)  introductory text to read as follows:     § 61.3   Requirement for certificat es, ratings, and authorizations.  (a) Pilot certificate.  (1) A person may not serve as a required pilot flight crewmember of a  civil aircraft of the United  States, unless that person: (i) Has a pilot certificate issued under  this part and in accordance with § 61.19;  (ii) Has a special purpose pilot  authorization issued under § 61.77;  (iii) Has a temporary certif icate issued under § 61.17;  (iv) Has a facsimile certifi cate issued under § 61.29; or  (v) When operating an aircraft within a foreign country, has a pilot license issued by that   country .   (2) The pilot certificate or special authoriza tion must be in the person™s physical possession  or readily accessible in the aircraft when exercising the privileges of that pilot certificate or   authorization.    (3) If the pilot certificate or authorization  is not a pilot certificate with photo, a person may  not serve as a required pilot flight crewmember  of a civil aircraft of the United States,    34 unless that person has a photo identification in  that person™s physical possession or readily  accessible in the aircraft when exercising the privileges of that pilot certificate or   authorization.  The photo identification must be a:   (i) Driver™s license issued by a State, the Di strict of Columbia, or a territory or possession  of the United States;   (ii) Government identification card issued by  the Federal government, a State, the District  of Columbia, or a territory or  possession of the United States;  (iii) U.S. Armed Forces™ identification card;   (iv) Official passport;   (v) Credential that authorizes unescorted access to a security identification display area at   an airport regulated under 49 CFR part 1542; or   (vi) Other form of identification that the Administrator finds acceptable.  * * * * * (d) * * * (2) * * *  (iv) Endorse a logbook for  solo operating privileges.  * * * * *  (l) Inspection of certificate.  Each person who holds an ai rman certificate, medical  certificate, authorization, or license required  by this part must present it and, unless the  pilot certificate contains a photo, a photo identific ation as described in paragraph (a)(2) of  this section for inspection upon a request from:   * * * * *  3. Add a new § 61.6 to read as follows:     35 § 61.6   Pilot certificate with photo and photo requirements.  (a)  Trigger-based implementation.   Except as provided in § 61.19(h)(2), after [effective  date of final rule], all pers ons must apply for a pilot certificate with photo and provide a  photo that conforms to the requirements prescrib ed in paragraph (b) of this section when:  (1) Obtaining a new pilot certificate or rating (including student pilot certificate);   (2) Obtaining a new flight instructor certificate;    (3) Renewing a flight inst ructor certificate; or  (4)  Obtaining a replacement pilot certificate resulting from a change of name, citizenship,   date of birth, or gender.    (b)  Photo Requirements.  (1)  A photo provided with an application for a new or  replacement pilot certificate with photo mustŒ     (i)  Be unretouched and in color;   (ii)  Be a recent likeness of only the applicant (taken within the last six months) and show a   full front view of the applicant™s face in su ch a way that the area from the bottom of the  applicant™s chin to the top of the applicant™ s head (including hair) covers more than 50  percent but not more than 75 percent  of the total area of the photo; and  (iii) Show the applicant in front of a plain light-colored background and in normal street  attire, without a hat, head covering, or dark  glasses unless a signed statement is submitted  by the applicant verifying the item is worn daily for religious purposes or a signed doctor™s   statement is submitted verifying the item is used daily for medical purposes.   (2)  A photo provided with an application for  a pilot certificate or rating must measure 2 x  2 inches in size.    36 (c) Application for new or replacement pilot certificate with photo.   (1)  A photo of the  applicant that conforms to the requirements pres cribed in paragraph (b) of this section must  accompany each application for a new or repl acement pilot certificate with photo unless the  applicant previously submitted a photo and that  photo has not expired or will not expire  within 90 days of the application.   (2)  An applicant for a pilot certificate with  photo must make an application accompanied  by a photo at a place designated by the Administrator.    (3)  An applicant for a replacement pilot cer tificate with photo who has a current photo on  file may make an application that is not acco mpanied by a photo at a place designated by  the Administrator or by mail to the Depa rtment of Transportation, FAA, Airman  Certification Branch, P.O. Box 25082, Oklahoma City, OK 73125.    (4)  Payment to the FAA of the fee specified in paragraph (d) of this section by check,   money order, or other payment method approved by the Administrator must accompany   each application for a new or repla cement pilot certificate with photo.  (d) Fee for issuance of pi lot certificate with photo.  The fee for processing an application  for a new or replacement pilot certificate w ith photo is $22.  The FAA periodically may  increase this fee to correspond with change s in the Consumer Price Index.     4. Amend §61.13 by revising paragraphs (a)(1) and (a)(2)(i)(A) to read as follows:  § 61.13   Issuance of airman certificat es, ratings, and authorizations.   (a) Application. (1) An applicant for an airman certif icate, rating, or authorization under  this part must make that application on a form acceptable to the Administrator and at a    37 place designated by the Administrator.  In add ition, an applicant for a pilot certificate with  photo must make that application as prescribed in § 61.6.   (2) * * *  (i) * * *  (A) Application for student pilot certificate that is received outside the United States; or   * * * * *  5. Amend §61.19 by revising paragraphs (a), (b ), and (c), and (g) to read as follows:  § 61.19   Duration of pilot and inst ructor certificates and privileges.  (a) General.  (1) Except for a student pilot certificate or flight instructor certificate issued  with an expiration date, a pilot certificate is  valid unless it is su rrendered, suspended, or  revoked.  (2)  A pilot certificate with photo is issued  with a photo expiration date after which the  holder of the certificate may not exercise the privileges of that certificate.   (b)  Paper student pilot certificate.   A student pilot certificate issued under this part prior to  [effective date of final rule] expires:   (1)  For student pilots who have not reached  their 40th birthday, 60 calendar months after  the month of the date of examination  shown on the medical certificate.    (2)  For student pilots who have reached th eir 40th birthday, 24 calen dar months after the  month of the date of examination  shown on the medical certificate.   (3)  For student pilots seeking a glider rating, balloon rating, or a sport pilot certificate,   60 calendar months after the month of the date  issued, regardless of the person™s age.     38  (c) Pilot certificates.  (1) A pilot certificate (other than a student pilot certificate) issued  under this part prior to [effective date of fina l rule] is issued without a specific expiration  date.   (2) A pilot certificate, including a student p ilot certificate, issued under this part after  [effective date of final rule] contains a phot o expiration date that is 96 months from the  month in which a photo is submitted for inclusion on the certificate.  (3) The holder of a pilot certificate issued  on the basis of a foreign pilot license may  exercise the privileges of that certificate only while that person\\'s foreign pilot license is   effective.   * * * * *  (g) Duration of pilot certificates.  (1) Except for a temporary certificate issued under §61.17  or a student pilot certificate issued under paragr aph (b) of this section, the holder of a paper  pilot certificate issued under this part may not exercise the privileges of that certificate after   March 31, 2010.  (2) Except for a temporary certificate issued  under § 61.17 or a facsimile certificate issued  under § 61.29, no person may exercise the privileges  of a particular certificate as pilot in  command or in any other capacity as a required pi lot flight crewmember of a civil aircraft  of U.S. registry unless that person has a  photo on his or her pilot certificate after:  (i)  [date 3 years after publication of final rule ] for a pilot holding an  airline transport pilot  certificate;   (ii)  [date 4 years after publication of fina l rule] for a pilot holding a commercial pilot  certificate; or    39 (iii)  [date 5 years after publication of final  rule] for a pilot holding a private, recreational  or sport pilot certificate.   6. Amend §61.25 by adding paragraph (c) to read as follows:  § 61.25   Change of name.  * * * * * (c)  For applications for a pilot certificate with photo, an applicant must make that   application as prescribed in § 61.6.  7. Amend §61.29 by revising the section heading,  revising paragraphs (a), (b), (c), (d)  introductory text, and (e) introducto ry text to read as follows:  § 61.29  Replacement of a pilot certificate with photo and replacement of lost or  destroyed airman or medical certificate or knowledge test report.  (a) (1)  Pilot certificate with photo.   A request for the replacement of a pilot certificate with  photo issued under this part must be made as prescribed in § 61.6.  (2)  Other airman certificate.   A request for the replacement of a lost or destroyed airman  certificate issued under this part must be  made by letter to  the Department of  Transportation, FAA, Airman  Certification Branch, P.O. Box 25082, Oklahoma City, OK  73125, and must be accompanied by a check or money order for the appropriate fee   payable to the FAA.   (b) Medical certificate.   A request for the replacement  of a lost or destroyed medical  certificate must be made by letter to the De partment of Transportation, FAA, Aerospace  Medical Certification Division, P.O. Bo x 26200, Oklahoma City, OK 73125, and must be  accompanied by a check or money order for the appropriate fee payable to the FAA.    40 (c) Knowledge test report.   A request for the replacement of  a lost or destroyed knowledge  test report must be made by letter to the Department  of Transportation, FAA, Airman  Certification Branch, P.O. Box 25082,  Oklahoma City, OK 73125, and must be  accompanied by a check or money order for the appropriate fee payable to the FAA.   (d) Request for replacement.   The letter requesting replacemen t of a pilot certificate with  photo or a lost or destroyed airman certificate,  medical certificate, or  knowledge test report  must state:  * * * * *   (e) Facsimile airman certificate, medica l certificate, or knowledge test report.   A person who has lost an airman certificate, medical  certificate, or knowledge test report may obtain  a facsimile from the FAA Aeromedical Certific ation Branch or the Airman Certification  Branch, as appropriate, confirmin g that it was issued and the:  *  *  *  *  *  8. Revise §61.85 to read as follows:  §61.85  Application An applicant for a student pilot certificate:    (a)  Must make that application in a form acceptable to the Administrator;   (b) Must provide a photo of the applicant that  conforms to the photo requirements set forth  in § 61.6 with the application;    (c)  Must submit the application to a designee authorized by the Administrator or to a   Flight Standards District Office; and   (d)  Must submit payment for the a pplication fee as directed in §61.6.    41 9. Amend §61.87 by revising paragraph (n), by adding the word ﬁandﬂ after the semicolon  in paragraph (p)(3), removing paragraph (p )(4), and redesignating paragraph (p)(5) as  paragraph (p)(4) to read as follows:   §61.87   Solo requirements for student pilots.  * * * * *  (n)  Limitations on student pilots operating an aircraft in solo flight .  A student pilot may  not operate an aircraft in solo  flight unless that student pilo t has received an endorsement in  the student™s logbook for the specific make and m odel aircraft to be flown by an authorized  instructor who gave the training within the 90 days preceding the date of the flight.  * * * * *  10. Amend §61.93 by revising paragraphs (c)(1)  and (c)(2) and adding paragraph (c)(3) to  read as follows:    § 61.93    Solo cross-country flight requirements.   * * * * *  (c) * * *  (1) A student pilot must have a solo cro ss-country endorsement  from the authorized  instructor who conducted the training that is pl aced in that person™s logbook for the specific  category of aircraft to be flown.   (2) A student pilot must have a solo cro ss-country endorsement  from an authorized  instructor that is placed in that person™s log book for the specific make and model of aircraft  to be flown.  (3) For each cross-country flight, the authoriz ed instructor who reviews the cross-country  planning must make an endorse ment in the person™s logbook after reviewing that person™s    42 cross-country planning, as specified in para graph (d) of this section. The endorsement  mustŠ   (i) Specify the make and model of aircraft to be flown;   (ii) State that the student\\'s preflight planning and preparation  is correct and that the student  is prepared to make the flight sa fely under the known conditions; and  (iii) State that any limitations required by the student\\'s authorized instructor are met.   * * * * *  11. Amend §61.133 by revising paragraphs (a)(2)(i )(C) and (a)(2)(ii)(C) to read as follows:    §61.133    Commercial pilot privileges and limitations.   (a) * * *  (2) * * *   (i) * * *   (C) Endorse a pilot™s logbook for solo  operating privileges in an airship;  * * * * *    (ii) * * *   (C) Endorse a pilot™s logbook for solo  operating privileges in a balloon; and  *  *  *  *  *  12. Amend §61.189 by revising paragraph (b)(1) to read as follows:  §61.189    Flight instructor records.   * * * * * (b) * * *  (1) The name of each person whose logbook that  instructor has endorsed for solo flight  privileges, and the date  of the endorsement; and    43 * * * * * 13. Amend §61.195 by revising paragraphs (d)(1) in troductory text and (d)(2) to read as  follows: §61.195    Flight instructor limitations and qualifications.   * * * * *  (d) * * *  (1) Student pilot\\'s logbook for solo flight pr ivileges, unless that flight instructor hasŠ  * * * * *  (2) Student pilot\\'s logbook for a solo cross-count ry flight, unless that flight instructor has  determined the student\\'s flight  preparation, planning, equipmen t, and proposed procedures  are adequate for the proposed flight unde r the existing conditions and within any  limitations listed in the logbook that the instruct or considers necessary  for the safety of the  flight;   * * * * *  PART 183ŠREPRESENTATIVES  OF THE ADMINISTRATOR  14. The authority citation for part 183 continues to read as follows:  Authority:  31 U.S.C. 9701; 49 U.S.C. 106(g), 40113, 44702, 45303.  15. Amend §183.21 by revising paragraph (c) and  removing and reserving paragraph (d) to  read as follows:  § 183.21   Aviation Medical Examiners.  * * * * *   44 (c) Issue or deny medical certificates in accordan ce with part 67 of this chapter, subject to  reconsideration by the Federal  Air Surgeon or his or her aut horized representatives within  the FAA; and   * * * * *   Issued in Washington, DC, on November 10, 2010.       .             John M. Allen     Director, Flight Standards Service     [FR Doc. 2010-29192 Filed 11/18/2010 at 8:45 am; Publication Date: 11/19/2010]   Page1of5AirLinePilotsAssociation,Int™l DocketNo.FAA20101127 PhotoRequirements ForPilot Certificates  February 16, 2011  Docket Operations; MŒ30   U.S. Department of Transportation    1200 New Jersey Avenue SE   West Building, Ground Floor, Room W12-140    Washington, DC 20590-0001     RE: Docket No. FAAŒ2010Œ1127; Photo Requirements for Pilot Certificates    To Whom It May Concern:      The Air Line Pilots Association, International (ALPA) represents 53,000 pilots who fly for 38 passenger and all-cargo airlines in the U.S. and Canada. The Association has a vested interest in the improvement of regulations related to aviatio n safety and security and is grateful for the opportunity to comment on the above-referenced  Notice of Proposed Rule Making (NPRM).     Section 4022 of the Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA) 1 requires the Federal Aviation Administration (FAA) to promulgate regulations governing the   issuance of improved pilot licenses. In the NPRM, the FAA prescribes the inclusion of a photo of  the bearer on the pilot certifi cate, with the statement that ﬁ This rulemaking aids in preventing terrorism and ensuring safety in air commerce.ﬂ   After careful review and consideration of the in formation contained in the NPRM, it is ALPA™s  view that the requirement for  the inclusion of a photo on a pilot certificate issued to pilots engaged in Part 121 airline operations, as defined in the Federal Aviation Regulations (FARs), will not contribute to security in a meaningful way as regards  FAR 121 airline pilots. We have  reached this conclusion because, as is described be low, all Part 121 pilots carry at least one photo   ID card issued by the airline a nd approved by the TSA and FAA according to federal security regulations, and most possess two su ch ID cards. Furthermore, FAR  Part 61 requires all pilots to have in their possession or readily accessible an FAA pilot certifi cate and at least one form of  government-approved photo ID whenever th ey operate a U.S. civil aircraft.   ALPA calls on the FAA to exempt airline pilo ts engaged in Part 121 operations from a new  requirement for purchasing pilo t certificates with photographs.   Background   Pilots engaged in Part 121 air carrier operations are required by governme nt, airline and airport regulations to carry a variety of identification to validate th eir identity and confirm their  employment status. These forms of identification  have for decades been considered sufficient to  permit pilots to access the flight deck and sterile a nd secure areas of airports. Following is a brief  description of the types of identification carried by Part 121 airline pilots.  1http://www.gpoaccess.gov/se rialset/creports/pdf/108 796/108 796_intel_reform.pdf Page2of5AirLinePilotsAssociation,Int™l DocketNo.FAA20101127 PhotoRequirements ForPilot Certificates Air Carrier-Issued Crewmember Identification Cards    All airline pilots must maintain on their person a  valid, air carrier-issued identification card with  photograph during operations. The process for issuing air carrier credentials is defined, regulated and monitored by the Transportation Security Ad ministration (TSA) through an identification  media control program. That program requires ai rlines to follow string ent background vetting requirements prior to issuing air  carrier credentials to pilots.    In order to qualify for service as a flight crewmember and be gran ted an air carrier identification  card, a pilot is subjected to: a government-required TSA Security  Threat Assessment (STA); a  Federal Bureau of Investigation (FBI) 10-year, Criminal History Records Check (CHRC); drug  testing; and, a review of the airman™s entire training history  as required by the Pilot Record Improvement Act (PRIA). Additionally, prior to  issuing an identification card, airlines conduct  credit checks, peer reviews and perform other b ackground evaluations to verify the identity and trustworthiness of crewmembers and to establish th e suitability of their character and fitness for   duty.     Upon successful completion of this vetting proc ess, an air carrier will issue the pilot an  identification card which, in compliance with TSA regulation §1544.231, includes a full-face   photograph and other data identifying the individual as a flight crewmember. This card must be  prominently displayed on the exterior of clothing  above the waist whenever  the pilot is acting in an operational capacity in the commercial aviation e nvironment. It is separate and distinct from  the FAA-issued pilot certificate which is normally carried in a discrete fashion on the pilot™s   person or within his/her immediate control.     The air carrierŒissued crewme mber identification card is:    Examined at TSA airport security checkpoint s to establish the identity of a flight crewmember. This examination is requi red to authenticate the crewmember™s  qualification for certain TSA-approved secur ity protocols that are applied only to uniformed crewmembers.    Relied upon by air carrier personnel who, per TSA regulations, must verify the identity of  flight crewmembers before they are permitted to assume command of an aircraft.    Recognized as authentication of the pilot™s authority to traverse certain specific air operations areas (AOA) of airports for which the pilot does not possess an airport-issued  Security Identification Display Area (SIDA) badge.    Utilized as the primary means  of identification for the Cock pit Access Security System  (CASS), which electronically authenticates a pilot™s employment status and identity to  make them eligible to occupy the flight deck  jumpseat of off-line air carriers. In addition,  airline pilots are required to carry and display a second form of government issued  photo-identification (normally a passport)  in order to qualify for CASS-approval.  Airport-Issued Security Identification Display Area (SIDA) Credentials   Page3of5AirLinePilotsAssociation,Int™l DocketNo.FAA20101127 PhotoRequirements ForPilot CertificatesIn addition to the background vetting that accompanies the issuance of an air carrier  identification card, most airline pilots are also  subjected to additional, similar scrutiny conducted  by at least one airport operator, in order to qualif y for receipt of an airport-issued SIDA badge.  The SIDA badge signifies that the bearer has been authorized by the airport authority to enter secure areas of the airport without an escort.  The SIDA badge bears a photo of the pilot and is required to be displayed in the same fashion as  the pilot™s air carrier-i ssued identification card whenever the pilot enters SIDA-designa ted areas of the issuing airport.    Passport   Per most air carriers™ policies, the  majority of airline pilots travel  at all times with a passport so  that they may establish proof of  their authority to occupy a flight deck jumpseat and/or conduct international operations. Among other industry-re cognized forms of identification carried by  pilots, the passport document can be relied upon by  authorized individuals to satisfy or resolve identity confirmation needs associat ed with a pilot certificate.      The FAA-Issued Pilot Certificate   Airline pilots are rarely required to present thei r FAA-issued pilot certificates for inspection or  identification purposes because the TSA-controlled  airline ID card and/or SIDA card is used for  that purpose. Normally, FAA certificates ar e presented for examination during company  sponsored training events, during an FAA inspection, or in instances when a pilot seeks permission from a pilot-in-command to occupy a fli ght deck jumpseat. In su ch cases, the pilot™s identity and employment status has been pre- established through a variety of standardized measures and other forms of recognizable photo -identification as previously described.   An FAA-issued pilot™s certificate is not intende d to be displayed for security purposes, but rather, is designed to demonstrate a pilot™s aircraft type ratings, skills and privileges. It is reflective of the bearer™s documented training hi story and qualifications, records of which are traceable and verifiable. As such,  in those very limited cases when a pilot certificate is examined  by an authorized, inspecting authority, the accuracy  of the data it represents is verifiable.    What is most critical in the issuance of an FAA  pilot certificate from a security standpoint is the  accurate establishment of the pilot™s identity,  background descriptors, and qualifications.  If  fraudulent data is relied upon and incorporated in the FAA™s record-keeping system at the time  of issuance, the process will be flawed at inception. Presently, FAA does not verify the identity  of the person requesting a pilot certificate other than through visual inspection of the individual™s driver™s license or passport. As such, adding a photograph to the certificate will not increase the   security attributes of the document because the requesting  individual™s true identity is not  verified with a high degree of confidence.     Threat Mitigation  TSA enumerates 20 layers of US aviation security, 2 which include the previously described crew vetting process and the Travel Document Checker (T DC), a person who scrutinizes government   2http://www.tsa.gov/what_we_do/layers/index.shtm Page4of5AirLinePilotsAssociation,Int™l DocketNo.FAA20101127 PhotoRequirements ForPilot Certificatesand/or airline-issued identific ation media presented by a crewmember seeking access to an  airport™s sterile area. The FAA-issued pilot cer tificate is not included in that category of normally accepted identification.    Efficient security countermeasures are designed  and implemented to mitigate a known threat of  meaningful consequence. Prior to implementation,  such measures should be demonstrated to be  necessary, effective and cost-justified. We note the lack of a ny supporting data in the NPRM which indicates that the specific absence of a photograph on an FAA-issued airline pilot™s certificate has created or contributed  to an actual aviation safety or security threat or that it is indicative of an exploitable vul nerability. ALPA would welcome the opportunity to see such data, if it is available.    Facsimile Copies of Airman™s Certificate   ALPA agrees with that portion of the rulemaki ng which continues the practice of allowing pilots to request and receive a facsimile copy of their ai rman certificate in the event the original is lost  or stolen. Changing this practice would effectively limit the ability  of an airline pilot to remain  gainfully engaged in his/her occupation until  a replacement is issued and would have a  detrimental impact on passenger movement  and the airline industry operations.  We would also submit that the FAA™s continuation of the facsimile practice for lost/stolen   certificates affirms that in such cases, the airlin e industry has traditionally been able to operate safely and securely without depending on the possession of an origin al pilot™s certificate in order  to:   1. authenticate the identity and qualifications -related  information it is intended to  represent   2. provide the pilot with needed access to airports and aircraft in order to accommodate the performance of his/her occupa tion and the flow of commerce     This fact, coupled with pilots™  possession of other forms of re liable identification which they  must by regulation carry with them in the comme rcial aviation domain, contraindicates the need  for an enhanced, photo-bearing pilot certificate as applicable to airline pilots.   Conclusions   A threat-driven, risk-managed and cost-effectiv e approach to ensuring aviation safety and security should be employed in id entifying and implementing meaningful  countermeasures to consequential vulnerabiliti es. ALPA is not aware of any such process being used to develop the requirements contained in this NPRM.     Relatedly, we respectfully disagree with the FAA™s assertion that ﬁ This rulemaking aids in preventing terrorism and ensuring safety in air commerce ﬂ because we do not see  the need forŠor benefits fromŠ a costly change to  a certificate that is never used by itself to  establish identity.     Page5of5AirLinePilotsAssociation,Int™l DocketNo.FAA20101127 PhotoRequirements ForPilot Certificates A photo of the bearer on an airline pilot™s certificate will not facilitate the efforts of  authorized examiners to establish its authentici ty or the identity and qualifications of the holder. Numerous, alternative methodologies  are available and currently relied upon to effectively meet those needs.  Nor will such  action improve airline security since the  pilot™s certificate is not, and cannot be,  relied upon as means of positively verifying  identity or confirming employment status.    The TSA already requires that airline pilots possess one or more  government-controlled,  photo-bearing ID cards.  The airline ID card with photograph, unlike the proposed FAA pilot certificate, is electronically verifiable  via the Cockpit Access Security System.     It is unnecessarily duplicative to  require airline pilots to pay for a third method of identity  verification when most, if not  all, airline pilots already carry two or more government- regulated photo ID cards which serve the intended purpose.   Recommendations   ALPA recommends that the FAA amend its proposal by exempting FAR Part 121 and 135   airline pilots from this  rulemaking. As justification for doing so, the agency can rightfully assert  that, for these pilots, it already meets the inte nt of the IRTPA™s Section 4022 as relates to issuance of improved pilot licenses (i.e., today™s FAA-issued plastic pilot certificates) that are resistant to tampering, alteration and counterfeitin g.  When presented in co mbination with airline  ID cards, SIDA cards, and/or passports, as is the case during airlin e operations, the FAA  certificate already provides the security features that are needed for this application.   We further recommend that FAA establish a mean s for pilots to identify themselves to the  agency as airline pilots for purposes of exemp ting them from the requirement to obtain a pilot  certificate with a photo. To this end, we would propose that the individual pilot request an exemption from the FAA by completing and submitting a form designed for that purposeŠ which form would be signed by both the pilot and th e airline™s chief pilotŠconfirming that he or  she is currently employed by an airline conduc ting Part 121 or Part 135 operations. A photocopy of the pilot™s airline ID would be attached to this form as further evidence of the pilot™s  employment status. Any airline p ilot who may wish to have a p ilot certificate with photo would  be able to obtain one by submitting the requisite photo and fee.    Thank you for the opportunity to comment on this proposed rulemaking. P lease contact ALPA  Aviation Safety and Security Specialist Greg Bergner ( greg.bergner@alpa.org, 703-689-4351) with any questions or comments.   Sincerely,  Capt. Robb Powers, Chairman   National Security Committee   BESTiFLlGHI \\'^ \\'W&& --\\'OPERATIONS ^^:ur;EC-s Pj2:0b Docket Operations, M-30; U.S. Department of Transportation 1200 New Jersey Avenue, SE., Room Wl2-140, West Building Ground Floor, Washington, DC 20590-0001 Re: Docket Number FAA-2010-1127 03 December 2010 Dear Sir/Madam: 1 write with several concerns over the proposed rulemaking. It appears the agency is engaged in eisigesis, picking rules from TSA, DEA, and the State Department to establish a new and burdensome procedure, while disregarding other mandates and project management best practice. I have no problem with photos or biometric data, but the system and its implementation must be logical and streamlined. At the end of the letter are suggestions that deliver real value to pilots. (1) It is a semantic difference only to say that a pilot certificate is good until \"surrendered, suspended, or revoked\" if the certificate may not be exercised when the corresponding photograph has expired. In practice, this rulemaking will result in the expiration of a certificate. Insofar as the agency has already established that the current cost of certificate issuance is $50, and that it intends to escalate the price every year up until it reaches the cost of production, this would appear to be a revenue enhancement venture. There is no evidence in the NPRM that the proposed photo procedure is \"in the interest of reducing burdens on the certificate holder...\" (2) Duplication of effort with the provisions of P.L. 107-71. In November 2001, Congress established a requirement for credentialing of pilots requiring access to an airport (which includes most of us). This credential is the Transportation Worker Identity Credential (TWIC). Has the FAA made any contingency plans for this program? It would be counterproductive to change pilot certificates three times in ten years. (3) The requirement for a 2\"x2\" paper photograph is obsolete. Only artists produce silver prints in 2011. The original image of all photographs today is digital. To create a digital image, convert it to paper for conveyance to the FAA, who will in turn digitize it again, is a waste of resources. The facial image should be supplied only in digital form. The TSA specifically prohibits paper photographs in its alien flight training tracking program for the same pilots. (4) The FAA has gone to great expense to develop lACRA, an excellent system that eliminates paper and increases accuracy in the production of certificates. To regress to a paper-based 8710 system is to move back to the twentieth century. The TSA\\'s corresponding system www.flightschoolcandidates.gov allows upload of photos. lACRA should be modified similarly. This is not difficult work. The DPE can verify the photo image against the person who shows up at the practical test. (5) The revocation of an AME\\'s right to issue a student pilot certificate is prejudicial to the rights of sixteen year-olds who wish to fly. The practice today is that a qualified sixteen year old gets a medical examination in the morning and solos in the afternoon. A delay of six to eight weeks for the FAA to process paperwork works specifically to the loss of youngsters who wish to become -2-pilots. This class would be unfairly singled out. The NPRM callously disregards our next generation of pilots. (6) It is illogical to say that collecting a digital image is burdensome on an aeromedical examiner. A digital image is simply another form of biometric data, just like weight, height, or eye color. If it is burdensome to collect a picture, then it is similarly burdensome to collect eye color, a bodily attribute that does not have anything to do with the health of the candidate. If the AME is the logical party to collect biometric data, as it does already, this is an option that must be investigated, and not summarily dismissed. (7) The NPRM fails to discuss the possibility of issuing a single certificate for flight instructors, rather than a pilot certificate and separate instructor certificate. This practice made sense when replacements were a two dollar affair, printed paper with no photo. Remember, a flight instructor certificate is without value absent a pilot certificate. The two should be combined. If the FAA intends to spend close to a half-billion dollars on this effort, the procedure should be designed by an expert, and not a patchwork based on whatever is easiest today. It is pointless to simply substitute the pilot\\'s photo for the Wright\\'s and call it a day. The NPRM is even more telling in its estimate of time required by pilots to fulfill the requirements of the proposed regulation - more than six million hours over the life of the program. I doubt this number. It takes an hour to drive to a shop to have a passport photo taken. In the long run, the certificate will include the following elements: Ł Certificate holder demographic information including name, address, date of birth, certificate number Ł Certificate holder biometric information (human readable) including eye color, height, weight, etc Ł Certificate holder photographic image Ł Photograph expiry date Ł Certificate holder privileges, ratings and limitations Ł Certificate holder biometric data (machine readable) which may include Ł Fingerprint code Ł Hand geometry Ł Iris scan data Ł Data store (\"smart card\") Ł Contactless data interchange device Ł FAA media identification The certificate will meet several needs, including identification to authorities as currently obtains and as an access control device as obtains in the maritime industry. This would be a big help for a pilot who goes to multiple airports every day. This would make the new certificate a valuable improvement for most pilots. If the FAA does not cooperate with DHS, then we will end up with multiple cards, with costs associated with each. If agencies fail to cooperate, here is the list of badges and licenses 1 will be forced to carry: Ł Pilot Certificate Ł Instructor Certificate Ł Medical Certificate Ł TWIC Ł Airport ID (multiple) Ł FBO ID (multiple) Best in Flight Morristown, 9 Airport Road, Morristown, NJ 07960 (973) 683-9002 www.bestinflijj-ht.net IWantToFly@bestinfIight.net -3-This project is not suitable for academic testing centers. Testing centers are not equipped with the equipment required to collect fingerprint data, iris scans, or handprint geometry. This project is not a $5.2 million dollar project for a contractor. It is certain to be much more, as the DHS discovered when it issued its final rule for TWIC cards in 2007. The cost for that certificate is now $132.50. This program needs to be well thought out, as the implementation of TWIC in the maritime industry was not. They have learned many lessons that the FAA should consider before engaging it its second certificate overhaul in ten years. If this one is not done with forethought we will see a third overhaul, with all of its attendant effort and expense again, before this one is complete. The FAA has the opportunity to plan properly and do a job that makes everyone\\'s life easier: the pilot, the FAA, and all of the DHS agencies who want photos, fingerprints, and demographic data for their dossiers. Stop the process and think it out from first principles. Then do it right. I am available to help your staff develop a statement of requirements and workplan if you so desire. Sincerely Robert Hadow Chief Pilot Best in Flight Morristown, 9 Airport Road, Morristown, NJ 07960 (973) 683-9002 www.bcstinflii/ht.net IWantToFly@bestinflight.net        P.O. BOX 3086 OSHKOS H, WI 54903 - 3086     T el   920.426. 6522      F ax   920.426.6560     WWW.EAA.ORG                 February 17 , 2011     Docket Operations, M - 30   U.S. Department of Transportation   1200 New Jersey Ave., SE   West Building Ground Floor, Room W12 - 140   Washington, DC  20590 - 0001     Reference:  Comments to  Docket No. FAA - 2010 - 1127, Photo Requirements for Pilot  Certificates     Dear Sirs ,     EAA (Experimental Aircraft Association) is the world leader in recreational aviation.   With an international membership of  160,000 people in more than 110 nations,   EAA  brings together aviation enthusiasts, pilots and aircraft owne rs who are dedicated to  Sharing the Spirit of Aviation  by promoting the continued growth of aviation, the   activities and events are known throughout the world for  Preserving   the heritage of  aviation,  Promoting   access to flight,  Protecting   the right to fly,  Preparing   for the future  of aviation, and of our  Passion   for aviation safety and education.     The proposal to include a photograph of the airman on FAA issued pilot certifica tes is  intended to fulfill the requirements of the Intelligence Reform and Terrorism Prevention  Act (IRTPA) enacted December 17, 2004.  While EAA has historically supported the  concept of improved identification on airman certificates we do not support the   adoption of th e proposed requirements because:       The proposal would pose an unnecessary financial burden on pilots with no  increase in the current level of security;      May  not  meet all of the congressionally mandated security requirements;     Does not satisfy  Department of Homeland Security (DHS) and Transportation  Security Administration (TSA) standards for secure identification; and     An estimated six to eight week delay for the issuance of student pilot certificates  is unacceptable.       Although EAA does not su pport the adoption of the NPRM in total as proposed,  comments are provided below regarding the seven specific question s the Agency is  seeking input .           P.O. BOX 3086 OSHKOS H, WI 54903 - 3086     T el   920.426. 6522      F ax   920.426.6560     WWW.EAA.ORG       Unnecessary Financial Hardship     Statutory authority permits the FAA to charge a maximum fee of $22.0 0 for issuing,  upgrading, or adding ratings to an airman certificate.  If the proposal is adopted, the  Agency would begin to charge at least that amount.  Depending on the outcome of the  FAA Reauthorization process, these fees could increase to $50 for iss uing a certificate  or rating and $25 for its replacement.       Additionally, since the proposal would require in - person identity verification, the FAA  anticipates allowing designees to accept and verify applications for pilot certificates  with photos to less en the inconvenience to certificate holders and new applicants.  The  designees would then be at liberty to charge an additional fe e on   top of  one charged by  the FAA.  There  is no means  to es timate this   designee fee .       During the implementatio n period, when a pilot applies for a new certificate or rating, it   certificate with a photo.        ach.   A pilot with an airline transport pilot (ATP) certificate would have three years after the  final rule becomes effective to obtain a pilot certificate with photo.  A commercial pilot  would have four years, with private, recreational, or sport pilots h aving five years to   -      The proposal estimates the total costs to pilots would be $445.8 million over a 20 - year   -  r commercial  pilots; significantly more than the $22 fee proposed.  EAA would argue that the costs  would be similar for any pilot, regardless of certificate level, and disagrees with the  FAA assumption that $175 per renewal does not represent a significant   impact.       EAA cannot support the adoption of the proposal due to the uncertainty in the fees  imposed upon the pilot community.  The proposed fee is $22 per certificate but the  NPRM clearly indicates the fee would be adjusted periodically based solely on  an FAA  estimate of expenses to provide the service for which there is no incentive to control  costs.  Additional fees would then be added for designee identification verification.  The  actual costs to the pilot community are effectively impossible to estim ate and  significantly understated in the NPRM.                         P.O. BOX 3086 OSHKOS H, WI 54903 - 3086     T el   920.426. 6522      F ax   920.426.6560     WWW.EAA.ORG       No Increase in the Current Level of Security     Pilots are currently required under 49 CFR §61.3 to have photo identification in their  possession or readily accessible when exercising the privileges of their p ilot certificate  or authorization.  The photo identification must be a:     1.      issued by a State, the District of Columbia, or territory or  possession of the United States;   2.   Government identification card issued by the Federal government, a   State, the  District of Columbia, or territory or possession of the United States;   3.      4.   Official passport;   5.   Credential that authorizes unescorted access to a security identification display  area (SIDA) at an airport regula ted under 49 CFR part 1542; or   6.   Other form of identification that the Administrator finds acceptable.       T he above documents co ntain   a photo of the pilot and requir e   in - person identity  verification.     EAA posits that there will be no increase in the current  level of security by placing a  photo on a pilot certificate when compared to the current requirement under 49 CFR  §61.3.     Congressional Mandate Requirements     Section 4022 of IRPTA requires the Agency to issue improved pilot certificates that:     1.   Are resistan t to tampering ,   alteration, or counterfeiting;   2.   Include a photograph of the individual to whom the certificate is issued; and    3.   Are capable of accommodating a digital photograph, a biometric identifier, or  any other unique identifier the FAA Administrator co nsiders necessary.     The Drug Enf orcement Assistance final rule required all pilots to obtain a plastic  certificate by March 31, 2010.  These new plastic certificates are resistant to tampering,  alteration, or counterfeiting, satisfying the first IRPTA requ irement.       As previously stated, EAA considers the coupling of a pilot certificate with  government - issued photo identification to meet the second requirement of the IRPTA.     Regarding the biometric identifier, the magnetic strip located on the back of  curr ent  pilot certificates could  contain   biometric data, subseq uently meeting the mandate  requirement.           P.O. BOX 3086 OSHKOS H, WI 54903 - 3086     T el   920.426. 6522      F ax   920.426.6560     WWW.EAA.ORG       However, any proposal from the Agency could be determined not to meet all of the  requirements of IRPTA.  Biometrics consists of methods for uniquely recogni zing  people based upon one or more intrinsic physical or behavior trait.  Biometric  characteristics can be divided into two main classes; physiol ogical and b ehavioral.   Physiological biometric examples include fingerprint, face recognition, DNA, palm  print , hand geometry,  iris recognition, and/or retina scans.  Behavioral  examples include  gait, typing rhythm, and/or  voice verification .  EAA considers the  re quirement fo r  biometric data on   a pilot certificate, which most pilots never present, u nnecessary and  excessive.       EAA contends that the current pilot certificate meets the IRPTA requirements when  coupled with a government issued photo ID as per required by §61.3.     DHS and TSA Identification Standards     The proposal states that the TSA is c onsidering a rulemaking to improve security  vetting of airman certificate holders and applicants for airman certificates.  If the TSA  issues a final rule regarding airman security vetting, the FAA may issue conforming  requirements in any final rule resulti ng from this proposal, subsequent to a  supplemental notice of proposed rulemaking, or as part of a new rulemaking project,       A   TSA identification rule would affect operations at airports that have co mmercial  service, as was the case with its commercial airport Security Directive 1542 - 04 - 08G.   The FAA currently lists  551 Part 139 airports versus 5,200 general aviation airports.   Pilots choose to operate into or out of an airport with commercial service   and those who  do are required to comply with any TSA identification requirement.       EAA contends that a revised pilot certificate must meet  any current and proposed TSA  requirements.  However, the revised certificate should be elective in nature.  If a pi lot   to a new FAA issued pilot certificate that a lso meets the TSA requirements.  Any   new  pilot certificate should   meet  all security badge requirements for airports.   The current  patchwork of airport specific SIDA cards has proven t o be prohibitively burdensome.     pilot certificate, thus foregoing the expense and time required to obta in one.       EAA suggests the Agency consider the Transportation Worker Identification Credential  (TWIC) program before implementing another pilot certificate change.  The TWIC  program provides a tamper - resistant biometric credential to maritime and other  tr ansportation workers requiring unescorted access to secure areas.       The Government Accountability Office has said the TWIC program has suffered from a  lack of oversight and poor coordination.  A delay in the development and  implementation of card reader t echnology has resulted in significant rollout issues and        P.O. BOX 3086 OSHKOS H, WI 54903 - 3086     T el   920.426. 6522      F ax   920.426.6560     WWW.EAA.ORG       lag time.  Lessons learned from the TWIC program should be examined and studied  before the Agency adopts any pilot certificate upgrade proposal rather than expedite the  NPRM that could ultimately fac e the same problems the TWIC program is facing today.       Student Pilot Certificate Lag Time     The proposal notes that the issuance of a pilot certifica te with photo could take up to six  to eight   weeks.  EAA is concerned about the effect this could have on the stu dent pilot,  now required under the proposal to obtain a certificate with photo.       A student pilot in an accelerated course could be ready for his   or her first solo well  before six   weeks.  If he or she is then forced to effect ively stop their training   and wa it  for  a pilot certificate , there would be a degradation of skills, often requiring remedial  training and added expense.       Currently, student pilots can obtain both their student pilot certificate and medical from  an Aviation Medical Examiner (AME).  If t he proposal is adopted, student pilots would  still have to go to an AME for their medical, but now also to a FSDO, knowledge  testing center, or designee for identity verification and pilot certificate application.  This  represents an additional barrier to  entry when the industry continues to see pilot  numbers decline and a student pilot attrition rate of 70 to 80 percent.       Responses to specific NPRM questions     (1)    Should the FAA require applicants to produce fraud - resistant documents to verify  identity?    If so, which documents or other identity verification procedures should the  FAA implement to ensure a high level of confidence in the verification process?       Again, EAA encourages the Agency to use the framework established by the  TWIC program and adopt th e list of documents it uses for identity verification.     (2)    Should the FAA consider an alternative im plementation     -        EAA urges the FAA to work with the TSA and coordinate any pr oposed  rulemaking and postpone any changes to pilot certificates until pilots can be  assured a new certificate satisfies all federal requirements.       When that assurance can be guaranteed, EAA recommends the implementation  be phased in, on an as - needed bas is.  Pilots operating into or out of Part 139  airports or needing access to security identification display areas would be  required to obtain new certificates.  These new certificates would meet all  requirements for TSA and FAA and should give the pilot ac cess the non SIDA  areas of all airports rather than  only  one.           P.O. BOX 3086 OSHKOS H, WI 54903 - 3086     T el   920.426. 6522      F ax   920.426.6560     WWW.EAA.ORG         This approach will allow pilots who need an enhanced photo identification to  obtain one and pilots who choose not to operate in that environment to opt - out.   A pilot operating out of an uncontroll ed grass - strip has no need for such an  identification badge and would represent an additional burden with no  commensurate benefit.       (3)    Are there alternative, potentially less burdensome, methods for pilot within the U.S.  and outside of U.S the FAA shou ld consider   to accept pilot certificate applications and  validate applicant identity ?       EAA views the least burdensome method for a pilot to submit a pilot certificate  application and validate applicant identity to be at the local FSDO office.  There  will b e additional costs for travel and time, but the FDSO method represents the  only alternative in which an additional, yet to be determined, fee would   not   be  imposed on the pilot.  EAA would encourage the Agency to develop the training  and equipment for photo cap ture, processing, and uploading at the FDSO office,  if the proposal is adopted.     EAA also recommends the FAA develop a pilot certificate outr each program  where FAA Inspectors travel to major aviation events, such as AirVenture  Oshkosh.  The outreach program should provide a complete one - stop  application, validation, and photo taking pilot certificate conversion facility for  pilots to take advan tage of while at these major events.      (4)    Is the proposed 8 - year duration for the photo, based on the photo duration for state   e  security needs expressed in IRTPA and the burden on certificate holders?       In order to provide continuity throughout the federal government and lessen the  possibility of future changes, EAA would recommend, if the proposal is  adopted, the Agency include a n 8 - ye a r duration   for the photo in order to comply  with the requirements under the Real ID Act of 2005.     (5)    Is there any reason why student pilot certificates should not be treated like other  pilot certificates for the purposes of meeting the IRTPA req uirements?       As previously stated, the proposal notes that the issuance of a pilot certifica te  with   photo could take up to six to eight   weeks.  EAA is concerned about the  effect this could have on the student pilot, now required under the proposal to  obtain a cer tificate with photo.       A student pilot in an accelerated course could be ready for his   or her first solo  well before six   weeks.  If he or she is then forced to effectively stop their        P.O. BOX 3086 OSHKOS H, WI 54903 - 3086     T el   920.426. 6522      F ax   920.426.6560     WWW.EAA.ORG       training   and wait for their pilot certificate to arrive, there woul d be a degradation  of skills, often requiring remedial training and added expense.       (6)   With respect to the photo that is placed on the pilot certificate, should the FAA  accept only hard copy photos, only digitally - captured photos, or either hard copy o r  digitally - captured photos?         In order to ensure the application and verification process to be the least  prohibitively burde nsome, EAA would recommend the A gency accept either a  hard copy or digitally captured photo.       (7)    If the FAA accepts digitally - captured photos, what are the advantages and  disadvantages of the following   methods of acquiring the photo?       a)   A n applicant uploading a self - captured photo to the IACRA sub - system;       Advantages     low cost possibility regarding time and travel       Disadvantages      lack of continuity and additional fee for DPE     b)   FSDO capturing the photo when the application is submitted;       Advantages     high level of continuity for photo, equipment and training  would also be standardized, no additional fee for applicant       Disadvantage s     costs incurred for travel and time     c)   Knowledge Testing Center capturing the photo when an application is  submitted;         Advantages     geographic proximity to applicant       Disadvantages     additional fee     d)   DPE capturing the photo when an application is submitte d?       Advantages     geographic proximity to applicant       Disadvantages     additional fee, lack of training, continuity                   P.O. BOX 3086 OSHKOS H, WI 54903 - 3086     T el   920.426. 6522      F ax   920.426.6560     WWW.EAA.ORG       Summary     EAA  recognizes   the FAA proposal is in response to section 4022 of the Intelligence  Reform  and Terrorism Prevention Act .  H owever , the IRTPA  was enacted December  17, 2004 and  EAA  question s   the urgency and  fundamental   need for  this   proposal.       EAA believes the proposal, if enacted, would pose an unnecessary financial burden on  pilots with no increase in the current level of security, may   not meet all of the  congressionally mandated security requirements, not satisfy DHS and TSA standards  for secure identification, and force student pilots to unnecessarily delay training.       EAA recommends the Agency postpone any rulemaking relating to  photo requirements  for  pil ot certificates   until the p roposed change  align s   with TSA security requirements.   In addition , the new certificate should meet all Part 139 airport security badge  requirements.  EAA firmly believes new certificates should be issued on an as - needed  ba sis and only for those   pilots who choose to operate  at  airports requiring security  badges per TSA Security Directive 1542 - 04 - 08G.       EAA appreciates your time and the opportunity to commen t on this matter of significant   importance to the aviatio n community .  We stand ready to answer any questions or  provide any  additional information  require d .     Respectfully,     David Oord   Government & Advocacy Specialist      ',\n",
       " 'While I recognize the necessity of adding a photo to my pilot\\'s certificate, the onerous process proposed is not necessary.  My sending you a passport photo would certainly suffice: the State Department seems to find it so when I renew my passport.  To say that there will be no cost to a pilot is nonsense.  BTW: i have never been asked to show my pilots license to anyone: I have been flying for over 50 years. Requiring a student pilot to obtain a photo ID seems ridiculous considering that for all practical purposes, they cannot fly without instructor approval.  It is bad enough that the license fee has to be paid each time a rating is obtained, but in the case of a student pilot, there is an event requiring replacement in a time-frame much shorter than the 8 year lifespan of the photo ID and makes the financial burden larger than that discussed in the NPRM.  This is not earth shattering in cost, but let\\'s be reasonable!  I\\'m not sure that the cost of obtaining the requisite photo is appropriately addressed.  References were made to passport photo establishments or possibly having digital photos made at the location that the pilot presents themselves to, to prove they are really themselves.  This will not be a free service and will again change the cost of the NPRM from that presented.    We pay for a passport, then a drivers license, then a carry permit, then a pilots license then....  Why not consolidate all these id\\'s into one?  Right now any pilot has a photo id in addition to his new plastic license---adding a photo to a license does nothing but increase costs.  We have got to find a way to reduce costs. The public is being taxed to death under this guise of safety and all this duplication does nothing but COST. After reading the proposed regulation I feel that this is a good idea.  The inclusion of a photo on pilot certificates would provide another form of governmental issued ID, and provide additional ID security at airports.  I feel that the requirements for the photo should conform to those for a passport, and would like to see them verified as a passport is before being issued.  I also feel that the 8 year renewal is appropriate, but would urge the FAA to allow the \"Bi-annual\" flight review requirement to be extended to 8 years at the same time.  I feel that a 2 year phyisical exam (by a flight surgeon)would be appropriate  to keep pilots safe and would reduce a costly process that has no parrallel requirement for other operators such as drivers license for trucks or autos. This is another one of those feel good initiatives. It will be expensive and never used. Why not just say that unless the pilot doesn\\'t have other photo id  (such as a drivers license) this is required. How many pictures of me do you need? I have a TSA ID to get to my plane with my picture on it, I have a drivers license with my picture. How much do we need? How about a dna sample with the picture. Again, how much will the expense of this program be? Are there any pilots in the US that don\\'t already carry photo id? Requiring a photo ID pilot license is a load of useless stuff.  Every pilot already has other suitable photo ID cards to confirm their identity.  The FAA does not need and should not require a pilot license with photo ID.  This regulation, if enacted, will hinder new pilot starts and needlessly cost the aviation community billions of dollars.  DO NOT ENACT THIS FOOLISH RULE! The regulation for Photo I. D. has already been established with the requirment to have a picture I.D. to be produced on demand with your license.  Most all States require a picture on your drivers license to be updated on renewal. This is done in 4-5 year periods. With the Fed. Gov. wanting to limit costs the law as it stands should be sufficient. With ones driver\\'s license the replacement photo is of a quicker duration therefore a better security check. If the State revokes yor operators permit then you would be grounded. Not so with this new law if inacted. The cost added to a student just starting out is a greater burden. The cost to the Federal Gov. is a greater burden. Safety as well as securty will not change. Following are my comments on subject NPRM:  1.  I doubt anyhone would object to a photo image on one\\'s pilots license as this is standard procedure for drivers licensing, at least here in Washington State.  What is objectionable from what I read in the General Aviation News is the potential cost:  $ 50 to as much as $ 210 for a  new certificate.  Also, requiring CFIs to get a new photo license every two years is simply ridiculous.  Here in Washington my driver\\'s license is valid for 5 years.  2.  The FAA should investigate how states, e.g., Washington, can issue photo drivers licenses on a massive scale, at modest cost and inconvenience to each applicant.  Perhaps a cooperative deal could be struck so a state licensing department could do the photo work for the FAA.  3.  The Immigration Service has specific requirements for photos used in passports.  There are specialty shops that do passport photos.  The customer provides the photos, wherewithall ($) and the Immigration Service issues the passport.  The last passport I got in 2007 cost around $ 67 and is valid until 2017 (10 years!).  Perhaps the FAA could implement an arrangement with either the Post Office Dept. or the Immigration Service whereby a pilots license applicant could obtain and fill out the application, provide the required photos and fee and mail same to the FAA for processing.  Alternately, all this could likely be done On-Line, however not everyone has the computer equipment or ability to do this with assurance the photo image transmitted over the Internet would be usable.  Jim Roelker I strongly disagree with the need for this regulatory change.  It will offer no benefits and yet result in significant costs in both time and money.  We should be standardizing on photo IDs - not increasing their number.  If photo ID is required with FAA certificates, then simply use the existing driver\\'s license, passport, etc.  Please don\\'t let this measure go forward.  It is an example of government waste.  Unecessary.  Costly.  It will not increase security or improve non-repudiation.  Let common sense prevail! My comments on the requirement of a picture on the pilot\\'s license:  Why are pilots continuing to be harassed?  This is just more \"feel good\" BS.  How many of the 9-11 cowards had a license?  This requirement will help nothing.  The cowards stayed beyond their visas. Keeping illegals out of our country will keep the country safer.  The government needs to quit harassing law abiding AMERICANS !  Greg Holt Michie, Tennessee This is going to put a big strain on student pilots. 6 to 8 weeks wait on plastic card just to solo? Most General Aviation student should solo in 4 to 5 weeks so this is going to prolong that moment plus let instructors charge for more hours. Students are not completing their training now and we need more General Aviation pilots. Photos are ok, but drivers license have photos and act as ID. Let students use Gov issued photo IDs and not have to wait on their plastic to solo. Give us at least 10 years between renewal and don\\'t make it so hard and expensive to get a photo to the FAA. Post Offices issue Pass Ports so use them. (Seems They Need The Money!) This requirement make no sense and serves no purpose.  Pilots are already required to carry a government issue photo id, such as a driver\\'s license. A driver\\'s license expires every few years and a new photo is taken.  A pilot\\'s \"license\" is really a certificate, and has no expiration date.   A photo could be rather old - even before the bearer looks like Orville & Wilbur Wright on the backs of the currently issued card. This is not needed nor desired.  It\\'s already required to have a valid drivers license or some form of photo ID in order to exercise the privilege of pilot.  All this regulation would do is add costs and expansion to government. It has no other real useful value.  The FAA already has enough on it\\'s plate to do. Get to what\\'s important involving safety instead of wasting time and dollars on things that aren\\'t.   -Ben I am a pilot who holds a FAA Sports Pilot license #3401072 and I\\'m writing you to say that the proposed Photo Requirements for Pilot Certificates (Document ID FAA-2010-1127-0001) is, in my opinion, wholly unnecessary and fiscally wasteful of money that should be used for other more important needs at this time of scarce resources and tight budgets.  I know the importance of the need for increased security that we have at this time in our country but this proposal is, in fact, redundant in that we are required to carry a governmental issued ID that has a photo, IE. drivers license or passport and therefore this requirement is a waste of money that could be put to better uses.  If this proposal becomes a requirement by law, it will NOT enhance our security in the least bit and will cost far too much of our dwindling available money for a result that returns no value for the effort.  I urge you to rethink this course of action that you are proposing.    Sincerely,  Joseph Swift Dear Sirs,  Who dreams this \"STUFF-UP\" ?    Is it because you are worried about losing your gov\\'t job ?  A drivers license has all the information required for the FAA and law enforcement need if there is a problem.   I know, I have been a active law enforcement officer for over 30 years.  This issue to require photo ID\\'s is just plain hog wash.   Criminal acts will continue with or without an photo ID. This is why we have paid law enforcement officers and laws. This requirement to have photo ID\\'s will just take more time and money away from catching criminals. It won\\'t help.  Jeff Aryan I believe the requirement for a photo pilot certificate is unnecessary. The current rules requiring a photo id, drivers license, passport, etc. are sufficient and requiring this duplication of regulations will in no way enhance security and only cause additional cost and regulatory burdens on the aviation community.  I am opposed to the proposed photo licenses for pilots because I think it imposes unnecessary costs to the pilot. We already have photo ID for driver\\'s licenses and the pilot\\'s license is never requested to verify an individual\\'s identification. This proposal creates another expensive program & more requirements for pilots while offering no measurable benefits.  Please do not add more layers of bureaucracy when there is no need for redundant forms of photo ID. This requirement will not improve the current level of security and will pose an unnecessary financial burden on the pilot community. I have A VALID state drivers license with photo ID that has been \"the official\" form of identification by all Federal and State agencies.   Rename my state issued \"drivers license\" to \"transportation license\" and include my pilot ratings and certifications on it.   Steve Ware  !. Is there a problem with the current system? 2. Is the photo required on all licenses? e.g. I have a pilot\\'s license, a flight instructor\\'s license and a ground instructor\\'s license. Will the cost be $66.00 PLUS the cost of the photographs? 3. Will this really have some benefit somewhere?   If it ain\\'t broke, don\\'t fix it. Rule is totally uncalled for. Every State requires a photo Drivers License. Why burden us with the hassle of getting  another license at great expense. More rules and regulations are just going to cause many to drop out of aviation which is tough enough to stay in as it is. I\\'m not sure what the purpose of this new rule would be. A pilot is already required to carry photo ID on his person when exercising his pilot privelages. I carry my drivcer\\'s license on my person along with my pilots license. If when contacted by any authority, the information on my pilots license will match my driver\\'s license and the photo on the driver\\'s license must be renewed every three years which would be more current than the \"eight year\" renewel for the pilots license should this pass. I might not be understanding something I guess... I think the idea of photo ID for pilots is good.   I don\\'t think taking 8 months for a student license is good. That will deter people from geting their license. Maybe students can be exempt  They are mostly with a Licensed Instructor any how.  I think if your gonna put an experation date on the photo then it should be on the license it\\'s self. Either way if the photo is expired then the licence is too.    The best way to do it would be copy the DMV departments and how they handle the photos.   I think photos should be on the maintenance licenses also. This is why my country is in debt (trillions!): wasteful administrators proposing duplicitous photo IDs (and grabbing more of my money!).  If my driver\\'s license with photo ID is sufficient in every state of my country, why isn\\'t it good enough for an FAA investigator?  I\\'d rather show them my passport; but maybe that isn\\'t good enough either.... The expiring license and the requirement for a photo is redundant. As a pilot I am required to have in my possession a form of photo identification such as a driver license, passport, or other form of a government issued identification. There would be no need of an expiring license if the photo was on another document, such as a driver license. I have three FAA issued licenses, Commercial pilot, Flight Instructor, and Instrument ground instructor. Would I have to obtain three separate photo Licenses?  I can see nothing to be gained for security, or any other matter, by burdening United States of America pilots with new certificates at a considerable expense to each individual. In my normal routine of flying I have never been asked to show my pilot certificate so were is the new certificate going to be a help? As President of the Missouri Pilots Association, an aviation organization founded in 1953, I speak for our Board of Directors and over a 1000 pilots residing in the State of Missouri.  The Federal Aviation Administration is obligated to comply with existing federal laws.  The Intelligence Reform and Terrorism Prevention Act, enacted December 17, 2004, states that our pilots license is required to include a photograph.  This requirement is stipulated in Section 4022 of the Act and is quoted here: INTELLIGENCE REFORM AND TERRORISM PREVENTION ACT (IRTPA) December 17, 2004 SEC. 4022.  IMPROVED PILOTS LICENSES. (b) REQUIREMENTS.-Improved pilots licenses issued under subsection (a) shall- (2) include a photograph of the individual to whom the license is issued. This task is to be accomplished by the F.A.A. by whatever mechanism they design. The current proposed rule to accomplish this is cumbersome, extremely expensive and is inconvenient for pilots. Two Suggestions: All of the Department of Motor Vehicles have digital photos stored.  They are taken and verified at the time a license is applied for or renewed.  The F.A.A. regularly communicates with the DMVs when verifying the driving violation record of a pilot  The license application could have a check box asking that the digital photo be transmitted to the F.A.A. The second possibility is that all Flight Medical Examiners be equipped with a simple computer digital camera.  At the time a physical is taken the pilot\\'s picture can be taken, verified and sent to the F.A.A. We all take our physicals at least every two years and renew our drivers licenses every two years.  Using the DMVs and Flight Medical Examinations, this requirement could be accomplished well within the four year time period.  The cost to the pilot would be minimal and there would be no extra travel time because it would be accomplished at the time of drivers license renewal and/or when taking a flight physical. This photo ID is totally unnecessary!!  In 43 years as a Military Pilot and Commercial Airline Captain, I have never had to show any proof of who I was.  Why all of a sudden do we pilots have to do this?  It is another hidden tax that you bureaucrats don\\'t need and can\\'t manage.  Forget it NOW!!!   As Patton once said,  \"NUTS to you\"   I suggest a photo expiration of 10 years instead of the proposed 8 years.  When I first heard about this proposed rule with the 8 year expiration it seemed to me that 10 years would be a more reasonable duration. A person\\'s appearance does not change that much in 10 years, so security would still be maintained. This would also cut down on the overall cost to pilots and to the FAA (fewer renewals to process each year). Then when I read the proposed rule I noticed that 10 years was considered. In the rule the point is made that a 10 year duration would agree with the passport expiration. That is another great point for making it 10 years instead of 8. 10 years is also easier to remember so that a renewal is not missed. (I also like the idea of having the expiration on the photo, but then how ofter do we really look at our license expirations.)  I do not see any advantage to having it be only 8 years as opposed to 10, but there are several advantages to setting it at 10 years as opposed to 8.  I am an airline captain flying the Boeing 757 and I hold a current CFI certificate. I feel that incorporating a photo ID on pilot certificates is a big waste of money.  The requirement of a valid additional photo ID such as driver,s license or passport or whatever is sufficient.  Incorporating a photo on the pilots license itself may be nice and pretty, but it does absolutely nothing to enhance security, and just increases cost and unnecessary inconvenience.  You could simply have a secure website for appropriate authorities to check on any pilot certificate for validity, and POP, like magic, there is all the info, including photos, drivers license and whatever info in the database is necessary  to validate the identity of a person in question.  Why bother with the photo stuff.  Be ahead of the curve, not behind it. I don\\'t mind the additional security benefits of having a photo federal ID. I just hope that it remains at very low cost. In the state of Connecticut driver\\'s licenses are darn near $100. Part of this is because they are calling a tax a fee instead of a tax (illegal) but I won\\'t go there.  I don\\'t want to see this happen with pilots\\' licenses as well since the cost of flight training is already out of reach for the average joe. Also, as a CFI, I certainly DO NOT want the Flight Instructor cert to also have a picture that has to be updated every two years because that would be a ridiculous pain in the butt. So go ahead and give me a photo federal ID, but if costs more than 50 cents or a dollar per person than forget about it. And please do not put them on certificates that expire every two years! Isn\\'t more secure and less costly under the current regulation. Requiring a second form of PHOTO ID seems a more secure way of positively matching an airman with his certificate.  I imagine the vast majority of pilots drive to work, therefore possess a driver\\'s license.  It would have to be easier to falsify one ID than two, wouldn\\'t it? We have enough picture Id\\'s. This would create a burden on young Flight Instructors and Pilots barely getting by. Only one picture I.D. should be required and not limited to a pilots license. A drivers\\'s license, passport, military ID or some other form of government I.D. should be acceptable. We don\\'t need this extra useless costly rule bogging down the pilot community. What will change, will it make us safer ? No ! Current FAA Pilot licenses already require an accomapnying government issued ID to make them valid.  This requirement is a duplication of effort, cost, time, etcetera, and is NOT only not necessary, but does nothing to ensure or enhance safety or security.  Further, an instructor\\'s license already requires a valid pilot license which again requires a valid government ID.  Additionally, the necessary required paperwork associated with this proposal would be difficult, if not impossible to comply with when soloing young students (age 14) as can and has been done for years in balloons and gliders.  It would also prevent them from getting their pilot\\'s license on their 16th birthday, as many famous aviators have done.  There is not one single, valid reason for imposing this burdensome requirement on pilots and instructors.  I highly recommend, and request that this rule not be adopted.  (What has worked well for 100 years through the present, is more than sufficient for the future.)  Who ever is in charge sure does not think too far ahead and seems to like to waste the goverments money.  Last year our goverment spent a lot of money having all pilots and mechanics go from paper to plastic certificates, now some one wants to have all theos replaced with new ones with our picture on them and charge us $50.00. I don\\'t know about other states but the state of Florida has your photo on thier drivers license. Isnt that enough proof to identify who you are  when you compare the adress on your certificate to your drivers license. All the goverment needs to do is to have a law that you must have a drivers license in order to have a pilots or A&P certificate. If the goverment feels the need to have your photo on your certificate they could have you go to the local drivers license bureau surrender you present certificate have your picture taken and give you a new certificate with your photo on it and charge you a fee equal to the drivers license fee. What a great incentive not to be a CFI or a student pilot. The student pilot exercises the privileges of a PIC based on the instructors\\' endorsement(s). So the student is basically flying on the CFI ticket. The CFI knows the student. With this NPRM, if the student pilot is ready to solo, he/she must wait for their photo ID license to be available before acting as PIC... on my ticket?? I can see it now, yes Mr/Ms student you\\'re all ready to solo but I can\\'t let you do that we\\'re waiting for your picture from the government.  Surely there is an easier, more logical way to do this. I am a flight school owner and CFII. If my colleagues and I were making $80,000 a year the $210.00 potential cost might not seem quite so bad. What about the majority of flight educators who are making 15-25 per year?   Let\\'s re-think this shall we? I\\'m all for security but not at the expense of common sense and intelligence. Thank you. I very strongly support the requirement for photograph of the pilot on the pilot certificate. I don\\'t think it will improve security at all. Photo IDs can be (and will be) forged as it is well demonstrated by the millions of illegal aliens driving on our roads despite the photo requirement on driver\\'s licenses. I support the photo on the pilot license because I worked hard for my license and I am proud of it. Having my picture on the license will make me feel good when I show my license for friends and non-pilots.   A government issue photo ID such as a state driver\\'s license or passport should be required along with the present plastic pilot\\'s license.  This is a bad, wasteful, very expensive proposal that can easily be solved with a photo driver\\'s license. A photo ID? For what? This is not a very wise thing the  FAA is doing. You recently had us do the plastic ID change and now this...we are not made of money and I strongly urge you to reconsider this change. We have a drivers license already...use it and call it good. Quit making things harder than they need to be at our expense. Another unfunded mandate for a government bureauocracy with no definable return on investment. In addition, I have 21 years of military service and innumerable security clearances within DoD and other governmental agencies and neither FAA, nor TSA, can communicate or figure out whether I constitute a threat to security of the United States. How will a picture, just like on my state drivers license, which I\\'m now required to carry as the PIC, be any better if it costs another $22 to continue doing what I have for 42 years? Absolute drivel. Why go to the expense and effort to replicate having a pictured id when all states require a picture as part of a states drivers license.  Why not revise the proposed rule\\'s language to require the pilot carry a valid pictured driver\\'s license from their state of residency.  If the concern is that foreign pilots have a picture then require those individuals to have their passports with them when flying within the US. This proposal is overdue and I am happy to see it finally happening, my only suggestion would be to use a renewal schedule identical to the US Passport. A Passport is the most valuable and widely accepted form of identification so allowing ten (10) years between renewals is certainly already been proven and would be more logical than eight (8) years between renewals. I have been a private pilot for 48 years and have never been asked to show my pilot license.  I think the current system is adequate and to require a photo on the license will do nothing to improve security.    After 46 years of being a licensed pilot no one has ever checked my license. This proposed change would be too expensive to GA pilots and pointless.  Instead I suggest you just require pilots exercising those privledges to also carry photo I.D. and present those if asked to present a pilot\\'s license by an authorized official. Most pilots would have driven a vehicle to their aircraft and would have one with them anyway. We currently are required to carry a government issued photo i.d., usually a driver’s license, in addition to our pilot’s license when we fly.  Government agencies already have the infrastructure to take photos and create secure identification cards and drivers licenses.  A driver’s license is valid for travel on commercial airliners, driving a car, and even driving a semi truck!  Driver’s licenses are an accepted form of identification for banking and for dealing with government agencies and law enforcement.  Yet for some nonsensical reason it has now been determined that a driver’s license is inadequate identification only for pilots.  And what form of identification will we present to prove who we are when we get this new photo pilots license?  Perhaps a driver’s license??!!   The FAA has no infrastructure for creating photo id’s and thus this would require a new fee for pilots as well as an additional burden on taxpayers to fund this new redundant capability.  An additional downside is that a pilots license would now expire requiring tracking of yet another expiration date (in addition to the newly expiring aircraft registrations, BFR, ICC, Medical Certificate, Pitot static transponder check etc., each of which requires a fee to renew)  At the very least I urge you to not put an expiration on a photo pilots license and just require that after 8 years one has the choice of either getting a new photo pilots license or flying with the old license and a current government issued photo i.d.   Since 9/11 general aviation has complied with many new security TFR’s and airspace restrictions.  Each new regulation and expense we impose on flying discourages new pilot starts and drives marginal pilots to quit.  I would argue that the security of the United States is far better served by a large and vibrant pilot community available to serve in times of crisis, than it is by carrying a redundant photograph.  Dear Sir/Madam,  Please don\\'t change the Private pilots License process. There is no reason to require pictures on our license, we have been doing fine by providing the Photo ID upon request.  There is no assurance the PRM will provide any better regulation and enforcement or security for our nation.  It\\'s an unnesscesary cost and a burden on pilots and the FAA system which will cost tax payers and the pilots a lot of money.  Thank you Don R. Bilbrey  I carry a photo on my drivers license. I carry a photo on my security badge at the Santa Barbara Airport. I don\\'t need to have my photo on my pilot\\'s license. Over 38 years of going from blonde to grey and 4 address changes, you would keep a federal employee busy. Please cancel the proposal for a photo ID on our pilot license. Save yourselves some money. Let me spend my money for my avgas.  Thank you for listening.  The whole process of issuing photo pilot licences should be handled in a simular way as Passports.  A required document to cross any countries border in the world. Access the documents online.  Print them out. Fill them out. Get a photo (like the passport photo) at your local drug store. Mail the completed document plus the photo to a FAA processing center. Get your completed licence in the mail.    I have been an active pilot for 30 pluss years and have never been asked to display my pilot license. To add a picture to a license no one looks at seems to be a worthless addition. It might be an assist to post a picture on the license of a commercial pilot but totally uncessary for a private pilot who flyies locally in a small airplane primarily for pleasure or limited transportation. This is only an added burden and expense that provides nothing to or for security. As previously stated by others, we have never been asked for our Pilot\\'s License for ID and we all carry a Driver\\'s License with Photo ID.  FAA has our address and could contact the Dept. of Motor Vehicles if they want to see our face.  FAA website states approximately 594,000 pilots.  The cost of this program is estimated at over $387 million.  That\\'s roughly $625 per individual pilot.  This is an absolute mis-use of taxpayer money.  We urge you to cancel this unnecessary, ineffective and wasteful proposal. I\\'ve been flying for 40 years coming up on July 2, 2012. In all this time, I\\'ve been asked to show my license only once, and it was a routine check of my A&P mechanic license... NO photo ID was even requested.   For the proposed trouble and expense being put to the aviation community, what is the expected return... one \"photo\" certificate check in the next 40 years per pilot? I ask any reasonable person, bureocrat or not, what experience or event suggests that photo IDs on pilot certificates are useful for any reason, given that some form of photo ID is already required?   The FAA should spend its efforts on safety and not respond in any way to the fear-profiteering going on in response to terrorism. Look at history and consider logical, practical means to an end, not time and money wasting rule-making that simply placates without any impact.  Please stop this nonsense and stay with the business of keeping our airways the most practical, inviting and safe place to fly on Earth.  Thank You!  Everyone is cost conscious these days, and while I do not object to photos on pilot licenses, additional fees should not be levied against the applicants due to this government mandate.  A small fee to cover postage should be all that is charged.  Also, require all FSDOs to allow walk-ins for photo applications so the applicant can avoid third party fees for applying for a photo license.  Also, I propose the photo expiration date is moved out to ten (10) years like passports.  To me, that document is at a higher authority level than a pilot\\'s license, so no more than the same standard should apply.  If ten years is good enough for the State Department, then it should be good enough for the FAA.    Whenever you think about adding/increasing fees like this, just go to a local airport and see all the small airplanes with flat tires and covered in dirt since their owners can\\'t afford to fly anymore.  Additional fees raise the cost of ownership and increase the number of these aircraft that are economically grounded.  For every aircraft taken out of service, a job is lost somewhere in our industry.  Think of how many more jobs we would have if more airplanes flew.  Thank you. This requirement is essentially the same proposed for Drivers\\' licenses, and it has the same privacy and other concerns that have led a number of States to ignore/fight that Federal requirement. This is not a passport, and we are citizens of the United States. A better solution would be to require and provide a government identification card/passport, and leave individual agencies and licensing policies alone. It would avoid duplication, avoid State/Federal regulatory infringements, and would provide cost savings.  We are seeing further erosion of individual freedom mandated by the Constitution in the name of \"protection\" from terrorism.  Unfortunately it is these very sorts of restrictions and erosion that is the desired end result of terrorism. By giving in to this sort of thing, the terrorists have already won. I think a photo license would be alright but I don\\'t think we should be charged a large fee. A fee of $22 when all other costs for aviation are rising is just more than we need at this time. Fuel prices are very high to the point that I am thinking of selling my airplane. I think the government should go after the oil companyies instead of letting them raise prices at their whim. The FAA has had 6 years to make these special licenses and now what to charge us for them after requiring us to get a new plastic license. Also where are we suppose to get the photo taken: at a passport photo service place? That would increase the cost even more. How about a personnal photo sent in? I think a fee of about $2-3 would be alright. I also think a time of 8-10 year length  would be preferable instead of the 3 years for aircraft registration. People/pilots age and the single time period photo may not resemble the older person.   Would need to re-take photos every say 5 yrs. Expensive.  Maybe the FAA medical exam should include a digital  photo taken for every medical license certificate  There is no need for a picture on a license. Why, because the current requirement to have a photo ID such as a drivers license serves the purpose. In fact it serves it better than having a photo on a pilots license because 2 forms of ID are needed to fly.   A better reason to leave the current rule alone is even simpler. In the 26 years I have been flying I have never been asked to show my credentials to anyone.   So, the only thing enhanced by a new regulation will be will be the hassle factor and expense.  Please leave well enough alone.  I’m an instrument rated private pilot and co-owner of a PA-32-300.  The idea of phasing in pilots license photos seems sensible but it’s a waste of time, money and government resources.  My 1st pilots license was paper and believe this served my fellow pilots and me perfectly for years.   Why?  NO ONE EVER LOOKS AT YOUR PILOTS LICENSE.  When a person’s identity is in question those in authority ask for your driver’s license.  Requiring a photo on your pilot’s license is redundant and does absolutely nothing to increase security. I am a retired Airline Pilot. When flying International my passport was ID enough both going and coming. In Canada, entered as a Tourist again only a passport of current ID such as a drivers license was required. I see no reason other than bureaucratic for any new form of ID. U.S. Immigration didn\\'t  ask for any more than a statement that I was an American citizen  \"Buck\" Why not just require another form of photo ID be carried along with the pilot\\'s license?  I would guess at least 99% of pilots also hold a driver\\'s license with a photo. The cost to the government and the individual to process and acquire would not be worth it when most people already have another form of photo ID. This FEE will not help anyone. It is wrong. Pilots don\\'t need this. This whole security issue is a \"FARCE\". I am a law enforcement officer with over 30 years experience and all this will do is make less people go into the avaition field.   I have been a licensed pilot for over 33 years and have obtained ATP and CFI ratings in both Airplanes and Helicopters. Also, I have owned my own plane for over 18 years. This extra purden will put me and many others I know over the edge and just quit and get out of Avaition altogether. I will sell my airplane and leave. There are many other enjoyable activities that are less expensive and burdensome than the avaition field.   The current I.D. system is fine. \" Why\" are you creating more work for yourselves. If you want to save money, stop the so-called NextGen stuff and maintain what we already have. It has worked for 50 years so far. What is the real benefit for all this ? If there are law enforcement issues then they are handled in courts of law. Not on the street because of some power hungry agency. Again, STOP THIS FEE. You will lose more people than the revenue will bring in with alot less headaches.  Jeff Aryan I\\'m writing in support of this proposal IF the photo certificates include security features for use in going through TSA security checkpoints. (so they may be used instead of a drivers license)  There does need to be an alternative for student pilots, such as a temporary non-photo certificate, so student pilots are not prevented from solo flight before they are able to obtain a photo certificate. The current system of a pilots license backed up by a state or federal id such as a drivers license is adequate security protection. There is no need to create another expensive layer of beauracracy. Pilots already pay for new certificates and we add ratings too often to justify this added charge which is in reality another tax. Personally I feel this NPRM is featherbedding in the FAA and Homeland security and is completely unwarranted. There is NO added protection for the citizens of the USA by having two photo ID\\'s over the one already required with a pilot certificate. Cost is excessive and photo id is unnecesary, as all states require photo drivers license or photo id card.  Simply stated an expensive wasteful requirement.  It is rare that a pilot is ever asked to identify himself/herself.  I think the proposed regulation to add photos to pilots license is rediculous. We are we required to have a photo ID. If the person is questionalble local authorities should be able to confirm or deny the photo ID and the pilots license match.  Please reconsider this. We have many other issues that need to be prioritized.  Many Blessings,  Randy West The photo expiration date should follow USA Passport guidelines.  The photo should be valid for at least 10 years, as is the current rule for a passport.  The proposed 8 year limit imposes an unreasonable burden on the pilot by causing the pilot to have unreasonably high financial burdens in obtaining unnecessary replacement photos on such a short schedule.  Thanks for your consideration. After several reads of the proposed rule, I find it cumbersome and  redundant.  The rules clearly require a second form of Identification such as a State Issued drivers license.  There is no need to require a photo on the Pilot\\'s license.  All this rule does is add to the bureaucracy and diffuculty in maintaining a pilot\\'s license.  This will do nothing to deter terrorism, but will cause more headaches and cost for the piloting public. The proposed fee is also arbritrary and exorbitant.  With the recent requirement to renew Aircraft Registrations and now this, the cost and bureaucracy is out of hand and unnecessary. This proposed rule to add a picture to pilots license and related cost isn\\'t good idea  there is NO NEED to have picture on the pilot license.  If you need proof of the  holder, then have them produce a government picture ID (like from a driver\\'s license  or if a foreigner, a passport!).  This is simply another step in the wrong direction by  the Feds.  Stop this nonsense!!! I believe this proposal will result in an unwarranted, unneeded bureaucratic requirement.  Most of us (aircrew) already have one or more picture ID\\'s with us.  I have a drivers license and a military ID card.  Please reconsider this expensive proposal Dear Sir,     Although I agree with the goals of keeping American skies safe from terrorism, I believe that the proposed regulation mandating the issuance of federal photo pilot license IDs is redundant and a total waste of money.  Under current regulations a pilot is required to have with him, along with his pilot\\'s license, a photo ID issued by a government agency.  I believe most pilots fulfill the requirement using their  Photo ID driver\\'s license.  I doubt the federal government would be more thorough than the State of New Jersey in the license validation process.  Hence, having a federal photo ID would just be redundant, expensive, aggravating, wasteful and add nothing to the security of the nation.  Anyone who could produce a high quality counterfeit driver\\'s license could do the same for the federal license.     Additionally, on a practical level, I cannot come up with a situation where having an ADDITIONAL photo ID would prevent terrorism.   However, I can come up with situations where more waste and aggravation could be generated on the federal government level.    Thank you,    Ed Golubiewski  I am apposed to proposed rule Photo IDs are already required to be carried by the pilot. An additional photo will not stop terrorism. Further more, there is almost no one to show the photo to. While I have only been a pilot for 5 years, I have never been asked to show my license or photo ID. After asking 7 more experienced pilots, all with more that 20 year experience and several that have been flying actively for more than 30 years; none have ever been asked to show their license. This rule will only add an additional expense, unneeded bureaucracy, and unneeded hassle to pilot renewals. But most of all – It will do nothing to prevent terrorism.  Why is it that only a few years after a plastic tamper-resistant license is required are we now being required to go to a photo tamper-resistant license?  And at the pilot\\'s expense?  What\\'s our next expense?  A biometric plastic tamper-resistant certificate?  This step is burdensome on the pilot population and totally unnecessary expense.  This mandate should be provided at no cost to the pilot, as there is no benefit to the pilot.  This license change mandate appears to be a thinly-veiled user fee, with no benefits.  Another form of taxation, without representation.  Don\\'t we have enough problems with identity theft without adding another layer of opportunity?  Thank you for dropping this mandate. You BoneHeads are coming on way too strong, way too late and looking like the Jonny Come Latelys while crying Wolf to boot.  We tried to get you to put pictures on our renewals six years ago.........no, you had to go ahead with the photos of Wilbur and Orville instead.  Now it would be nice to have our photos on the pilots cert, but why not just use our State issue driver\\'s license as is?  Much more information and local control and contact that way.    In the future for renewal purposes, or phasing in of new issues, go with the photo at a REASONABLE fee.  Like using the passport photos we can take ourselves, obtain at Wal Mart, or have AAA take for free..........and paste the pics on a new certification or license issue card before putting the plastic on?   Cheap and easy...........NO new fees and charges needed.  Sid Alpena, Mi  49707 Sir:   I am of the opinion that this requirement would do very little, if anything to enhance security.        In most cases, pictures contained bear only a minimal resemblance to the person carrying the document.  Case in point, state drivers license\\'s, passports.        In some cases, the photo is so small that use of the picture is nullified.  It just shows the general features of the individual.     There are very few times when producing the pilot\\'s license is required for inspection.  When it is required, such as aircraft rental, job application, it is produced once and then backed up with other documents such as medical certificate, passport, drivers license.  In the case of an infraction, such as would be required by an inspector, this again would be required to be backed up by other documentation.  In this case, review of FAA records etc.     The cost of the implementation of this program would be excessive for any potential benefit.   I urge you to reconsider this requirement. thank you. ANDREW J. LIPTAK  I think a photo on the pilot\\'s license is good but I suggest for the flight instructor\\'s license not to have the photo since it has to be renewed every two years but is valid only when accompanied by the Commercial certificate. The Commercial license could have the photo. The Private and Commercial licenses could  be updated say every ten years. This is a compromise and I think it is a good one. I fail to see what additional benefit this regulation will have, considering that pilots are already required to carry an additional photo ID with them when excercising the privileges of their pilot certificates.  These other photo IDs ( usually state issued driver\\'s licenses ) already carry photos and have to be updated periodically.  Requiring the pilot to renew their pilot\\'s license every 8 years adds additional expense and hassle, which is not what the aircraft industry needs at this time.  There are already too many hassles involved with flying today  that didn\\'t exist 20 years ago.  I understand that there was some response required to the terrorist attacks on this country, but is voluntarily surrendering our freedom an appropriate response? Photos on pilot certificates do nothing to advance or improve security.  Pilots are already required to carry government issued photo IDs.  Carrying our passport and/or our drivers license is no hardship.  Those documents have renewal requirements built in and the infrastructure in place to handle them.  There is no need for yet another process that will divert funds away from FAA\\'s primary purposes.    Any pilot who does not hold a valid passport or valid driver\\'s license can acquire a state issued photo ID from their DMV.    All discussions of fees and means of altering existing regulations miss the point entirely.  The notion that this can be accomplished without adding to the FAA budget, imposing costs on society, in a \"cost neutral\" way are ludicrous.  This will grow into a self perpetuation process that will cost more and more with each successive iteration.         Showing a photo identification is not a problem for me.  I always carry my driver license with me with I fly.  Since I and many other pilots I know already carry a photo id, why do we need to put our picture on our pilot license?  Driver license photos are updated when we renew our license.  Will the FAA be requiring new photos every some many years? I think that would be an unnecessary expense. The current system works very well. Adding cost and a photo to a pilot license will not make it any more valid than it currently is. The current rule is sufficient. As a pilot working for an airline under this proposed rule...I will carry a military id with photo, a Passport with photo id, drivers license with photo, company/TSA badge with photo, and now a pilot license with a photo. Do I really need five forms of ID to prove who I am. This is very redundant. It will greatly burden an already slow process and increase cost to the taxpayer. It will add great delays to new pilots applying for licenses as well as anytime the certificate gets upgraded, which happens often. Please do not require photos on pilot licenses. Thank you. I am an italian pilot holding FAA (#2307986) and italian JAA licenses. I think that the requirement to have a photo on the pilot license is not good, since there are already identity documents, e.g. passports and drivers licenses. In my opinion the passport is the best identity document and is a lot more difficult to counterfeit. Moreover, we will need to change the license every 8 years, and this will be expensive in time and money, for pilots and government that will have to employ a lot of persons for this sistem. We used to have pilot licenses with photo in Italy , and now with the JAR we got rid of them and in my opinion is a lot better sistem, without any decrease in safety and security. Sincerely Michele Cecchi The proposed Rule is unnecessessary, burdensome, expensive, and the FAA is not equipped to handle such an undertaking.  It already takes 60-90 days to receive a replacement license as it is.    An alternative solution would be to require a pilot to carry a current U.S.Passport as photo identification.    Many pilots already have a passport.  They are already bar-coded for computer verification.The mechanisms and locations are already in place to issue them.  They are already familiar to state and local law enforcement personnel, as well as international authorities which typically ask for a US Passport and Pilot\\'s License. Why the cost? I know they are pushing this photo bit, so why not utilize the existing system every state has of photo I.D.s on drivers license? Seems it would be simple to provide a basic blank card to the states licensing departments where a pilot could bring in thier current pilot license with a photo I.D. drivers license, and have thier photo put on a new card. All that equipment is already in place and should not cost the pilot any more than a photo drivers license. A simple web report to the FAA is all that would be needed.  Steve Pankonin As a private pilot I am opposed to this idea.  I believe it will only add to the cost of being a pilot without adding at all to security.  Why not just have the requirement for a vaild driver\\'s license, state ID, military ID, or passport?  Nothing is gained by requiring this, it only adds to cost! I am a pilot (Sport Pilot Certificated), and a I also recently completed 5 years of employment at the National Counter Terrorism Center as an Operations Officer on the Watch Floor.  The requirement for a Photo ID on the Pilots Certificate is over-due and insufficient as submitted.  1.  Shorten the time requirement from 3-8 years, to 12-24 months for all pilots to obtain a photo embossed pilots license.     2.  If a validated Pilots License is deemed a requirement, make it fool-proof.  Incorporate a Retina Scan verification requirement into the pilots certificate - and absolutely ensure all foreign airline transportation rated foreign carriers are required to comply.    3.  The technology for retina-scans is simple.  Soldiers in the field in Iraq, Afghanistan, and NYPD beat-cops take retina scans routinely in the course of their duties.  This isn\\'t expensive or difficult technology. I already have to pay for, spend the time to renew and carry an airport photo ID and a state drivers license with photo. Putting another photo on my pilots license is an unnecessary cost and a waste time for all parties. It could be a voluntary option for those who for some reason find it more convent than showing their pilot\\'s license and a separate photo ID to confirm identity. The present system is more than adequate. I believe that most GA pilots rarely show their licenses to anyone official. I have shown mine only once in the past 20 years other than when getting a new rating. Please just put a nice bar code on the one we have...lets be smart about our FAA license.  Do not throw good money away!  I work for a major airline, we have enough photo id\\'s for people to know who we are...we ALL carry a passport with our photo.  Here is something to work on....get all pilots to by pass TSA, our hands and our minds are the most dangerous thing on a plane.  Sincerely,  JC Baltz Unnecessary increased governmental oversight. All Pilots are required to also carry a form of photo identification. Driver\\'s license, passport state ID.  This will only increase costs for every pilot without any benefit or security improvement. It is a solution looking for a problem or an ill disguised attempt at revenue enhancement or tax without proper authorization. Seems we already proposed this 9 years ago. Every pilot already has a photo ID of some sort. Requires that be carried with the pilot\\'s license rather than spend countless dollars on updating everyone\\'s license. It is costly to do what this rule proposes and it will not add much in the long run. I feel that this idea of having a photo on your pilot lic. is not a bad idea. But How to do it. And Renew every 8 years? That sounds like a way to extract money for something that is not realy needed.  We now have to carry a Driver Lic photo ID with us, and that is renewed every 5 years. I feel that that is good enough. And this is surly not going to stop a terrorist from flying an aircraft. If you want a photo ID on a Pilot Lic. then have the FAA contact the state Lic division and optain a copy of the photo on the Driver Lic. and use  that. And if you realy feel like you need a renew, have the FAA get one every 10 years when the Driver Lic is renewed. This is my second comment on the Docket 1127 ... see Document ID: FAA-2010-1127-0163.  I have now read Congressman Mica\\'s October 19, 2010 letter (which instigated this knee jerk FAA reaction) and note that he seems preoccupied with the 2004 IRPTA Section 4022 requirement for biometric ID.  In the last sentence of paragraph one of his letter to FAA, DHS and TSA, he states, \" The intent of this provision was to ensure the license or certificate would be biometrically enabled.\"  In reviewing the docket in depth, I note that the FAA\\'s response is to now create a pilot license WITH photo ID ON the plastic ID card for every pilot.  This wiill NOT satisfy Rep. Mica !!  It will not be \"biometrically enabled.\"  Existing FAR 61.3(a)(2)(i) thru (iv) delineates that a photo ID be separately carried and describes documents that would work.  Among these is an official passport.  Recent US Passports ARE biometrically enabled.  Some of the other types of acceptible secondary documents are also enabled.  Why not just simply change FAR 61.3 (a)(2) to read that the separately held IDs MUST be biometrically enabled.    A pilot using a passport as the photo ID would not only meet the \"intent\" NOW, the photo is already in a State Dept. database which is easily callable and having a passport is a good idea, anyhow.  Also, they expire.  Why not amend the FARs such that pilots flying privately and/or recreationally under FAR Part 91 could meet the requirements by using a second ID that is biometrically enabled and pilots flying commercially under other FARs would require the higher level of scrutiny and have a photo ID pilot license?  If the FAA adopts this docket, private/recreational flyers will have still another onerous and expensive requirement laid upon them.  Lets separate pilots who fly commercially from those that fly recreationally under FAR 91.  If the addition of a photo is added to the certificates, it will NOT satisfy Rep. Mica, at al.  A passport is all we need Faking a pilots license with a photo won\\'t be much harder then one without.  At least now a Passport being used as ID is a good idea, it\\'s harder to fake a passport.  Years ago in 1987 I was told by the FAA I had to have a crew card to fly in Berlin for PanAm, I was never required to show it to anyone and never asked for it, it was a really effective system.  For that matter I have only had to show my pilots license to FAA inspectors.  The Passport office has me for a full day every 10 years while I renew my Passport.  Now that Passports are getting biometrics why create another system and another \"empire\" at the FAA.  The expense in time and money is not required, other more secure forms of ID, such as the Passport would be better and they already have the ability to verify that you are who you say you are.   This rule is more burdensome governmental regulation whose misguided purpose is to improve aviation security.  It will not accomplish it\\'s said purpose, but will increase costs and public time wasting.  Pilots, especially commercial pilots, are already required to government issued photo identification.  I have to carry a driver\\'s license, passport, company ID badge, all which have my picture on them.  I also have had to submit biometric data.  When I pass through a CASS checkpoint I have to show a SECOND photo ID even though the TSA can see that their data base photo of me is the same as the one on my Company ID.  The TSA will not recognize a FAA pilot license to passenger travel on commercial airlines.  Foreign travel requires a US passport.  The government already has access to driver\\'s license and passport ID photos.  The value of another photo ID does not justify the time and expense.  A better method would be the FAR  requirement a government issued photo ID be carried in addition to  the FAA Pilot license.  Two matching IDs is better than a non-verifiable  single photo ID. This proposal is yet another example of over-regulation, with no real solution to expeditious delivery of pilot licenses.  If pilots are required to carry photo ID in addition to the Pilot\\'s License, please explain the point of such redundancy?  Insurance companies, doctor\\'s offices, hospitals, courts of law, schools, universities, libraries, and liquor control boards all accept a photo ID - usually a State issued Driver\\'s License or Non-Driver\\'s License.  Why is this not good enough for pilots?  Just another way for the Federal Government to squeeze additional money out of pilots and lessen the freedom of its people...all in the name of keeping the public \"terrified\".    This is not necessary.  It will do nothing.  Instead, concentrate on something constructive - like bettering the infrastructure in this country.  You could realize much more revenue from improvements that would benefit future generations. I would like to suggest the FAA use the picture ID from the pilot\\'s drivers license available in digital format from the Department of Motor Vehicles database. This method would be easier and more cost effective to implement than having the local FSDO handling it. Presently the DMV driver license picture is the required picture a pilot must carry with him to exercise the privilege of flying an aircraft. The proposal for a photo every 8 years is way too short. I recommend you use at minimum the same policy at the Passport office.  10 years for adults.  I can understand for pilots under that age of 18 you may wish to make it 5 or 8 years.  At least then we would have some consistency between government departments.  I also recommend you allow various state Motor Vehicle Departments verify identity (for a fee) then this could be done when a driver\\'s license is renewed. They are trying to regulate a non-problem.  I have been a pilot for 40 years and not once has anyone asked to see my pilots license so what good would it do to have my picture on it.  I have other forms of picture ID, why is that not sufficient? I am opposed to the requirement to have a photo on the pilot’s license.  It makes no sense to set up a process that duplicates one that is already in place. The states already have procedures, equipment and personnel to create secure photo ids.  These are secure enough to allow access to commercial air travel.   As far as I know, the existing requirement for a concurrent driver’s license or state non-driver’s license has worked.   I think requiring a photo on a pilots license is not a good use of time or effort.  currently, my drivers license, passport and ID card all have a photo.  All pilots fly with atleast one of these other documents.  requiring the issuance of new pilots license with a photo, would serve little purpose other than create alot of work.  I beleive our resources could be better spent elsewhere. Don Henline I believe the proposed requirement for a photo of the pilot on his license is a needless expense and would be a costly increase in an already overly expensive endeavor.  The pilot is already required to hold a driver\\'s license with photo to be identified, and most pilots already carry a passport with photo ID.  FFDO airline pilots have a photo ID as their credential and, in Illinois, anyone owning a firearm is required to possess a firearm owner ID (FOID) card with a picture on it.  Even my Costco card has a photo on it, so I feel I am sufficiently photgraphed for ID purposes already.  Any further increase just contributes to a much more expensive expansion of governmental beauracracy, which is certainly not needed in these times of tremendous debt increasing!  Security would not be measurably increased by proceeding with this requirement. Just wanted to add my opinion, its long overdue, having a photo on a pilots  certificate, I have been a  private pilot for almost 20 years, and I think there are two major reasons for a photo, one is security obviously, but just as important, pilots are responsible for the well being and safety of their passengers, and they should be treated with at least the same degree of respect that a driver with a cdl license or even a everyday driver gets. Without a pcture id, the certificate does not hold the same creditability as an ordinairy drivers license. my vote is yes, for the photo Id In the nine years I have been flying, not once have I ever been asked for my pilot\\'s license. If the occasion were to arise and a photo ID was required, I would use my drivers license. Since my drivers license is always on my person I see no need for an additional photo on my pilot\\'s license. I consider it a waste of time and money. This is absolutily \"horse puckey\".  First they hit us with re-registering our planes every three years and charge us every time, now they want another photo ID.  You can\\'t fly as a commercial passenger without two photo ID\\'s, one of which is a driver\\'s license.  99.99% of general aviation pilots have a drivers license.  It should be more than adequeate to show your driver\\'s license (all 50 states have a picture ID now) and your pilot\\'s license as proof that you are who you say you are.  To me, this seems to be just another way for the FAA to gather $22.00 from all the pilots in the USA, no small sum when you add them all upl  Now, on to another scenerio, what if a pilot from (you pick a country) wants to rent a plane here in the USA while on vacation.  He show\\'s the FBO his driver\\'s license (with a picture) and his pilot\\'s license (without a picture).  Will the FBO turn down a chance to rent their aircraft for a few hours because \"that country\" isn\\'t following the rules that have been set up by the US of A?  I think not.  There are other ways of making money for the Federal Government coffers, why do they have to pick on pilots? 01/31/2011 15:13 2022675875 /EJil^/JOIl 3:45PM SENATOR JON KYL OFFICE OF RULEMAKING PAGE 82 Na F,-\\\\A-E-li/lail Vievmr MeseageT\"]! PBtajIs | r^achmenta )P\\'Hwdgs\\'\\'\\'li Souroa\\' Ł\"I HTML X5 -^^ 1^ on CO rrem: \"nobody@wwuir,senarfft.goi/\\' <n6bDdy®wwvir.8enBte.gDV> Date: 1/12/2011 11:49^ PM To: \\'\\\\vebm«^ky)-1q,3enata.gov\" <watima1lfikyl-lq.«enate.s0v> Cc; 3ubjec<!Stor)FMWaalB <IP>24,251.2Z.220</IP> \"-APP^SCCMAIL <nRSt>FlloharcJ</FIRST> «!LAsn>Wrtght<AJ\\\\ST> «AODR1»\\'21320 N 68th Street - Unft 2163</ADDRt> <ADDR>>^ATORZ> <CrnC>PhoBn!)t-«/CJTY> <STATE>AZ«/8TATE> \\' <z\\\\p>aeQS*t/zv» ŁcPHON&>4d0^203^8S9<PHONE> <EMAll^ick@wrlshtaviafion.net«/EMAlL> <IS9Lfe>Mr3C\\';/I3SUE> <RSP!>Y</RSP> <M8G>FAA te In Uw proceea of amending resuiatloM (0 reqiAs the addition of fi p^otograph io all US pilot cerltfioates (license). Thfs Is being done to comply with section Section 4022. of ttie \\'Inteitigencs Refoim end Terror1«rn Pravenflon Aclaf2C104\\'(|RTPA). I urge you to take steps to curti ihEs befbie tba FAA Impleineiits steps to create Ihs bureaucracy nece^asry to fmplement ihle change. Vvhy? Because Is does nothing whfitwer to maKe m safer or nxtie ceoure. Pilots (! dm one} already miist carry a goveiYiment Issued photo ID In order to exerdse the pit^eges of any pitot or Instmctor certificate, (i cany a US paeeport and and fiZ drfvai^s license). Today, a pllel cerlHIcato b issued virfth NO EXPIRATION DATE, and has been for as long ea they have been Issued. MadiMi exernlnaHons end flight reviews ore required to JnamtBtn quelltioaQons, but the ceriHtoate itself dtws not eKpina, Adding a photo win create a cfreumetance where (hat certHIcatB win, loglcaOy, have to be reissued periodically, if Cor no other reason than to update the photo - ata the pawpoif and drfver\\'a license. I can aaaily understand what U doec to add to the cost of operallon the FAA. I cannot think of a single thing it win do to Increaee eecurilir or impnve safely,. ACT NOW twfbre the bureaucracy la put h) place end the money spenl Ooni bs fooled into (hinklns this will be cost neutral. Jobs v/lll be created, processes 9nd procedures will be Iimplsinente ard the fedemj dollare that DO NOT NEED TO BE WASTED, lUW be wasted lo meeta poor^ eonoeived eecurlty action wiRi no neal, provable bene(it.</l^$d> <i!APP> ^oQ, http:/^l-iq:800/iq/view_einl.a3px7rid=^129n9ftoM=1926934 1/27/2011  KRISTIN ENTERPRISE, INC. \\' K\\'ARTMENTOF 4735 N. Lear Rd. .-INSPORWION Eloy, AZ 85131-9710 ;;::T OPERATIONS January \\'i?l^/*ioii A ih 50 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 Dear Sir? This letter Is In reference to and opposed to the new proposed rule that requires that a new pilots license have a photo I.D. on it. Ate you trying to tell us pilots that the photo I.D. on our drivers license isn\\'t good enouth to tell if we are that person that is carrying the drivers license isn\\'t good enough to recognize if that is the same person that has the drivers license in his hand. Your not concerned with the extra time and expense that will be put on all the pilot\\'s back. Its Just more and bigger govem»ent and put more money in the government\\'s hand, so that they\\'ll have more money to spend, I a« a commercial pilot with SEL and SES, MEL, flight instructor. I am retired, but still fly and do Biannual Plight Reviews, which means every two years I\\'d have to go throaght the same process, expense and time. Vfe don\\'t need this. Sincerely, Alvln D. Hamman  ',\n",
       " 'I understand that the FAA is required by federal law to implement photographs on pilot certificates.  I am therefore submitting comments on how I believe the FAA can implement this requirement as efficiently as possible.  All formal methods by which a pilot has direct or indirect electronic contact with the FAA should allow the pilot to upload a digital photo e.g. IACRA, MedXpress, Knowledge Testing Center.  Designated individuals (e.g. DPEs, AMEs, exam proctors) can verify that the photo matches the pilot\\'s face at the same time they examine the pilot\\'s identification.  This would necessitate software changes, but being able to upload a small image file via a webpage shouldn\\'t be a difficult undertaking.  The NPRM mentioned: \"At this time, the FAA is prepared to accept only a hard copy of a photo, similar to the Department of State\\'s passport model.\"  If possible I think the FAA should be able to access a pilot\\'s passport photo on file with the Department of State.  This would eliminate the need for a pilot to make an in-person visit just to provide a photo to establish identity with the FAA if the pilot has already established identity with the Department of State.  Naturally, the photo expiration date would be based on the passport photo date.  I think the valid time for a photo should be the same as those for passports (ten years) if the FAA is able to access the Department of State\\'s photo database.  Otherwise I think a 12-year period would suffice.  By way of example the valid time for a photo on an Arizona driver license is 12 years: http://www.azdot.gov/mvd/faqs/scripts/FAQsResponse.asp?Category=1&Keyword  I think having a single deadline regardless of certificate level would overwhelm the FAA with last-minute applications.  A phased approach appears to be better. As a professional aviator for the last 25 years I have only had to produce my Pilots License on a hadfull of occasions and each time I had to show the FAA inspector I also had to show my company ID.  This is an not needed in any aspect of aviation and only will add to the numerous costs associtated with being a professional or private aviator.  Do not go down this path!  I suggest finding other ways of deriving revenue. This new regulation will prove to be a great burden to individual pilots as written.  Internationally based pilots will have a great burden through this process.  The basis of this program is for security but this effort will do little to secure the US.  Pilot\\'s certificates rarely ever come into view and don\\'t warrant such a system.  Pilots, such as those for comercial air carriers, already carrier photo ID issued by their companies.  A majority of these company\\'s already participate in a data share program that includes Photo\\'s.  The FAA should expand this type of program and work to tie in Photo\\'s that are already vetted, such as Passport and Driver\\'s License photo\\'s, and utilize those directly to produce certificates with these photo\\'s.  This would minimize duplication of efforts and provide a tie between documents that would enhance security.    The real key to security is biometric data which this program does not include.  If the program included this data, and tied it in to the systems to access airport\\'s secure areas then you may begin to justify the cost.  Charging for cetificates and their consistent renewal will drive the already high cost a flying even higher.  When you include cost of the certificate, charges that a DE or Testing Center would charge with the cost of travel it becomes a burden that does not pay in safety or security dividends.  I would ask that the FAA go back to the table and take the concepts here and develop them to a more mature position and then take up this NPRM again so that it will actually accomplish what it ask without burdening the pilots with cost and no security. Although I understand the FAA\\'s mandated requirement from Congress for the issuance of a Pilot Certificate with Photo ID, I do not think the implementation has been thought through at all.  I also doubt that the FAA has started to establish the administrative organization to process the certifiates in a timely manner.  It reminds me of the total fiasco of CAMI in their attempt to streamline the process of Special Issuances.  One time it took me 9 months to get an upgrade from a Class II to a Class I physical after I had had laser surgery.  I also think that the FAA should initially take digital photographs with a date stamp on them.  Getting into a FSDO office currently takes an \"Act of Congress\" post 9/11.  Finally, the requirment for a 8 year renewal seems stupid - most State Automotible licnese are 10 year renewals. WHY 8 years? This makes about as much sense as the 1320# LSA weight requirement. Can the FAA not implement something sometine that is not an administrative nigltmare and not take 6+ months to process.  Please learn from you past mistakes! The proposed cost of the updated licenses seems too high.  We do not need any more costs in the industry if we are going to prevent further decline in general aviation.  The FAA should cosider partnering with state or county agencies that already have the technology.  Our tax dollars are already paying for the equipment to provide the images for passports and drivers licenses.  The government should act responsibly and share resources rather than add more bureauocracy and equipment at our expense both as an industry and a private taxpayer.  Thank you. Completely withdraw Docket No. FAA–2010–1127; Notice No. 2010–16], RIN 2120–AJ42  Issue new NPRM that requires one of the forms of identification listed in the withdrawn NPRM at §61.3(a)(3)(i thru vi) to be available in the cockpit.  After all, the mandated requirement is merely more security theater to make the public feel good about their elected officials. Truly effective national security is achieved behind the scenes by intelligence agencies. (And, occasionally, by mere citizens, such as flight attendants)  \"The greatest dangers to liberty lurk in insidious encroachment by men of zeal, well-meaning but without understanding.\" -- Justice Louis D. Brandeis (1856-1941) U.S. Supreme Court Justice  After carefully reviewing NPRM Docket No. FAA-2010-1127 I believe that it will cost millions of dollars without any improvement of aviation safety or security and should be dropped in its entirety.  The current 61.3(a)(2) already adequately addresses all the safety and security issues and should be retained as is.  Thank you for your consideration.    This \"proposed rule\" should never see the light of day!  It is absurd and accomplishes absolutely nothing!  It\\'s \"supposed reason\" is national security, which is simply a \"flimsy excuse and hoax\" on the American public!  It is nothing more than \"out-of-control\" bureaucracy, at its very worst!  I haven\\'t yet mentioned the egregious costs in time and expense that those in this administration seem to \"waste as they please\", so long as it is the public who pays!  If the dolts at FAA want this regulation...let FAA pay for it out of its own funding!  Oh yes...I forgot the bureaucrats at FAA have already squandered the billions they were allotted and so intend \"to tap\" the taxpayer once again!  The ineptness and slovenliness of FAA these last 16 years has not gone unnoticed by the aviation consumer and taxpayer. The Air Traffic System is a shambles that is completely ineffective and dangerous, training of new pilots is at it\\'s lowest since 1946 and now the \"mindless minions\" at FAA want to take this opportunity to \"completely kill\" what is left of the aviation industry in this country.  That is quite evidently the \"true reason\" for this rulemaking!  Well, this should do it!  The aviation industry is \"on it\\'s last legs\" in the USA, because of incompetence and inept management at the government level (DOT/FAA).  It is ridiculous rulemaking and shoddy management for one and a half decades that has brought this industry to its knees!    It is over 325 miles for me to reach the nearest FSDO and I \"can\\'t just walk in\"!  I must have an \"appointment (which is nearly impossible to get), because they hide like mice in the basement or in the woodwork, afraid to come out and represent and \"serve\" the flying public \"in the light of day\"!  There\\'s a good reason for that I suppose, as the federal government deserves nothing but rancor from the American people and it is an absurd NPRM like this one, that has made it so!    There is no reason to require pictures on our license, we have been doing fine by providing the Photo ID upon request. There is no assurance the PRM will provide any better regulation and enforcement or security for our nation. It\\'s an unnesscesary cost and a burden on pilots and the FAA system.   Pilots have enough expenses to keep flying.  For flight instructors, who must renew every two years, the cost will be significant, not to mention the hassle every two years.  The FAA is charged with promoting avaition, along with regulating it.  This proposed rule does little if anything to promote safety, and it adds another burden to our aviation industry, which is already under stress. Per current FAA regulations, my drivers license and my private pilot certificate are perfectly adequate to establish my identity and my \"right to fly.\" No one can rationally believe that this redundant and costly form of ID will have even the slightest deterrent effect on terrorism. When you add up the spiraling cost of new IDs, ADS-B equipment, new 406 ELTs, etc., general aviation pilots are experiencing financial death by a thousand regulatory cuts  Please don\\'t add to our burden by adopting an entirely unnecessary regulation. This new requirement is quite frustrating to say the least.  The aviation industry is expensive enough as it is to try and make a living, let alone having the FAA empose more unnecessary fees on pilots.  A picture on the id is quite redundant, as many people have already stated, since you are required to carry a photo id any time you fly.  And the idea that having a photo on the license will increase security makes no sense what so ever.   As a professional pilot and CFI, I find it almost insulting.  The feeling that comes from this new requirement is, \"The FAA has no confidence in our current pilots, flight schools or instructors what so ever.  We are apparently totally incompetent when it comes to keeping aviation and the public safe.\"  It feels like a slap in the face, and a very lame excuse to try to generate more income and expand.  I really hope that the FAA will see that they need to help stimulate aviation in America, rather than trying to weight it down with more paperwork and fees.  Sincerly  Eric O\\'Connor CFI,CFII,MEI The rationale and proposed cost to pilots\\'s from this rule is without any logical basis and lacks substantive benefits. The rationale used by the FAA for the costs, amounting to more than several hundred dollars for each license is absolutely ludicrous. In addition, the recurring costs for flight instructors to renew their photo-id licences will result in many choosing not to renew their CFI. The FAA should completely shelve this whole idea. The FAA shoiuld adopt the driver\\'s licence only along with the existing certificate as the means to address IRTPA. The use of an \"FAA photo-id\" will not result in any increase in aviation safety. If anything it will detract from it as it gives imposters only 1 item to try to duplicate as opposed to 50 different state IDs. This proposed rule is NOT AT ALL cost effective for either the U. S. Government, nor anyone in aviation.  All drivers licenses require a photo.  Most airports are required to issue photo IDs under TSA rules.  And most of us are required have at least one other photo ID through work etc.  This propsal would NOT increase security.  It would not benefit the pilot, the public, and I dare say it would NOT benefit FAA.  But it would cost all of us, pilots, airports, and FAA additional time effort and money for no gain.  Please do NOT adopt this proposed rule.  Thank you.  William R. Massey I wonder if it is a good choice to ask pilots to supply a photo for their new ID.  If this path is followed it will be difficult to control the image quality or age.   It makes a lot more sense for the FAA to take a picture of the pilot when preparing to issue the new certificate,  This is the way it is done for driver\\'s licenses in my state and, I suspect, all other states.  One way to get participation from pilots is to make it easy for them to do so.  Some ideas for encouraging participation: 1. Eliminate the fee. 2. Eliminate the requirement for the pilot to deliver himself to some obscure location like an FSDO. 3. Hold certificate issuing events at popular aviation gatherings such as Airventure/Oshkosh, Regional aviation events such as the annual NorthWest show at Puyallup, WA, etc.  The current plan requires a great deal of effort from pilots to make it easy for the FAA to issue the new certificates.  I believe this will be a failure.  If the FAA makes an extra effort to make it easy for pilots to get their new certificates then a lot more pilots will comply. We do not need another id. Every one has a state id, or should have.  This is another Federal expansion of power and buerocracy, create an ever increasing governmental empire and steal from us.  Perfect example of the current administration\\'s thinking.  My last \"new\" license came back with errors they still can\\'t correct but the FAA wants to expand on what they can\\'t do now. This new set of rules is purely harassment. The current system is in no way broken. The mad, heavy-handed bureaucracy is totally unwarranted and will serve no useful purpose.  As a commercial pilot, I am already harassed enough by the FAA. I am utterly opposed to all aspects of the proposed new rules. This rule does nothing to thwart terrorism nor increase security.  All this rule does is increase the cost and bureaucracy involved in being a pilot.  Current rules adequately support proper identification.  All one has to do is to validate the existion pilot\\'s license against a government/state issued license, and a positive ID can be verified.  The added expense, time and renewal only creates a revenue stream for the FAA.  The proposed $22.00 cost is arbritrary and not based on actual expenses as is the renewal time frame.  The student pilot requirements are even more rediculus.  This will only result in more disencentive to learn to fly!  It seems all the FAA is interested in doing is creating more jobs within the FAA at the public\\'s expense.  A prime example is the new Aircraft Registration policy that also provides no value added for the general public! DEPARTMENT OF TRANSPORTATION Federal Aviation Administration 14 CFR Parts 61 and 183 [Docket No. FAA–2010–1127; Notice No. 2010–16] RIN 2120–AJ42 Photo Requirements for Pilot Certificates AGENCY: Federal Aviation Administration (FAA), DOT. ACTION: Notice of proposed rulemaking (NPRM) This is bad law making, we are saddled with excessive regulation which are complicated to say the least. If this rule goes in to effect it will have increased the already high cost of private and commercial flight without improving the perceived required security requirements. Security requirements in the private pilot sector are of no security threat to the general population. We are required to have a valid photo id with us when we fly, and the added burden imposed by this legislation is absolutely not necessary, it just adds another layer of bureaucracy to a already over loaded system. End result is that it will hasten the demise of a faltering private aviation system that is presently  the best in the world.   Is it necessary that we follow other countries that have regulated private piloting out of existence? It is my opinion that having flown since the 50s and having my private and A&P, the system is not broke as is and should not require tampering with. The proposed legislation is redundant, we have other entities nosing in to the FAAs business, and for the sake of private aviation, we cannot let that happen, I have read the proposed rule making and it complicates flying and increases an already expensive sport. In closing the legislation should be trashed in its entirety   sincerely John Allen Deiter       As proposed, these changes are unworkable for student pilots.  The time period between submission and issuance is longer than it takes some students to solo, and that\\'s assuming the student has no instruction prior to submitting his or her application for a student license.  Student frequently do not apply until they are sure that flight training is something they wish to, or are able, to pursue.  A paper certificate with a government issued ID should be acceptable for 12 weeks and the certificate can be so dated.  As other persons have stated, Aviation Medical Examiners should be authorized agents for submitting photos.  First, the majority of pilots have to deal with an AME on a recurring basis.  Second, they have experience communicating with the FAA.  As to using DPEs, many DPEs do not even have an office or place of doing business.  They are essentially \"shade tree\" operators for whom performing examinations is a secondary occupation.    As for testing centers, the number and accessibility of testing centers is perhaps not as great as the FAA may suppose.  Many have closed in recent years and if student starts do not increase I\\'m afraid even more may be closed. Another layer of bureaucracy that the FAA itself says will not really make any difference for security/safety--at a cost of over 700 million dollars--all at a time when we have record deficits.  It is one more thing that makes flying for pleasure less and less pleasurable and more expensive/time consuming.  “IV. Discussion of Benefits   As noted in 49 U.S.C § 44703(g)(1) of IRTPA, the proposal would also help to ensure safety in air commerce by ensuring verifiable identification of individuals applying for airman certificates. This would also make the system more efficient in serving the needs of those enforcing laws related to combating acts of terrorism.  The proposal requires owners to personally appear before authorized persons and to include photo identification, which would help in the prevention of fraudulent and fictitious registration. The new registration requirements would allow the FAA to build and maintain an up-to-date database of pilots.” --------------------------------------------------------------------------  This appears to be nothing more than a bureaucratic “jobs program” for government employees and the “designees” assigned to the program.  Virtually all pilots involved in “air commerce” employed in the United States have had thorough background checks and have an employee photo ID, which along with their plastic pilot certificate, covers everything this NPRM is attempting to accomplish.  The excessive cost in order to “make the system more efficient in serving the needs of those enforcing laws related to combating acts of terrorism” is ridiculous, as the only time one shows a pilot certificate for cause is for a ramp check or route check by the FAA, at which time a government issued or company ID is shown at the same time.  If the FAA feels that it needs to “build and maintain an up-to-date database of pilots” now, ten years after 9/11 and just a few years after requiring the updated plastic certificates, then the theory of adding a photo to another certificate to improve safety, security, and efficiency proves that the FAA is overstaffed in the “OFFICE OF AVIATION POLICY AND PLANS OPERATIONS REGULATORY ANALYSIS BRANCH.”  This is a needless, costly proposal that needs to be discarded immediately.   In the current economy I believe the mission of the government, the FAA included, should be to be economical with rule making.  In this case the requirement could be to require airmen to hold an authorized photo ID in addition to their current laminated plastic certificate.  Law enforcement or FAA enforcement could easily compare the drivers license or passport, for example, with the name on the existing certificate to confirm identity.   All at no additional cost to the American tax payer.   It is time to cut back on bureacracy rather than add to it. As a customer service organization, you must resist the temptation to lessen the service you are commissioned to provide.  Adding pictures when not necessary, then charging an initial $50 \"fee\" is ludicrous, and opposite your mandate.  I expect more from the admiinistration in terms of support and competence.    This is yet another example of how the FAA beaurocracy has ballooned to unrealistic levels of arrogance and incompetence. Ask us what we need, don\\'t presume over us like a mother hen.   As the world rebels against government intrusions, it is the FAA who is whistling past the graveyard.   We are the flying public, and deserve the FAA that serves us. Now go and do that and stop being the FAA that has become arrogant, intrusive and ignorant of the public it is supposed to serve.   Has the FAA looked into integrating into the Department of Motor Vehicles data base for pictures or using this infastructure to accomidate this action?  Since an infastructure already exsists in most states this would impose the lowest cost for the pilots/FAA and may streamline this process especially since most pilots use the drivers license as photo ID.  The other option may the local airports that issue ID to access hangars where our aircraft are located. I would like to express my negative concern toward this proposed rule for the following reasons:  1. I had previously queried the FAA in 1981 about providing a more durable license vehicle with photo and was told it was not a major concern.  2. The FAA adamantly required acquisition of hard plastic licenses last year by regulation. Compliance was mandatory. The new licenses, though durable, did not retain any new information except removing SS numbers from the database.  3. With all of the information that I personally have on file with government agencies (i.e. passports, FBI background, Driver\\'s License, etc.), there is absolutely no need for me to include ANOTHER picture just to satisfy some bureaucrat. Nor am I likely to pay for such a service when my current aviation status has served me and the FAA well for over 30 years.  4. The mere fact that the government is to make this mandatory and charge licensed pilots for the service is a \\'shake down\\' and unethical as far as I am concerned.  5. The projected government costs for the implementation of this system, is grossly overestimated. My company uses a photo ID system with supplemental data support and it does not cost an estimated $700K to implement or maintain.   If the FAA decides to follow through with this rule, I would have it enforced for new pilots only and those obtaining new ratings and licenses. I would not force duly licensed pilots to comply with this ruling who are in good standing. This meassure if adapted should also include Aircraft Technicians with FAA Airframe and Power Plant License. Very often they travel to work on aircraft and they most at the time have an Airport Badge where they are based after full background check, fingerprints etc. Why not a 10-year interval between photo updates for the proposed new requirement on pilots\\' licenses?  The U.S. State Dept., another U.S. Government agency has such a 10-year requirement which has served it well for many years.  Surely, the U.S. Department of Transportation and the FAA can live with the same time frame. Having a 10-year interval instead of the proposed 8-year interval would reduce agency processing costs and the costs of renewal passed along to its applicants without diminishing the currency of the photo displayed on the license. Furthermore, why not use the digital photos stored by state motor vehicle departments.  The FAA already accesses these files in connection with checking for motor vehicle violations, particularly as it pertains to DUI convictions.  This capability will allow the FAA to quickly process license applications with current photos, photos which are no more than 4 years old and taken digitally by agencies which are already well equipped to obtain them.  This guarantees to the FAA that any such photos which might be submitted directly by applicants are not out of date. Regards, Jan H Smith 1878002 This adds nothing to security nor does it provide any assistance to law enforcement. 99.9% of all pilots will have several more forms of I.D. on them and the ones who do not can easily be verified by other means. More senseless regulation that is quickly strangling aviation to death. This proposed rule is nonsense; a thinly-disguised fund-raising scheme without safety or security justification. FAA would be better advised to slash its bureaucracy to lower costs rather than this ill-conceived scheme. If state driver\\'s licenses with photos aren\\'t acceptable, then provide a quick and inexpensive way to have passport photos made, submitted to FAA and a new license issued. This business of having to go to a FSDO and the other bureaucratic red tape smacks of a solution looking for a problem. Choking the life out of general aviation will not make this country stronger or more secure but rather would accomplish the exact opposite.  The proposal to require photos on pilot licenses is unnecessary, expensive, redundent and ineffectual.  A simple regulatory requirement that all pilots carry an official document with a picture, such as a driver\\'s license or a passport, would accomplish the goals of this burdensome regulatory effort.  And could be accomplished at little or no cost to pilots or their employers.  The goal of any agency ought to be to increase effectiveness while spending less, not decreasing effectiveness while spending more.  James Hartley Houston Aviation Alliance Universal Weather and Aviation AOPA United States Pilots Association     I find it ridiculous that the agency wants to add to this rule by requiring the FAA to issue its own pictured IDs.  As a pilot, I already carry a (state government issued) drivers license, an airport (county government issued) access badge, and at one time a military (federal government issued) identification.    The rule, as it stands now, states that a government issued ID is required.  Any of these three forms of ID are adequate currently.  I am sure there are other forms of ID that I am not listing.  The FAA has already issued its own form of identification in the newest pilot\\'s licenses when the new plastic cards replaced the paper ones.  To now require the FAA to reissue a new ID to every pilot flying would be unnecessary, redundant, and waste precious resources that the FAA can ill afford to lose (see the continuing resolutions to fund the FAA - 6 and counting - that Congress is using rather than fully fund the FAA budget).  In this day and age of deficits and controlling costs, adopting this rule would be foolish and irresponsible in both the fiscal and common sense arenas. To my knowledge, all states require photos on drivers\\' licenses. In New York State, the mechanism for verifying identity and obtaining these digital photos is well established and regulated. It probably is in other states as well. These photos are required to be updated every eight years. The FAA is already connected with state motor vehicle departments for driving record verifications. Wouldn\\'t it make sense for the FAA to obtain the digital photo for my pilot certificate from the NYS DMV? As a further refinement of this process, why not provide a checkbox on state driver\\'s license applications to request transmission of a pilot\\'s photo to the FAA? Docket No. FAA–2010–1127; Notice No. 2010–16  The Arizona Pilots Association wishes to take this opportunity to speak out in opposition to the proposal to mandate an I.D. photo on the pilots certificate. Presently, FAA regulations (FAR 61.3) require you to have a governmental agency photo I.D. in addition to your airman\\'s certificate in possession to operate an aircraft. This proposed action only  adds more expense and regulation when citizens are asking for a smaller, less costly, and more efficient government.  This proposal provides no additional security or value and further burdens pilots and taxpayers with unnecessary additional costs.  Respectfully submitted,  James Timm Executive Director Arizona Pilots Association  I have reviewed the proposed rulemaking identified as Docket Number FAA-2010-1127. I am disappointed at the logic and rationale used in supporting the proposed regulation because the rule: 1.\\tIncreases the bureaucracy of the FAA 2.\\tExpands the control and responsibilities of the FAA and its representatives 3.\\tAdds redundancy to governmental regulations 4.\\tIntroduces a new Federal tax on a small group in society 5.\\tDoes not make the system more efficient enforcing laws related to combating acts of terrorism. FAR 61.3 already require each pilot to possess a pilot certificate and Government issued picture identification when operating an airplane. Costs incurred for issuing and maintaining the Government issued picture identification is already paid by citizens willing to exercise the privilege of pilot in command. The rule needlessly introduces additional burden on the pilot to provide a standard picture, increases costs to handle the photo and process the certificate, and increases the paperwork for both pilot and DPE. The rule is very detailed on how it would increase a tax burden on pilots and increase the bureaucracy in the aviation community by processing and maintaining pilot records. However, it lacks analysis as to how the regulation will increase securities against acts of terrorism and lacks supporting evidence of increased efficiencies to FAA operations or the Air Traffic Control system. It presents in general terms how taxes may be used and collected, but does not specifically state how the taxes will be used or rates controlled. In summary, I believe this regulation is counter-productive to its intent and be a detriment to law-abiding citizens who desire to exercise pilot privileges. It will result in a decrease in the pilot population base, require an increase in taxes for the pilot license, and not increase our security against acts of terrorism. This regulation appears counter-productive to the purposes for which the FAA was established. Personally, I don\\'t have a real problem with having to get my picture on my licenses. What I do have a problem with, is understanding how this is going to make a anything safer. What is the real intent of this mandate? In my opinion, all this really does is inconvenience hard working americans trying to make a living in aviation. This proposal provides a false sense of security, and will have no real impact on the safety of aviation activities.  I oppose several parts of this proposal, and it can certainly be implemented better.   First, the cost.  My state charges $13 for a “secure ID”.  Even with new legislation, the FAA should not be allowed to charge more than the average State issued “secure ID” charge.  If the FAA cannot do this efficiently, the cost should not be borne by the applicant.  Second, method.  Simply allow an applicant to submit a photo (supplied by the applicant or taken by FSDO, Testing Center, etc) via ICARA or a similar system and allow “designees” to verify the photo.  Designees, again, should include ANYONE that approves a part of the pilot certificate process.  As mentioned above, AME’s providing a medical exam should know whom they are examining.  FSDO Examiners, Designated Examiners, and Testing Centers should all have verified the identity of the applicant they have examined. All of whom (and others) should be allowed to validate identity of an applicant without fee since this requires no equipment, only that the photo be uploaded for their verification.  Third, double jeopardy.  I currently hold several FAA certificates and ID.  Whatever system is employed must be able to track the most recent photo approved or validated, and not require submission of additional photos each time a certificate is renewed or replaced.  It also must be able to glean approved photos from several FAA-approved sources.  For example, Cockpit Access Security System (CASS) is already FAA approved and photos from that source should be able to be used, Current FAA ID photos since identity has obviously been verified, ICARA accepted photos, etc.  In summary, allowing several sources for a validated electronic photo should cost the FAA almost nothing, and certainly does not warrant the proposed labor and fee. I pay enough fees and taxes. I don\\'t want to be penalized any more to continue the enjoyment of flying. Submitting an updated photo is additional paperwork which is not needed. Appearing before the FAA in person will be nothing but an inconvenience due to your shortage of locations not to mention the additional cost for gasoline and lodging for traveling. AMEs and DPEs not being able to issue student pilot licenses will cause waits, travel expenses and delays in students starting their flying. DPEs are the ones who know students best and should issue flying licenses.  For \"Plastic\" certificates new Government red tape will have to be designed and started which is definitely not needed. These new costs are not necessary. The starting $22 fee is way to high and probably will jump to $50 with the new legislation. Leave things as they are. Stop these attempts at greedily squeezing more money out of us! FAA 2010-1127 should be scrapped! I oppose this Rule. It is redundant in that a photo ID is already required to be carried by pilots.  * It will be harmful to General Aviation in adding additional cost with insignificant benefit to the public.  * This will hit Flight instructors hard as they regularly update multiple certificates. One source calculated an additional $210 for an individual.  * This will impact the industry as it complicates new student pilots and raises a new barrier against entry into training.  * This will burden us pilots from remote states who are somewhat more dependent on aviation to traverse our large country, yet are forced to travel great distances to seek FAA approved outlets for mandated photos and services.  I have been a general aviation pilot for over 32 years and a professional flight instructor for over 20. I know the impact these ridiculous regulations have on my clients in the flying community. The economy has forced many to abandon their recreational flying. Ever increasing and unnecessary costs imposed on them -- such as TSA gate access screening or  aircraft registration renewals to name a few -- are sucking the joy out of the industry. This photo requirement for pilot certificates is hazardous to the general aviation piloting community.  It is busy work to insure job security for a batch of pencil-pushers who want the public to think they are accomplishing something with their lives.  It is bad! It is unnecessary! It should be scrapped. With regards to the section \"implemeting approach\" you refer to foreign based pilots visiting field offices to have photo id\\'s processed - i would like to emphasise that for example the london field office does not process licences and refers you to the NY office. this means that UK based FAA reciprical or FAA licence holders have no option other that to travel internationally to obtain or comply to this rule making..  This could make a limitation for low hours private pilots.   Requiring new plastic certificates with photo does not add safety.  If one can board a commercial flight using the photo ID on a state driver\\'s license, the driver\\'s license is deemed to be sufficient ID. If the TSA or FAA want more certainty about the identity of a pilot, they should require a separate photo ID that is acceptable for commercial flight to be carried along with the current plastic FAA certificate. Further, the use of photo ID is so rare in aviation as to make this requirement superfluous. I have flown for 40+ years and have NEVER shown a licence to other than an FAA examiner. Further, the cost and travel requirements are onerous, and will cause more GA pilots to cease flying. The FAA should recall that part of the mission is to *promote* aviation, not to discourage flying.! Lastly, this NPRM represents yet another odious, ineffective, unnecessary attempt to control citizens lives. We are all prepared to sacrifice for safety, but resist non-sensical regulation.... as the last election has shown! Why is the FAA wasting our money?  More bureaucracy will add operating cost to the FAA budget for zero benefit.  Next year the plastic photo renewal will cost pilots more money and the FAA will be begging Congress for more tax dollars to support it.  And with the 4 hour driving time to get photographed at the nearest FSDO, the cost to me will be even substantial.  We already are required to have photo ID when we present our certificate.  Stop wasting resourses and work on cutting back the bureauracracy. FAA Rule making NPRM Docket Number FAA-2010-1127: Pilot Photo Id requirement is NOT cost effective and puts a un-needed burden and expenses on all pilots. We currently carry many photo ID\\'s along with our new plastic pilots licenses, to show compliance. This new rule is not needed,  please stop this un-needed FAA rule to - increase fees and greatly hurt the  Aviation Industry.  Signed - Dale Wittman, Santa Rosa CA  U.S. Citizen FAA Pilot Certificate holders in Singapore will be unusually burdened by this requirement as for over a decade that FAA International Field Office at Changi Airport in Singapore has not had a FAA Flight Operations Inspector resulting in us having to fly to the U.S.A. at great expense for even the most mundane of certificate matters.  The FAA should allow internationally based Pilots to submit their Photo applications via the FAA designated Aviation Medical Examiners due to the lack of either FAA Operations Inspectors, FAA Designees or FAA Knowledge Testing Centers in all of south east Asia inclusive of Singapore.  Thank you for your time.  Requiring pilots to travel to a distant location to submit a hard copy photo is unreasonable, bad for the environment (additional automobile fuel consumption and emissions), and unnecessary. Why not use an existing mechanism that is nearby almost all pilots, such as local post offices where passport applications are processed or, even better, submit a photo when applying for or renewing a FAA medical certificate? This would allow the identification of the pilot to be verified against the photo by a US Postal Service employee or FAA Medical Examiner. The nearest FSDO or testing center may be several hours away by automobile for pilots outside of major cities. This would also keep the cost down and avoid adding fees for intermediaries. This proposed rule will not enhance security. It will only have the effect of creating another level of bureaucracy at the FAA at the expense of an already beleaguered sector of the industry. No return on investment. I vote NO After 100 years we now need a photo ID to go along with the photo ID we are required to carry with it. Will the photos be lifetime or have to be renewed. Who will verify the photo if a smuggler, thief or terrorist falsifies the ID. Does the FAA have the necessary budget and the extra Personnell to collect verify and store the photos? Is this a priority when money for infrastructure is wantiing?  Does the requirement have any actual beneficial aspect? Does the FAA need more to do now that the new navigational, emergency locater  and collision avoidance systems have been perfected and are up and running? Has anyone calculated the unintended consequences of a new program affecting every pilot and burdening the overworked FAA. The FAA can do Registration and Licensing (and DUI) check points and skip the more difficult planning, efficiency and safety projects.  It bewilders me that we continually resist all efforts to require a photo ID for something as universally important to our nation as Voting while we attempt to fix something that is not broken and has worked for decades.  It\\'s the FAA that is broken - fix that! It is understandable that the FAA would want pilot licenses to now be a photo ID as proposed in the current NPRM. The initial cost to pilots was figured at being about $50. While high compared to state issued driver’s licenses, this figure was somewhat acceptable. The current estimate by the FAA of the cost to photo ID to pilots is now $210. This is clearly unacceptable. This is undoubtedly due to inefficiencies in the FAA. In a time when the average citizen must make daily accommodations of doing more with less, the government needs to adopt the same practices. There is no legitimate reason for a photo ID to require that sort of expense.   The premise that enhancement of Pilot Certificates by the addition of a identifying photograph as a means to further  support efforts to contain potential terrorism do not appear to be well founded.  In more than 40 years in aviation, I have been asked on only a very few occasions to show my certificate, each time to an FAA inspector, and only when applying for an additional rating.  I believe that most pilots already have another form of government-issued photo identification, usually carried on their person, in the form of a US state driver\\'s license.  No acknowledgment is made of the existing databases and collected photographs of state agencies.  Using existing government (state) agency photographs and handling all others by exception would demonstrate a credible efficiency.  The NPRM makes no mention of new procedures to be instituted, funded, or implemented by the FAA or any other Federal, state, or local government body to check photo identifications of pilots and student pilots once photos were added to pilot certificates.  Therefore, this entire proposal appears to have no supportable and measurable means of implementation that would lead to improving anti-terrorism activities.  In addition, no person with malicious intent will take the time, or make the effort, to comply with such onerous procedures when it is much more efficient to steal or commandeer an aircraft in the furtherance of their goals.  Therefore, while I support the efforts of the FAA to participate as requested by other federal agencies in reducing potential terrorism, I believe that, as currently constituted, this proposed rule will not achieve the desired goals.  Specific comments about the NPRM itself are contained in the attached and annotated  PDF file. I object to the proposed rules concerning requirements for photos on airman certificates and urge that the proposal be abandoned because it is wholly flawed.  I support the proposal made ty the Society of Aviation and Flight Instructors (SAFE)  The current proposal provides no demonstrable security benefit to the nation, its citizens, residents nor to FAA certificated airmen.  In it\\'s present form it would fundamentally harm the process of becoming a student pilot and learning how to fly aircraft.  It is an expensive and redundant requirement for airmen excercising the privileges of flying Light Sport Aircraft because that already must possess a valid driver\\'s license, which contains a validated photograph, as part of their requirement to fly Light Sport Aircraft.  Thank you for your consideration,  Richard B. O\\'Reilly  The FAA has been steadily transforming itself from an aid to aviation into an enemy of aviation.    A while back you wanted to publish all our home addresses as if we were sex offenders or something.  Now you want to create a photo database of us?    There is no legitmate reason to force us all to put our photos on our pilots licenses.  We all carry drivers licenses or passports or both.  If you think we are terrorists, come arrest us.  If not, then why punish us all with an expensive and pointless excersize in bureaucratic authoritarianism?  I vote, \\'no\\', on the photos. Cost should be driven by the incremental cost of providing the picture.  The FAA has issued plastic license twice since the start of conversion to plastic a few years ago.  The requirements for Photos and English Language Proficiency have been in place for years, since well before the start of the first conversion to plastic.  The cost incurred because the FAA failed to comply with requirements that were already in place does not create a need for additional fees on the pilot community.    There should be no charge for a mandated upgrade to a different plastic certificate when this could and should have been incorporated in the first, and what should have been, only certificate upgrade to plastic. See attached file(s)  The FAA should establish a pilot certificate similiar the Canadian Aviation Doc. (see attachment).  The Canadian Aviation Licence resembles the Canadian and  United States Passport.  The software to produce the Canadian Aviation Licence is identical to the Canadian and United States Passport Agency\\'s.  The Canadian Aviation Licence can be read by both the United States and Canadian Customs and Immigration, to improve aviation security.  The Canadian Aviation Licence if implemented by the United States FAA would allow cross sharing of data to improve licensing between the countries in accordance with the 2006 Canada / United States Bilateral Aviation Licensing Agreement. As a pilot of 40 years experience flying recreationally under a commercial pilot certificate, I want to register my vehement opposition to the requirement to - AGAIN - change the pilot certificate requirement.  The FAA is once again acting in \\'knee jerk\\' fashion to another Governmental agency\\'s security overreaction by imposing a SIGNIFICANT monetary and time requirement upon tens of thousands of pilots needlessly.  The current system of requiring a photo ID to be simultaneously carried should be sufficient for a person to prove their identity.  Having that same photo on the plastic pilot certificate serves NO PURPOSE other than to create additional FAA beauracracy, further intrusion into my privacy and does nothing to provide additional National security.  I can think of numerous ways a terrorist could circumvent the current system AND the proposed system.  A person or group dedicated to dastardly acts will always find a way.  This proposition will not add any security to an already onerous and burdenson system.  It is about time that the FAA understands that it is systematically destroying aviation in this Country one razorblade cut at a time.  This proposition should be dropped immediately in favor of the system currently in place.    Government beaureaucrats need to be stopped!  If this requirement is SO important, let the Congress vote on it and THEN ... let the FAA pay for it in much the same way as they did for the current plastic certificates which only recently came into being.  If the FAA won\\'t pay, then drop the requirement ... simple as that.  If I had a photo ID pilot certicate on my person ... who exactly will be looking at it when I open my hangar door and pull my general aviation airplane out to go fly on a nice day ... answer ... NO ONE !!!  It won\\'t make one IOTA of difference.  It won\\'t make any difference to a terrorist, either!!  I want the name (sic) of the FAA employee(s) who thought this ridiculous idea up.      Carefully reading the RPRM I have been unable to identify any reasonable nor logical justification or benefit for this requirement other than \"Congress said so\".   As noted in the FAA\\'s own analysis of this Congressional mandate, it will incur additional costs passed along to the individual pilot. People with FAA certificates are already required to carry photo id. Requiring the photo to be embedded into the certificate will not produce beneficial results to national security.  Anticipated additional cost to both the individual and the FAA  in expense and time (6-8 week from initial application to delivery to the individual) is unreasonable and unacceptable.  This is one more knee-jerk reaction from Congressional members and/or staffers who have not taken time to identify nor understand other Federally mandated identification rules.   Tell me how putting a photo on an FAA certificate when the individual most likely at least one other, possible 2 or more State and/or Federal forms of photo identification, will contribute the National Security.  Convince me to change my opinion. Claiming \"Classified, Need to Know\" is an excuse, not an answer. First, I would like to express my concern for the way this proposed rule was put together.  Because a member of congress made a lot of noise, the FAA jumped quickly and developed a proposed rule that was not well thought out.  I believe this proposed rule needs some time to be more refined before it is implemented.  Take it back, form a committee of pilots, FAA people, aviation business leaders, flight instructors, etc., etc. to refine it and make it less onerous and more workable for everybody. Here are some suggestions to look at.  1.  To require that pilots either go to a FSDO, a Designated Pilot Examiner or a testing facility to submit a photo puts an undue burden on pilots in rural areas.  We will have to travel distances and incur extra expenses to be able to comply with this provision of the proposed rule.  Why not allow pilots to go to a local Notary Public to have the photo verified before sending it in to the FAA.  This would save time and expense.  2.  As a flight instructor, it will be particularly burdensome for me and my students to have to wait approximately 7 to 8 weeks for the student to receive his/her Student pilot Certificate before solo.  Students should be allowed to solo with their interim Student Pilot Certificate which would be issued by a FSDO or a Designated Pilot Examiner.  This would allow flight training to progress on a regular time line without an unnecessary break in the training schedule.  3.  There is no understandable reason for having to submit a new photograph every 8 years other than that is the way it\\'s done by the Real ID Act.  I realize the need to update photographs (we all change), but if 10 years is good enough for the State Department, it should be good enough for the FAA.  Let\\'s make it 10 years and releive some of the burden.  4.  There ought to be some provisions to allow for uploading digital photos to make it less of a burden on pilots. This requirement would merely add an additional layer of bureaucracy to an already overwhelmed agency WITHOUT increasing the level of safety or security whatsoever to the FAA licensing process.  FAA licenses could simply contain the phrase \"Valid Government issued photo ID required to accompany this document when exercising the privileges therof\".     This new requirement will make FAA inspectors into identity fraud investigators, which will keep their eye off their primary job of aviation safety.  This reminds me of taking a train through Europe in the 70\\'s and having the customs inspectors checking passports like so many inspector Cleauseau\\'s every half hour as the train crosses into and out of another country.  When airmen fill out Medical Certificate information, the FAA links into the National Driver Database to search for any unreported DUI\\'s.   SURPRISE...This database also has PICTURES.   Just link to it.  Does no one at the FAA have the capability of thinking OUTSIDE of the box?  This legislation is the classic fix to a truly nonexistent problem; unless one is in favor of hiring more FAA paper pushers who operate under the false guise of having enhanced safety and security.    It appears to me that the FAA is trying to kill general aviation.  These changes will increase the cost for flight instructors, make a student wait 6+ weeks, and make the process very inconvenient.  What happened to \"paper\" certificate for a student that you got from your medical examiner? Remember those?  How does this reduce the burden on the certificate holder as the proposal states?   It is quite clear to me that the FAA, US Government, the TSA or all of the above want the process so arduous that no one will want to participate...  Make the law abiding citizen that is interested in aviation pay the price for the Governments inability to secure its own borders...   Aircraft re-registration, Photo Certificates, Fees, waiting periods for students..  what will the \"Free Society\" require of general aviation next !  I am one discouraged, and upset student pilot.... America and Freedom will soon no longer be synonymous.. JcmBTMENTOF —,,,, :\\\\; ASPORTATION ^^^^^^ Ł.::T OPERATIONS Docket Operations M-30 ?CH JAN II A S: 43 US Dept. of Transportation 1200 New Jersey Avenue, SW Room W12-140, West Building Ground Floor Washington, DC 20590 RE: Docket FAA-2010-1127, Notice #2010-16 I have reviewed the above NPRM which the FAA states is required to bring it into compliance with section 4022 of the Intelligence Reform and Terrorism Prevention Act and offer the following comments. The FAA is correct that the referenced act requires it to issue airman certificates which include photos (sub section 2). However, the actions proposed for compliance are not cost effective, are impractical, offer no improvement in national security, and are beyond the capability of the FAA to implement. Over the past five years the FAA has made several attempts to issue photo identification to its volunteer safety counselors known as FAAST Representatives. This group comprises only a few thousand airmen at most and represents individuals personally known to, and vetted by FAA staff, and who voluntarily submitted digital photographs, meeting the standard proposed in this NPRM, in a timely fashion to the FAA. The FAA announced in 2010 that it was overwhelmed by the volume and had no way to generate such IDs; a non-photo ID was subsequently issued at very little cost. Even after this failure the FAA now proposes to initially process over 830,000 airman photo ID certificates initially and over four million (a very low estimate unless the aviation industry essentially disappears) in the next 20 years. The FAA provides no evidence to support such a capability and its recent history shows that it will be incapable without a massive increase in agency staffing and budget. Since current general fund and political realities preclude this the FAA will be left with one of two options, either increase the airman certificate \"fees\" far beyond what is suggested in the NPRM or significantly delay certificates to large numbers of airmen effectively grounding them and causing serious damage to this sector of the economy. The rulemaking must be deferred until the FAA can show a believable and cost effective capability of implementing the proposals. The FAA is dishonest in its fiscal impact analysis stating that the final rule would have \"no significant economic impact on a substantial number of small entities\" and therefore a regulatory flexibility determination is not required. Only the Federal Government could conclude that an action affecting its citizens approximately four million times, requiring over 7.5 million hours of private sector time, and costing in excess of $718 million dollars is of \"no significant impact\". The FAA also makes it clear that it intends to continue to increase the fees over time, using 49USC45302(c), to unspecified levels making the costs of the final rule far in excess of the presented analysis and provides no evidence that the proposed fee level(s) will be directly tied to actual direct agency costs of administering the proposals in this NPRM. Most of the aviation sector operates on an extremely slim margin and the analysis further fails to account for the recurring lost time/revenue operators will incur while trying to comply with this proposal, creating additional adverse economic impacts to this industry. The FAA and industry has shown in other studies that for every few dollars of increased operating costs within the air commerce sector there are real operating reductions, with adverse impacts upon support sectors as well, yet the FAA analysis ignores this. A Regulatory Flexibility Determination Analysis is required of the FAA for the proposed rulemaking. The FAA claim that the rulemaking will aid in preventing terrorism and in ensuring safety in air commerce is unsubstantiated. First, the vast majority of the pilots targeted by the proposal are student, sport, recreational or private pilots with no direct involvement in air commerce. Further, there is no historical evidence that this group has, or could, create a credible security threat with the means at their disposal. While it can be hypothesized that commercial or ATP certificate holders, having access to larger machines and more of the air commerce system, could represent a potential threat this has never been realized and remains a bureaucratic hypothesis. However, if the FAA wishes to rely upon this false security claim then the rulemaking must be amended to target only holders of commercial and ATP certificates. The FAA claims that there will be no hindrance to a pilot who upgrades a certificate since temporary paper certificates would still be issued. However this would still have to be accompanied by the \"underlying pilot certificate with photo\". This effectively grounds the successful candidate pilot since the underlymg certificate must be forwarded to the FAA for processing along with the candidate\\'s Form 8710; the FAA admits this process would require at least 6-8 weeks. Since the pilot would no longer have a photo certificate in his possession the FAA states that he would not be able to exercise his pilot privilege(s). Coupled with the FAA\\'s already proven inability to issue a photo ID there is no telling how long a pilot would be groimded and how adverse the economic impacts will be to the pilot and/or his business. The FAA must revise this proposal to allow the use of the paper temporary certificate, with full flight privileges, while awaiting FAA issuance of the permanent plastic photo ID certificate. The FAA concludes that airmen applications for the new photo certificates would be evenly spread over the 5 year implementation period thereby reducing the FAA needs for additional finding and staffing. This defies common sense. Few, if any certificate holders will voluntarily submit to the initial and recurring fees, inconvenience, and potential temporary loss of flight privileges sooner than is absolutely necessary, meaning the FAA will be inundated with applications as the conversion deadline approaches and will clearly use this as an excuse to seek greater funding and staffing, while at the same time temporarily denying flight privileges to an growing number of airmen who represent absolutely no threat to national security. Since the FAA will need to show an unmet workload to defend additional staffing and budget requests they will be clearly induced to slow the process even further leaving an undetermined number of airmen grounded for a significant period of time waiting certificate processing. The implementation period must be deferred imtil the FAA can show reasonable capability of issuing the new certificates and reasonable procedures are in place to prevent grounding of airmen during the process. The FAA provides no evidence to support the proposed expiration of all airman certificates. The FAA attempts to hide this by claiming the certificates do not expire, just the photo. Since the end result is still a total loss of flight privileges it is a certificate expiration regardless of the FAA\\'s wordsmithing. The attempted correlation to state driver licenses is not valid since states have a renewal requirement primarily to ensure drives can still pass a vision test and safely operate vehicles on the highway. The FAA already achieves this purpose with existing medical standards and fiight reviews; it is not to provide the state with a new photo of the driver. The attempted correlation to passports is also not valid since the primary purpose of the State Department is to ensure only authorized persons enter and leave the country and State reviews/renews this status for political reasons, not bio metric reasons. The FAA admits that it has not been directed to establish expiration dates for airmen certificates and fails to show, even anecdotally, that certificate expiration and renewal, on any time scale, will in any way enhance air commerce security or safety. History shows that non-expiring airmen certificates, the norm in this country for many decades, have never contributed in any way to security or air safety issues. This proposal represents a major change in the long standing successful airman certification process with huge unfunded costs to both the government and the private sector for absolutely no return. This proposal must be deleted. The FAA proposes to require student pilots to obtain a photo based certificate prior to solo flight. The FAA calculates this will take a minimum of 6-8 weeks and its own history shows this will be far longer thereby delaying the critical solo phase of flight training. FAA statistics show roughly 80% of all students drop out of flight training before earning a pilot certificate which is causing current and projected pilot shortages in air commerce. The FAA offers no evidence that student pilots, the most highly investigated and supervised segment of the industry, will present a credible security threat without this proposal. Student pilot candidates can currently obtain a combined medical certificate and student pilot certificate from an authorized aviation medical examiner thereby reducing the bureaucratic workload, cost, and time for both the candidate and the FAA. The FAA proposes to separate this process and require candidates to apply directly to the Airman Certification Branch for their student certificate thereby significantly increasing time delay and cost to the candidate and increasing processing and staffing costs to the FAA for no demonstrated benefit. The FAA\\'s cost analysis fiirther fails to account for the student\\'s additional costs associated with converting the student pilot certificate to a rated pilot certificate just a few months after having paid what will likely total several hundred dollars for the student certificate. The FAA offers no analysis of the adverse impacts these additional impediments will have upon completion rate for the remaining 20% but common sense indicates it will be negative and the industry cannot afford this. The FAA proposes to delete the requirement for endorsements on the back of the existing paper student certificate and require all applicable endorsements be placed in the student log book. This is a logical simplification of the current requirements and should be implemented but the rest of this } r proposal is not cost effective, exceeds the FAA\\'s capability to implement, offers no improvement to national security, wdll reduce the number of students completing flight training, and must be deleted. The FAA\\'s cost analysis is structured around the proposed arbitrary 8 year renewal period but fails to account for the existing requirement for certified flight instructors to renew their certificates every two years. Using the FAA\\'s number of 93,000 flight instructors who would not only have to renew their commercial or ATP certificates but they would also have to renew the instructor certificate four times during each 8 year period resulting in an additional 930,000 certificate actions over the 20 year analysis period which would have to be managed by the FAA along with significant additional monetary and time costs to flight instructors, flight schools, and ultimately the students who must bear the costs of overhead. The FAA does not appear to have included these, and the consequences, in its analysis and must be required to do so. With the minor exception regarding student pilot endorsements the proposals in this NPRM are not supported by factual evidence and will not contribute to any increased national security. On the other hand, the proposals do have profound adverse economic impacts upon an already struggling portion of our economy and represent an obvious attempt by the FAA to use the IRTPA mandate to increase its staffing and budget by absorbing unnecessary additional workloads while providing no additional value to the public or to air commerce. It also reflects the long standing desire of the FAA to bypass Congressional appropriations and to generate operational funds through an escalating fee revenue program not subject to further Congressional scrutiny. Congress has consistently rejected such FAA overtures. The FAA seems to have lost sight of the fact that it is an economic enhancement agency in support of air commerce; it is not a national security agency nor a revenue generation agency. The current system of non-expiring certificates accompanied by a government issued photo ID works well, achieves the goal of IRTPA, and does not require massive additional Federal and private sector spending. The proposals contained herein must be rejected and I suggest the FAA report to the Congress that the intent of the photo ID requirement in section 4022 is already being met and with a recommendation that Congress amend the language of subsection (2) to reflect this. Clifford F. Chetwin Vice President Kestrel Air  UNITED STATES PILOTS ASSOCIATION 1652 Indian Point Road www.usp.iots.orq -ŁŁ a\\\\NSPORTATIOM Docket Operations -. ;vr;y QpcDAjjOMS M-30 Dept of Transportation r-r.-i rca 90 D n- o 1 1200 New Jersey Ave SE i\\'-M 1 LD ^ d , ^- ^ 1 Room W12-140 West Building, Ground Floor Washington, DC 20590-0001 13 February 2011 Re: NOPR Docket # FAA-2010-1127 (Proposal to require photo ID Pilot Certificates) The US Pilots Association is opposed to this proposal to redo all of the pilot certificates to now include a photo on them. . There are two main reasons we oppose this NOPR. First is the cost. The FAA just last year made it mandatory for all pilots_to pay for and havejh^ new FAA issued plastic,Jamper-f^roof, pilot certificate ID\\'card. Just^few months^laterTtheFAA decidied to discard all of the years and moliey spent ^ mandating this new card. Now the FAA wants to require every pilot to spend a lot more money creating another new card with a photo on it. The FAA is constantly crying poor and yet it wants to waste even more money, time, and untold personnel hours redoing this entire scenario. What is wrong with the current regulation requiring all pilots to also have a government issued photo ID along with the new plastic pilot certificate ID card? After all, the FAA proposal adds absolutely nothing to any security that the current requirement of using another photo ID (such as a state driver\\'s license) does. This proposal makes no sense at all. Additionally, it must be done again, every eight ygars, adding more senseless costs to an idea that is not needed.\\' The\\'FAA will require all pilots to go-to the.FAA to process this new.photo ID. \\\\For many pilots.the nearest FAAFSDO is not around the corner, or even in the next tovi/n. Many pilots are not within hundreds of miles of the FAA. And the FAA is not even taking the photo to verify the photo is of the certificate holder. In these days of lean fiscal times and a poor economy our government has created another idea to waste more money and impose another financial burden on pilots for a scheme that is not warranted. The second reason for opposing this NOPR is a lack of justification for why a photo ID pilot certificate is needed. The only reason cited for this proposal is some unknown terrorist threat purported by another obscure federal agency. It is thus assumed that unti[ we pibts have ari^FAA certificate with a \"pPToto on it, we are deemed US security threats and possible terrorists. This borders oh the absurd. Has anyone in the FAA ever asked why this proposal is necessary? Consider the fact that the FAA is not taking the photo of the pilot but requiring the pilot to furnish it. Therefore, the FAA has no proof that the photo that will end up on the ID card is actually of the pilot. When was the last time someone in the FAA asked to see your pilot certificate, other than when obtaining a higher certificate or rating? In 35 years of flying over 6700 hours I have never been stopped by the FAA and asked to see my pilot certificate. What is the purpose of this exercise in futility? Is the FAA going to run a criminal background check on every pilot submitting a photo? Is Homeland Security going to investigate every pilot applying for thephoto ID?: If.the pilot applying for the photo ID is not being vetted; then - <:\" how. doesa photograph now render this-pilpt no longer a national, security .threat? Ł The USPA and its members do not view this proposal as a worthwhile venture. It does absolutely nothing to provide additional national security and the cost far exceeds any benefit anyone would ever receive. For example, the US military issues photo ID cards to all retired veterans. This ID card allows retirees to enter most military posts and there is no requirement for this ID to be renewed. My US Army retiree ID card only expires when I do. Many pilots have other fonns of government ID cards in which the card was received, only after the holder underwent a thorough background investigation. So why are these ID cards no longer valid by the FAA\\'s reasoning? Because the FAA does not intend to do any type of background investigation to go with the photo ID requirement why waste the time, money, and effort just going through another govemmental \"feel good\" exercise. If our government deems that national security would be greatly enhanced if all pilot certificates had the pilot\\'s photo on it why not set up a viable plan, which would accomplish this over time. I am not writing about the current convoluted proposed plan, which few can really understand, but a reasonable concept. Set up a procedure where a student pilot applies for a student certificate in which the applicant has his/her photo taken by the FAA or flight school or the local police department and then a background check is completed on the pilot applicant. When the student becomes a pilot, then the pennanent photo ID card is issued. The FAA*on\"31\\'March last year ma\\'ndated\"eveFy pilot\"have^the \"riew\"\\'jc»ilof^eftificate and to also carry any other government issued photo ID card. Why is this concept now being seen as no longer valid? Is the FAA going to get halfway through this new photo ID proposal and then scrap it because someone decides it is no longer a good idea? How much time and money will be wasted on this new idea before someone decides it does nothing for national security and then the FAA must come up with something else. After all, it took the FAA less than seven months to want to scrap a pilot certificate ID that made sense and replace it with a very complicated and very expensive proposal that makes no sense for increasing national security. USPA recommends that the FAA drop this proposal and approach it from a practical and realistic point of view. And perhaps reconsider the fact that what we now have in place makes perfect sense, and in no way violates any part of national security. Dr Bob Worthington President, United States Pilots Association  Richard W. Murray 15806 Sorawater Drive ,, Lithla. FL 33547 \":\\'\"AR i MEN I OF \\' :.\\'f>PORWION Ł i\\'^v OPERATIONS Łon FEB -I a 3: 53 January 25,2011 Docket Operations, M-30 Department of Transportation 1200 New Jersey Avenue Room W12-140, West Building, Ground Floor Washington, DC 20590-0001 RE: Docket Ntmiber FAA-2010-1127, Photo Requirement for Pilot Certificates Dear Colleagues; RE: Additional Designees To avoki unnecessary costs, travel expenses, and time delays as well as more effectively utilizing FAA emptoyees and actually enhancing security and effectiveness, the proposed regulation shoukJ primarily use an existmg system for obtaining in-fterson klentity verifKatkMi. Specificalty, the process shoukJ primarily utifize the designees currently authorized to accept and process US Passport applications. The requirements are klentk^l: The indivklual must appear in person before the designee (usually a specially trained US Postal employee) vMth the appropriate documents and a suitable photo. That employee then completes the paperwort( and mails it to the appropriate government agency for subsequent processing. There are literally thousands of local post offices where citizens can apply for a passport - often without even an appointment. And many of these post offices will even take a suitatile \\'passport quaii^\\' photo on the spot for a reasonable fee. In many instances, these can be digital photos. These authorized employees are already trained to identify the documentation needed to prove residence, date of birth, citizenship, verify passports, identify enhanced Driver\\'s Licenses, etc. FAA employees and the suggested designees are not generally proficient in these areas and the additional training needed to accurately fulfiH this new mandate would necessarily distract from the FAA\\'s primary mission. I would suggest a system whereby a pikit applicant woukj obtain the necessary FAA application for a Photo Pilot Certificate t>y downk>ading it off the web; requesting a paper copy t)y mail or (Mcking one up at his/her local FBO. Then he/she wouM take the completed applic^on along with his/her current pik>t certificate and a suitable \\'passport* photo to any designees (post offk;e) that processes passport api^ications. The authorized designee simply: accepts the FAA application; verifies that the applk^nt and photo match; verifies the current Pilot Certificate number in the apipl\\'icant\\'s possession matches the appltoation; photocofMes the applk:ant\\'s Passport; Driver\\'s License or other form of current klentificatmn; collects the required fee; and packages everything up and mails it to the FAA processing center. No need to travel to a distant FSDO; no need to divert a significant number of FAA employees from ther current tasks. RE: Specific Identity Verification Standards The following should be accepted as sufficient identity verification: A valid US Passport or a cunnent photo Driver\\'s License complying with the Federal Real ID Act. Sincerely Richard W. Mun\\'ay  One Pilot™s Comments on Notice of Proposed Rulemaki ng FAA-2010-1127  February 3, 2011     I understand that the FAA is mandated to include ph otographs on pilot licenses under the terms  of the Intelligence Reform and Terrorism Prevention  Act of 2004 ((IRTPA), P.L. 108-458.   Adding a photograph to certificates provides no add itional protection to the American public  over the current requirement to possess a governmen t-issued photo identification while  exercising the privileges of an airman certificate.   This effort is window dressing for public  perception, since it will put a photograph on a cer tificate that is never asked for.    The photo process proposed by FAA-2010-1127 does no t reduce burdens on the certificate  holder.  Instead, this program is projected to cost  the FAA over $700 million over twenty years.   This amount does not lead to increased security, wh ile the fees will be passed on to certificate  holders and burden the FAA with the burden of becom ing another government agency that  produces photo identification cards.     In over 30 years of flying, I have never seen any c ertificate holder be asked to show their  certificate for ID purposes, and I only know of suc h incidents by third-hand stories.  The only  time most certificate holders show any authority th eir FAA certificate is during their upgrade to a  new rating/license, before beginning the practical  test.  Showing another government issued  photo ID works fine in those situations.     If the FAA continues to pursue issuing photos on al l its certificates, I recommend it adopt  paperless submission, including digital images, thr ough its website, and align photo expiration  periods with the Department of State™s ten year per iod for passports.  The FAA should allow  certificate applicants to upload their photo throug h IACRA, with an instructor verifying it for  their student, and an FAA designated pilot examiner  or FAA Inspector verifying the submission  for other applicants.  The FAA should fund all phot o certificates through the existing and  adequate funding for the FAA from aviation fuel tax es.  The FAA should continue to issue  instructor certificates without charge, as they are  only valid for flying when used in conjunction  with a pilot certificate.  Student pilot applicants  should be allowed to upload their photo via  IACRA and print their own temporary certificate.  T he FAA should investigate how to issue any  future certificates that will comply with TSA secur ity directive 1542-04-08G in the same manner  that seaport facilities use the Transportation Work er Identity Credential, learning the lessons  from the maritime community.     I recommend the proposed rulemaking be discontinued .  The proposed rule offers no increase in  security, adds cost of adding to the FAA, the aviat ion community and certificate holders, and  does not plan for including biometric data for the  future.   Therefore, the FAA should discontinue  this proposed rule and investigate options that wil l allow for its second overhaul of airmen  certificates to be accomplished correctly, while en compassing future requirements.    Sincerely,     Alan Bridges   ATP-Airplane and CFII-Helicopter   ^ , 512-863-8323 P^ Nov 19 10 10:13a Bill and Karen Hoglan \\'ŁEmRTMENTOF SiANSPORWION ;:KET OPERATIONS r. — .r^ V \\'?-? f\\'^^\\'\\' ?^ A l|: ib Docket Operations FAA Photo ID FAA-2010-1127 The proposed legislation for a Pilot to have a photo ID Pilot\\'s License is redundant. There is probably not a pilot in the USA that does not have at least: Drivers license; Concealed Carry ID; Retired ID; Pass Port; Line Badge from the Airline they work from or a Line Badge from the Airport they are operating from! All with photos! This requirement will be another burden placed on hundreds of thousands of Pilots and businesses in order to meet the requirement. There will be a monetary cost. There will be difficulty in traveling to a location to accomplish the task. The location will probably place another charge on top of the FAA charge. In 45 years as a General Aviation Pilot I have never had to show my license to anyone other than a rental company, FAA Examiner or Testing Facility. I think this new requirement is just a waste of time , resources and money. It is probably designed by a \"desk jockey\" that is not an aviator. Personal Opinion: Photo ID License is not needed. \"The FAA is the largest group of non-aviation oriented individuals in the world controlling and regulating aviation\". Bill Hoglan Pilot and Aircraft Owner Retired USAF/FAA 183 Valleyview Rd. Georgetown, Tx 78633. 11/19/2010 1^  \\'Ł^\\'PARTMENTOF Kevin P. Hynes iANSPORWION Ł -.AlT OPERATIONS Docket Operations, M-30, U.S.D.O.T. 1200 New Jersey Ave SE,WstBldgGTnd Fir, RmW12-140 -J^M r.c^ . | r:^ 3: 53 Washington, D.C. 20590-0001 January 26, 2011 Ref: Comments on FAA\\'s Photo Requirements for Pilot Certificates: For the Record, Document ID: FAA-2010-1127 The FAA best expresses within their own proposal the proper frugal and wise attitude toward redundjuicies in proposed FAA photo ID process: \"In the interest of reducing burdens on the certificate holder and government, the FAA will continue to...reduce potential redundancies or duplication in Federal certification, vetting, and credentialing process.\" Per the FAA, state issued drivers license or other forms of photo ID found in FAR 61.3 are acceptable to the FAA and all local, state, and federal law enforcement agencies, including the Department of Homeland Security\\'s TSA. Same are stated by the FAA as being acceptable for the validation of identity for any issuance of the proposed photo ID. The FAA clearly sums up the redundancy of their own proposal in stating \"The FAA has determined two photo identifications are unnecessary and do not serve a safety or security interest\" (Page 70872, Column\\'s 1 & 2, Last Pgrph\\'s for each, respectively) Per the NPRM, \"the agency is soliciting comments to\" (Page 70876, first column, bottom of page) cover four (4) areas of concern. These four areas, along with comments to each follow: \"1) Evaluate whether the proposed information requirement is necessary for the proper performance of the junctions of the agency, including whether the information -will have practical utility:\" The requirement is not necessjuy for AND counter to the proper performance of the flmctions of the agency AND doesn\\'t provide any practical utility beyond that in place. a) In simplest terms, tiiere has never been an accident in which the identity or valid ID of a pilot has caused or contributed to an accident or injury to anyone. b) The FAA\\'s analysis has NO examples of increased safety for anyone involved in air commerce if the FAA requires pilot certificates to have an FAA issued photo ID, c) The proposal would NOT stop an unidentified pilot fi-om flying if they are truly intent on the same, whether it involves possible terrorist motives or not. d) No improved safety aspect of air commerce mandated by Subtitle...44703(b)(1)(c) is afforded by the FAA having to establish, implement, and then monitor all the proposed requirements of issuing a photo ID on all pilot certificates. e) If safety could be improved by an FAA issued photo ID, then why not demand the same for anyone involved in air commerce (mechanics, ATC personnel, airport workers, or even all passengers, etc.) rather than just pilots? f) The proposal is counter productive to the FAA\\'s own safety mandate. The implementation of this requirement will reduce the FAA\\'s ability to perform functions the agency currently undertakes to monitor & audit safety in air commerce as mandated by law. g) As outlined the FAA will have to commit additional resources to this program AND would not be able to recoup the additional costs to do the same with the proposed fees. This means that a certain percentage of current and fiiture FAA funding spent on safety in air commerce would need to be reallocated to the photo ID task proposed. What current area of safety activities & audits will be cut or ignored in fevor of the requirement to place photo ID\\'s on all pilot\\'s licenses? h) The proposal for FAA issued photo ID\\'s does provide any practical utility beyond that in place. \"2j Evaluate the accuracy of the agency\\'s estimate of the burden:\" The accuracy of the estimated costs to the agency and all pilots involved is suspect and could have a greater economic impact on a significant number of entities. a) Proposed cost of $387,460,624 to process 4.4 million photo ID\\'s over the life of the analysis means the average cost is expected to be $88 per event, FOUR times the currently proposed fee. This imflmded mandate must be absorbed by the agency\\'s current & future fimding levels OR passed onto the users of the system. FAA would need to raise the fee beyond $22 - even well beyond a proposed $50 fee pending in FAA re-authori2ation legislation - to achieve adequate fimding levels to cover FAA costs. b) The impact is significant on the 740,442 individuals who must comply with the proposal. It is estimated that only a Vi day will be required to gather & submit the required information for processing. The FAA likens the process to that of applying for a passport, whose current cost in fees by the government is over $65. As anyone who has applied for a passport with the US Department of State can attest, it is easily one day\\'s activity to obtain the proper photo, fill out the paperwork, and present the same to a designated representative for issuance (who ironically accepts a state issued drivers license as a valid form of photo ID). c) Stated cost to pilot\\'s being $445,800,000, divided by 740,442 pilots, results in an average cost over the period being $602 per pilot, NOT the FAA\\'s stated \"cost of about $375\" (page 70877, third colunm, 4th pgrph). d) The cost estimate to oversee and audit the accuracy of the various portals to be used by pilot\\'s, inside & outside the FAA FSDO\\'s, is suspect. Using FAA information, 960 Knowledge Testing Centers (KTC\\'s) with the FAA spending 32,752.4 man-hrs/yr equates to 34 man-hrs/yr per KTC. With 2700 Designated Pilot Examiners (DPE\\'s), the FAA spends only 4.3 man-hrs/yr to verify the accuracy of each DPE\\'s worit. No separate cost to internally audit the 96 FSDO\\'s is presented. Why not? Why such a large discrepancy in the time required to audit the data presented to/by KTC\\'s & DPE\\'s for issuance of photo ID\\'s? e) FAA does not address need & cost to validate proposed system of obtaining photo ID\\'s. How will the FAA know the date of any photo presented for use? Such a mandate for FAA photo ID\\'s lends itself to the need for a \"federal\" photo ID system, to be established, implemented and overseen by another as an yet utmamed and unfimded federal organization, OR added to that already undertaken by the US Department of State for issuance of passports. f) The FAA does not fector in a pilot\\'s costs of using portals (KTC\\'s and/or DPE\\'s) for this process. The FAA acknowledges it will require and greatly depend on the usage of portals. In total, the FAA underestimates the costs to pilots, uses suspect information for auditing all portals and the cost of \"federal\" photos, and no cost for portals handling the large task at hand. From a current cost of $0 with use of currently authorized ID\\'s, such as state issued driver\\'s licenses (stated as being acceptable for future use) to well over $700 for tlie pilot\\'s cost of compliance is a large change for NO additional safety benefit sited. The cost analysis and impact presented may not accurately reflect the true cost and nor the safety impact of this proposal. \"3) Enhance the quality, utility, and clarity of the information to be collected:\" The proposal merely duplicates current requirements, and does not enhance the quality, utility, or clarity of the information that is to be collected nor enhance or clarify that already collected. a) FAA expended resources issuing pilot certificates meeting \"DEA fmal rule\" (proposed over twenty-three years ago, in 1988) and satisfying \\'*the IRTPA requirement to issue pilot certificates that are resistant to tampering, alteration, and counterfeiting.\" b) FAA requires each pilot exercising the privileges of valid certificates to hold in possession a photo ID in the form of a state issued drivers hcense, federal government ID, armed forces ID, official passport, etc. as found in FAR 61.3(a)(3) & (3)(i...vi). c) Each pilot given training by any US certified flight instructor is identified by that CFI with proper photo ID and proof of citizenship ifas required by the Department of Homeland Security\\'s TSA ifas eligible to receive the desired training. Same documentation records must be kept by the CFI as prescribed by the TSA. d) Every applicant for any test and/or pilot rating who goes before the FAA or their KTC or DPE must show proper ID, retained by the appUcable authority on behalf of the TSA. e) Each of these actions required of pilot applicants OR pilots exercising the FAA\\'s granted privileges is in keeping with the TSA\\'s IRTPA Section 4022 and the FAA\\'s mandates found in Section 44703(g)(1) for individuals applying for or exercising the privileges of airmen certificates, f) The proposed additional need to modify the airmen certification system to accomplish currently satisfied requirements is duplicate and redundant to those already in place, g) There is currently NO requirement for a Federal photo or other biometric ID for all US citizens. Is Congress really calling for only pilots to be subject to such a requirement? If so, what about all others involved in air commerce and not properly \"known\" and photo ID\\'d by the FAA? h) Does such a requirement for a \"federal\" ID call into question the validity of state issued ID\\'s that are acceptable and/or proposed to be used for this or any other federal ID process? i) The desire for a national, federally controlled ID system is not the same as the need for such a system, when all of the currently acceptable ID systems in place are acknowledged to be acceptable both now and for the foreseeable future. The proposal does not in any way enhance the quality, utility, and clarity of the information to be collected or already in place for the proper validation of pilot ID\\'s. \"4) Minimize the burden of collecting information on those who are to respond, including by usins appropriate automated, electronic, mechanical, or other technological collection techniques or other forms of information technology. \" The proposal increases the burden on those who are to respond by duplicating activities. a) For all pilots, for all domestic flight activities, a state issued drivers license or other ID prescribed in FAR 61.3 is considered valid by any law enforcement agency, whether local, state, or federal. These same forms of ID are stated Jis being valid for FAA use in the proposed initial, renewal, or special authorization facsimile replacement pilot certificate. b) In keeping with ICAO standards, when traveUng internationally, pilots carry a US Department of State passport photo ID, which suffices as being valid for and recognized by various foreign government\\'s identification requirements. Any proposed FAA issued photo ID would be redundant, in having the FAA create and oversee a duplicate process that is already available and undertaken by the US Department of State. This brings us to a generzJ comment about the proposal: If Congress proposes to implement a citizen wide federal ID program, and wishes to start with a small segment of the general population by requiring the FAA to issue a federal photo ID for all pilots: a) same can be easily accomplished, at NO COST to the FAA, by revising FAR 61.3(a)(3) to state \"...the photo identification must be an official valid US Department of State issued passport or other foreign government issued and recognized passport with valid US approval and/or documentation.\" b) The US Department of State, set up to accq>t, validate, & issue federal photo ID documents with expiration dates, could provide every pilot with a federal issue ID (again, ironically, accepting & using a state issued drivers hcense as a valid form of ID for issuance of the federal passport ID), c) The FAA incurs no expenses and is able to devote their efforts to the mandated purpose of ensuring safety in air commerce. d) No revision to the FAA\\'s FAR\\'s would be required beyond that stating the only acceptable form of ID would be the passport, for any applicable time inwhich a photo ID is required. e) If the Department of State anticipated that a \"one date fits all pilots\" would be burdensome, then the FAA\\'s proposed \"phased\" approach could still be undertaken to help relieve any increase in the workload encountered by the Department of State. f) A pilot could use any previously issued \"expired\" passport ED for the exercise of the privileges granted while awaiting the issuance of a valid replacement passport, provided the pilot carried some receipt issued by an applicable US Department of State representative showing the same was \"in process.\" g) This method would ensure the viability and usefulness of the pilot\\'s underlying certificate based solely on the safety benefits of medical fitness and currency of flight experience as prescribed within the FAA\\'s mandated safety regulations, without subjecting a pilot to delays caused by any government entity\\'s inability to timely process the appUcation for any reeison. \"Comments Invited\" (Page 70875, 3rd Column) Additional comments presented per the request: \\'The FAA is specificallv interested in receiving comments on the following questions:\" \"(1)...standards that should be used for identity verification...\" If the proposal is undertaken, same photo ID validation should only be undertaken by the US Department of State, to ensure consistency and eliminate duplication of efforts, as well as prevent any foreign country firom questioning the validity of an identity presented when only based on a FAA issued pilot certificate. \"(2) Should the FAA consider an alternative implementation approach...\" The approach should be acceptable if it adequately addresses the anticipated workload to the US Department of State in issuance of \"federal\" photo ID\\'s, in the form of a passport for all pilots. \"(3) ...Are there alternative, potentially less burdensome, methods for pilots within the US and outside of the US the FAA should consider?... The stated use of the US Department of State representatives, both domestically and abroad (foreign consulates & embassies etc.) would keep the FAA firom having to duplicate & oversee a process that is already in place. \"(4) Is the proposed 8-vecU\" duration for the photo, based on the photo duration...a reasonable period of time that balances the securitv needs. ..and the burdens on certificate holders?... Current US Department of State 10 year duration of passports is adequate for all security needs, both domestically and abroad, and accepted by the Department of Homeland Security\\'s TSA. \"(5) Is there any reason whv student pilot certificates should not be treated like other pilot certificates...? The 6-8 weeks aad complexity involved prior to the ability to fly any first lesson discourages any spontaneous student starts. The CFI involved in training already vets the apphcants ID and eligibility for any training per TSA requirements. DupUcation of same while enduring an excessive wait is unnecessary and counter productive to encouraging training. \"(6) With the respect to the photo...should the FAA accept only hard copy ...digitally captured... Or either...photos? The process should be the same as and only undertaken by the US Department of State, to ensure consistency and eliminate duphcation of efforts, as well as prevent any foreign coimtry from questioning the identity presented when only based on a FAA issued pilot certificate. The use of any other standard would require substantial & uncalculated costs to verify photos. \"(7) If the FAA accepts digitally-cqjtured photos, what are the advantages and disadvantages of the following methods...(a) ...self-captured...(b) a FSDO capturing...(c) a Knowledge Testing Center capturing...(d) a DPE capturing the photo when an application is submitted? The process should be the same as and only undertaken by the US Department of State, to ensure consistency and eliminate duplication of efforts, as well as prevent any foreign country firom questioning the identify presented when only based on a FAA issued pilot certificate. Additionally, (a) self captured photos negate the ability to check the authenticity of the photo and defeat the purpose of the verification process. For (b)(c)&(d), all other proposed methods require an as yet imdesignated process to establish, verify, and oversee the accuracy of any such process, which duplicate processes proposed to be or already in pljice with the US Department of State. In closing, the proposed revisions to 14 CFR Par 61 for a photo ID on all pilot certificates are uimecessary and counter to the scope of the FAA\\'s authority and mandate found in Subtitle VII Part A, Subpart iii. Section 44703(b)(1)(c) for ensuring safety in air commerce. In addition, any Congressional requirement put forth in Section 4022 of the 2004 IRTPA for estabUshing the identity of pilot applicants and the issuance of improved pilot licenses has been undertaken, surpassing any requirement for discerning the identity of any present or fiiture pilot. The proposed requirement for a photo ID on pilot certificates creates duplicate and redundant requirements, well above & beyond that of any other US citizen, or any persons with rights to exercise privileges earned and granted by the US government. Your time and interest in our public comments are greatly appreciated. I hope the same will clarify the need to send this proposed requirement for the FAA to issue photo ID\\'s on all pilot certificates back for further review OR to be withdrawn completely, as unnecessaty with the current level of safety & security provided under the current FAA regulations. Sincerely, Kevin P. Hynes Kph/Cc: Rep. Thomberry/Sen. Hutchison/Mr. Craig Fuller, President of AOPA 4806 Lake Park Dr. Wichita Falls, TX 76302-3904 ktayneswftx@hotmail.com (940)781-3030  ŁTARTlvlENTOF Ł ;3-0RTATI0N Feb. 18,2011 ^--L.uiiD.b Comments Re: Docket # FAA 2010-1127 : --> i x v Ł o DOT Docket Operations 202-493-2251 FAX Dear Sir: I have been very frustrated trying to utilize www.reguiations.Eov to submit comment to the FAA docket regarding Photo Requirements for Pilot Certificates. Accordingly, 1 \"Would appreciate you adding page 2 of this FAX to the docket, despite a day\\'s tardiness. Please retain my page formatting by appending page 2 to the docket as an attachment. Thank you. Sincerely, Ed Neish 30700 Road 14B Steamboat Springs, CO 80487 edneish@jimo.com Feb. 18,2011 Comments Re: Docket # FAA 2010-1127 Dear Sir: Please add these comments to the above docket. Please retain my formatting. This proposal is another example of government Tunning amuck! The cost is the better share of a BILLION dollars over 20 years! That is a BILLION!!!! The NPRM itself estimates 445.8 million 20-year cost to airmen and $718.7 million total cost. What conceivable benefit can accrue? None has been demonstrated or even alleged. Hence the cost-benefit ratio approaches infinity. This proposal is absolutely outrageous and further, cost overruns can be expected. Not included are the significant logistical, non-monetary costs. Also not included is the hfe disruption for nearly a million pilots. Also not included is the energy waste of transporting pilots to the photo locations. Majiy pilots live hundreds of miles fi\"om \"civilization\". The retroactive impact of the proposal is particularly onerous. This proposal counters President Obama\\'s own agency cost-cutting agenda, counters the congi\\'ess\\'s budgetary mandate, counters the nation\\'s energy woes, and exacerbates the nation\\'s fiscal crisis significantly. When the government is seeking cost-cutting measures to improve the federal deficit, the FAA should not be pursuing counterproductive and unnecessary regulation that offers no benefit!!! Accordingly, this proposal should be summarily withdrawn. The only possible rationale is the compliance with an obscure provision in the IKPTA. Obviously the congress needs to remove tlie flawed provision if it is the driver of this proposal. Congress has lost touch with reality. It is time for the FAA to stand for reason in accord with its statutoiy authority. Moreover, if this outrage is enacted, what is next? Another BILLION-dollar repeat for biometrics? Dna samples? The floodgates are open. This is a BILLION-dollar waste of your money and my money as well as inconvenience to all pilots for no apparent purpose. Sincerely, U-Ed Neish 30700 Road 14B Steamboat Springs, CO 80487 edneish@juno.com  Cessna Aircraft Company  One Cessna Boulevard, P.O. Box 7704, Wichita, Kansas 67277-7704, 316/517-6000   Cessna Aircraft Company is a subsidiary of Textron Inc.    A Textron  Company Cessna          10 January 2011    IN REPLY, REFER TO:           L390-11-0043    Lance Nuckolls Certification and General Aviation Operations Branch    AFS-810, Flight Standards Service  Federal Aviation Administration   800 Independence Avenue SW.   Washington, DC 20591       SUBJECT: Cessna comments on Docket No. FAA-2010-1127; Photo Requirements for Pilot Certificates   Dear Mr. Nuckolls,     This letter is being transmitted electronically; the original will be maintained in the  Cessna Airworthiness files.    Cessna Aircraft Company has no comme nts on this issue at this time.    Cessna Aircraft Company appreciates the FAA™ s consideration of our comments.  If you require additional information or have any questions, please do not hesitate to contact Neale Eyler at telephone number 316- 517-7488, facsimile number 316-206-7258, or  email neyler@cessna.textron.com.     Sincerely,  for  Carlos Ayala Manager of Airworthiness  CESSNA AIRCRAFT COMPANY   The current FAA plastic certificate, while vi sually artistic and ta mperproof, presents  readability difficulties as well as being ﬁclut teredﬂ with information, particularly in  matters concerning ratings and limitations.      By mandating a photo (or other biometric data) to  be present on the license, it adds to the certificate clutter, readability, and will add  to the administrative overhead expense of the  FAA, especially since the proposed $22 processing fee is far less than the cost to operate the yet to be created photo ID section and fund its employees , particularly given nearly $14 trillion in national debt. The FAA has no business of adding to the national debt and no business of expecting the pilot population to subsidize its administrative expenses  relative to photo or other biomet ric identification management.     A better solution is to require pilots to carry  a U.S. Department of State Passport ID Card  ﬁPasscardﬂ, which is valid for ten (10) years. Department of State (DoS) presently has a  complete, worldwide infrastructure to issu e and manage Passcards Œ administratively,  operationally, legally, and with security enforcement. The Passcard application process is  both thorough and rigorous.     The FAA merely needs to add ONE (1) lin e on the medical certificate application  document Œ FAA Form 8500-8 Œ requiring th e current US Passcard ID number and expiration date. Such an action does not require the FAA to create an additional  infrastructure to manage photo identification to  include avoidance of all start-up costs and subsequent operational costs. Rather, the FAA needs to coordinate a Memorandum of  Understanding with DoS to exchange database information comparing and validating   Passcard identification number  and expiration date. The FAA would transmit to DoS a  roster of pilots who are or will be in th eir Passcard expiration month. DoS would validate  renewal or expiration. If the Passcard is expired or revoked, the pilot would not be able to exercise pilot-in-command privileges. Ther e would be a corresponding paragraph in FAR Part 61 specifying US Passcard requirements  for identification and regulatory duty to carry the Passcard with Pilot  Certificate and Current Medi cal to exercise pilot-in- command privileges. As an entity of the US government, the DoS issued and managed  Passcard satisfies a national standard and eliminates the ﬁinconsistencies/non- standardizationﬂ of the present 50 states, four trust territories, and one district without requiring FAA to re-invent an already ex isting and proven modality of approved,  standardized identification that meets all st andards of each and every U.S. Government  Department, Agency and Commission.      This Passcard approach is much easier to im plement, faster to implement, highly cost  effective, and does not require any ﬁheavy liftingﬂ by the FAA. This Passcard approach leverages the existing U.S. Government enterprise and economy of scale by utilizing best-of-breed existing capabilities, expertise and infrastructure. DoS has a robust infrastructure of U.S. Post Offices and DoS ﬁbranchesﬂ throughout the world that can process any Passcard request (to include fast turn-around) or issue an emergency  Passcard on an as needed basis.    Charles M. LaBow 14420 SW 79\"\" Avenue Palmetto Bay, Florida 33158-2006 United States of America +1 305 255 6121 Facsimile +1 305 253 8467 chuckltSaskchuck.com ^LRARTMENTOF ^Ł\\'\\'MSPORWION Ł<I:T OPERATIONS JAN !0 P i:3l January 3, 2011 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 RE: Docket ID: FAA-2010-1127 Gentlemen: I wish to express my opposition to the proposed rule changes contained within Docket ID: FAA-2010-1127. I have been a certificated pilot since 1967 and a certificated airframe and power plant mechanic since 1971. AT NO TIME in the past 44 years have I ever even been asked to produce either my pilot\\'s license or mechanics license in any form, by any person in authority other than when at an FAA facility, such as a Flight Standards District Office, when upgrading a certificate. In most cases, they asked to see my certificate in order to correctly copy the existing ratings and endorsements to the certificate they were issuing. Most of the time, they never even asked to see a photo ID of any sort. If they did, a passport or government issued photo ID, such as a state driver\\'s license was sufficient, as long as all of the address information was the same. In addition to my FAA issued certificates, I also hold a Master Mariner\\'s License, issued by the U.S. Coast Guard, and a Commercial Driver\\'s License (CDL with \"HAZ-MAT\" endorsements) issued by the State of Florida. The Coast Guard license is simply an 8\" x 10\" piece of paper with no photo and my thumb print on the back. (A full set of fingerprints was taken by the Coast Guard at the time of issuance and renewal.) In order to maintain my Coast Guard license, I was required to obtain a \"TWIC\" card (Transportation Workers Identification Credential). The TWIC program is currently administered by Lockheed/Martin and costs $132.50 for issuance with five year validity. The CDL with HAZ-MAT endorsements in the State of Florida, costs $75.00 for the license, PLUS $130.00 \"administration fee\", PLUS $91.00 \"Haz-Mat Application fee \", or $296.00. The \"Haz-Mat Application fee and \"Administration fees\" are described by the State of Florida as being mandated by the \"TSA Hazardous Materials Endorsement Threat Assessment Program\". This would be the same Transportation Security Administration that charges a fee for the same security/background check in order to issue the TWIC card. However, since for some incomprehensible reason, in the days of everything being on computers, federal agencies cannot seem to share common data between agencies. I mentioned to the Lockheed people issuing my TWIC card that I had a valid hazmat background check done within the year, by I was advised \"that was not within an acceptable time window.\" I asked if, since I was also a pilot, \"Will my TWIC be able to be used at airports?\" The response was, \"No, that\\'s a completely different agency.\" I know the TWIC card works at FAA facilities because on a recent visit to an FAA TRACON facility, the security people asked for my ID, so I gave them my TWIC card. Their first reaction was, \"What\\'s this?\", since the face of the card simply has my name, photograph and \"TWIC\" in bold letters. I told them it was a TSA card and to scan it. Whatever is contained on that card generated a lot of, \"Yes sir, Mr. LaBow...park right over there Mr. LaBow...let me show you where you are headed, Mr. LaBow.\" So, it seems the FAA can use this data. While engaged in operations at the Port of Miami (seaport), in the past two years, I have been asked for my TWIC card, exactly ONE time. I have read the comments by Mr. David Tietelbaum, DOT/FAA, regarding FAA-2010-1127-003.1, as this change in the rules would have \"no net cost to society.\" \"While this is a real cost to the pilots, these payments to the FAA are considered transfer payments; 0MB 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. \" While I can understand Mr. Tietelbaum\\'s \"GOV-SPEAK\" line of thinking that there is \"no net cost\" to society, i.e. \"The FAA\" since it is a transfer of funds, there is a large net cost to individuals such as pilots. In addition to the obvious direct charges for the document itself, there are the incidental costs of time off work, travel costs, car expenses, etc. that will be absorbed by the pilots. All for what gain? To simply satisfy the Congress to do something under \"The USA Patriot Act\". Congress has made stupid demands in the past, and they will continue to make stupid demands in the future. In theory, the FAA should be a little more intelligent than Congress and be able to show that rules are already in place that fulfills the requirements of this new photo ID. You already have to carry a form of \"official\" or government issued photo ID (driver\\'s license, passport, etc.) in order to exercise the privileges of you FAA certificate. This new requirement is an expensive and wasteful duplication or resources and money. Past performance by the FAA in areas such as this, have not been particularly encouraging that this program would even work. The changes to eliminate paper certificates for plastic cards were done only a few years ago. Now you plan to completely redo all of that once again. The FAA has basically admitted they have in effect \"lost\" about 1/3 of the US aircraft fleet because of poor record keeping of the aircraft registry. Who\\'s to say this change would be any different? In closing, I would respectfully request that you reject this re-issuance of pilots certificate cards, at least in the form presented in this NPRM. Perhaps, you could phase it in as pilots replace or upgrade certificates. The load on pilots of both time and money would be somewhat less as well as the burden on FAA staff in Oklahoma City record processing. Sincerely, Charles M. LaBow CML/msw  Submitter Info:  First Name:  John  Last Name:  Allen  Mailing Address:  Deiter  City:  Tulsa  Country:  United States  State or Province:  OK  Postal Code:  74134  Email Address:   deiter@cox.net   this does not belong with this proposal  remove this from the legislation!  or better yet scrap FAA?2010?1127 completly   DEPARTMENT OF TRANSPORTATION  Federal Aviation Administration  14 CFR Parts 61 and 183  [Docket No. FAA?2010?1127; Notice No.  2010?16]  RIN 2 120?AJ42  Photo Requirements for Pilot  Certificates  AGENCY: Federal Aviation  Administration (FAA), DOT.  ACTION: Notice of proposed rulemaking  (NPRM)  This is bad law making, we are saddled with excessive regulation which  are  complicated to say the least. If  this rule goes in to effect it will  have  increased the already high cost of private and commercial flight without  improving the perceived required security requirements.  Security requirements in the private pilot sector are of no security  threat  to the general population.  We are required to have a valid photo id with us when we fly, and the  added  burden imposed by this legislation is absolutely not necessary, it just  adds another layer of bureaucracy to a already over loaded system.  End result is  that it will hasten the demise of a faltering private  aviation system that is presently  the best in the world.  Is it necessary that we follow other countries that have regulated  private  piloting out of existence?  It is my opinion that having flown since t he 50s and having my private  and  A&P, the system is not broke as is and should not require tampering  with.  The proposed legislation is redundant, we have other entities nosing in  to the FAAs business, and for the sake of private aviation, we cannot let  tha t happen,  I have read the proposed rule making and it complicates flying and  increases an already expensive sport.  In closing the legislation should be trashed in its entirety          sincerely John Allen Deiter    Docket Number FAAŒ2010Œ1127  The background material states the following (extra cted from various parts of the document): a) The FAA also proposes to amend § 61.3 to remove  the requirement to carry a separate government- issued photo identification for persons carrying a  pilot certificate with photo. The FAA has determine d  two photo identifications are unnecessary and do no t serve a safety or security interest. b) The FAA would treat the facsimile pilot certific ate as a special purpose pilot authorization that m ay  be used in conjunction with a government-issued pho to identification under § 61.3. This treatment  would allow a pilot whose identity has been certifi ed by the FAA to continue to exercise pilot  privileges while allowing security agencies to veri fy the pilot™s identity against a government-issued  identification.   c) Summary of time and costs (20-year): Total ..... .............. $387,460,624 & 7,597,502.66 (hours,  I  presume?)  d) In conducting these analyses, FAA has determined  that this rule: (1) Has benefits that justify its  costs, (2) is not an ‚‚economically significant reg ulatory action™™. e) Summary In this analysis, the FAA estimated futu re costs for a 20-year period, from 2010 through  2029. All costs in this analysis are in 2008 dollar s.  f) There are currently about 740,000 pilots and 93, 000 CFIs that would be covered by this proposal.  First, I must ask, how did we come to be so far out  of touch with reality? In \\'a\\' above, the FAA will not require two photo id entifications. Given that few pilots walk or take  public transportation to get to their aircraft, the y still will be carrying that most common of primar y  pieces of identification, the driver\\'s license. The y need it on both ends regardless of FAA identity  requirements. This has always worked well and I am  aware of no instance where the lack of an FAA  photo ID contributed to any event.  In \\'b\\' above, in order to vet the authenticity of a ny pilot required to obtain a new FAA photo  identification, the FAA will continue to rely on ot her, common forms of acceptable identification. Now ,  while there are many, including passports and other  recognized ways to do this, the state driver\\'s lic ense  will remain the most used. Therefore, what is the p oint of requiring a pilot to get another photo ID  using an already-accepted form of ID to verify iden tity? Other than the FEAR component of the  various legislative acts driving this agenda, there  is no point. The change serves no articulable purp ose,  nor will it prevent any criminal from acting.  In \\'c\\' and \\'f\\' above, are there no adults in the ro om? Is everyone involved with this dubious process  completely oblivious to what is going on? We are po ised to incur over 380 million dollars of  costs...more than a third of a billion dollars, was te over 7.5 million hours of everyone\\'s time and  inconvenience and penalize over 830,000 people, for  what? Because 19 people, who were not citizens  committed a massive crime on Sept 11, 2001? By what  cost/benefit ratio is this even remotely rational?  Where does suspicion of American citizens arise fro m this act and further factor into this equation? I t is  highly offensive that the mistakes and oversights o n the part of government agencies, all of whom had  entirely adequate tools at the time but, though ina ttention, ignorance or incompetence, did not do the ir  jobs on and before that terrible day now find it ex pedient and desirable to impose onerous requirement s  and restrictions on citizens. Shame on all of you.  In \\'d\\' and \\'e\\' above, by what measure do the enormo us penalties in money, time and personal impact  \\'justify costs\\'? Apparently, determining the action  is \\'not economically significant\\' is made on the b asis  of per capita impact. On the basis of program costs , more than a third of a billion dollars certainly  is  very significant. And, all that is based on project ions made in 2008 dollars. Any thinking person know s  it will cost more in the long run.  Lastly, it\\'s way beyond time to stop cowering in fe ar and letting our institutions, traditions and rig hts be  determined by the acts of a truly miniscule handful  of criminals. Let\\'s stop pretending things such as  this photo ID will provide any measurable level of  safety or security and is anything other than a hug e  waste. A pilot\\'s license and another government pho to ID have been sufficient for years. They remain  so and there is no need to create another bureaucra tic scheme. Thank you.  Stephen Fleming  Alto NM 88312  castolon@gmail.com  ',\n",
       " 'This is a ridiculous requirement that will further complicate the already challenging task of becoming a pilot without adding one iota of extra security.  Just require pilots to carry their driver\\'s license with them if you want photo identification.  Sometimes I wonder if anyone working in the government has any common sense what-so-ever. The Arizona Pilots Association wishes to take this opportunity to speak out in opposition to the proposal to mandate an I.D. photo on the pilots certificate. Presently, FAA regulations (FAR 61.3) require you to have a picture ID in addition to your airman\\'s certificate to operate an aircraft. This proposed action only  adds more expense and regulation when citizens are asking for a smaller, less costly, and more efficient government.  This proposal provides no additional security or value and saddles pilots and taxpayers with unnecessary additional costs.  Respectfully submitted,  James Timm Executive Director Arizona Pilots Association  Concerning rule requiring a photo on pilot license  (FAA-2010-1127) is redundant and costly.  Any acceptable picture ID could be shown if needed if one is exercising their pilot privilege.  It is unfortunate that we get someone in congress that thinks they have great ideas and do not think it through.  By making this rule change, it creates more paper work, creates more expense in government and consequently it passes down to the expense of General Aviation.   It would seem that the FAA is going overboard with the requirement to have a photo on the pilots certificate. The certificate along with a photo ID such as your driver\\'s  license or other form of photo ID would be adequate. This just seems of another way to waste our taxpayers money when it isn\\'t necessary.  If there is a will, there is a way and if someone wants to make a false photo ID then it will be done.  Just as with the drivers license or any other ID so why waste our time and money inventing another way to waste our taxpayers money. We just have to use common sense pay more attention when it comes to inspecting a persons credentials.  Don\\'t nickle and dime us to death using the \"Threat to National Security\" to try and justify your actions. I am AGAINST this rule.  The requirement for pilots to have pilot certificates with photos on them is NOT NECESSARY.  The issue of positive identification of certificated pilots is taken care of with the existing rule that they must have with them also a government issued photo ID such as a drivers license or passport.  Furthermore, the FAA would have to incur costs to hire people to administer the program, there would have to be a way for the photographs to be verified which does not exist today, the certificates would have to presumably be periodically updated with new photos, etc...   The costs to both the pilots and the government just multiply for nothing. Instead of ADDING to the burden of the General Aviation pilot, how about SHRINKING the burden?!  There\\'s no new security here - Note to self:  Bad guys don\\'t carry licenses whether they have a picture or not!  This is nothing more than an agency money grab to justify their existence.  As the number of pilots, planes, and flights shrink --- So should the FAA! I am against this proposal because I believe it\\'s a make work item rather than a security issue. The local FAA offices will be inundated if the rule is approved and increase workload to an already stressed agency.  Most, if not all pilots also have a driver license with photo that will serve to supplement their Pilot License. Only recently we all had to get the new plastic license so why go forward with this?   Government is already big enough and TSA has become IMHO an 800 pound gorilla already. Everybody has an opinion about the TSA and most are not good. For example, I can fly for free as a retired airline employee, but I\\'d rather drive than fly anywhere within 500 miles of my home.  Flying a private airplane is also very expensive already with gas at our local airport in excess of $5.00 a gallon. The eyes and ears of airports are the pilot population and we get treated like nobodys. Most TSA employees have no first hand experience in aviation IMHO again.  Don\\'t make this rule effective. It is unnecessary except for the jobs it will surely create in Government.  I feel that a pilot must carry a government photo ID.  I also feel that those pilots who already carry a government photo ID should be exempted from this new proposal.  I personally carry two already (Drivers License and Military ID) plus a photo-badge for one of the airports I fly out of.  A fourth photo ID would constitute a costly and time-consuming new layer of bureaucracy for this pilot to hassle with.   Furthermore, the federal government is responsible for safe skies, national security, and those protections that citizens cannot provide individually.  If we must carry a third or fourth government photo ID then it is the federal government\\'s responsibility to fund it out of the tax dollars I have already paid.   I find no justification for the pilot photo ID for the following reasons:  * Already a requirement to carry gov picutre ID * Additional cost and time is lost to pilot * The Federal Gov is already drowning in debt.  We do not need to add additional duties to Fed employees or hire new ones * Everyone in the country is walking around with wallets full of picture ID\\'s in addition to the ones hanging aorund their necks.  They mean nothing, since the dishonest can make better looking copies than the Gov * More burden on the aviation industry is not warranted.  Everything costs time and that equals money.  We\\'re hurtin\\', folks....time to pare back, not load on.  If this proposal would help I\\'d be for it.  It will do nothing except further cripple our industry.  Thanks,  Jim I think photo id is a good idea as well as biometric so long as there is a use for it.  If we pilots are to be given a pass at the airport security lines by showing our ids, then I\\'m for it.  OTOH, in the nearly 4 decades I have had a license I have been asked for it exactly once and that was to turn it in for an upgrade to my instrument rating.  If there is to be no additional benefit in the change, then it is spending money for no purpose other than to provide employment for even more government bureaucrats.  Your proposal for a photo ID is another extension of big government socialism.  Oppress the innocent at the expense making us safer.   I foresee brown shirt FAA goonies asking for your license at every airport.  I\\'am against such government invasion of freedom and will oppose  your rule making. This is a really bad idea.  What is wrong with the current system of using a driver\\'s license or other government issued photo ID?  Why do we need another means of identifying ourselves?  All this does is make it more expensive to issue a license and create more bureaucratic jobs and government waste. I am  against this proposed rulemaking!  There appear to be no benefits that would accrue to the FAA or security enforcement organizations from this rule. Certificated pilots are already required to possess photo identification when operating their aircraft. Thus, the rule is redundant.  Financially this rule would impose regulatory costs on the FAA and burden pilots with a needless expense.  Finally the proposed rule would constitute yet another government restriction on free citizens who already resent the extreme intrusiveness of the federal government in our lives. Re: the proposed rule to require a photo ID and bionic information on a pilot\\'s license, the only rational response is, NO!  Adding more layers of bureaucracy to the flying process will not improve aviation safety. Real safety means that the Federal Government stops allowing students with expired visas, refugees, and workers with expired green cards to get \"lost\" and melt into society, while legitimate citizens are being tracked from every angle. Real safety means securing our border with Mexico. Real safety means passenger profiling and Isreli-style security at every commercial airport. Real safety means finding and punishing businesses that hire illegal aliens. Real safety means shutting down \"sanctuary cities\" within our country. Real safety means kicking organizations like CAIR off our soil. Real safety means stopping the flows of drugs and human trafficking into the US that fund terrorist organizations - the very ones we then pretend to fight, and to be tough against as we haze Grandpa Joe for wanting to take his grandkids up for a spin in the sky!  I thought the switch to plastic pilot\\'s licenses AND the new student screening procedures AND the airport security badges were supposed to eliminate the safety threats to GA. Apparently they didn\\'t. Go figure! I guess the policy wonks didn\\'t realize that criminals don\\'t follow the rules! Maybe that\\'s what makes them criminals? Do we really think future hijackers and underpants bombers are going to abide by stricter licensing requirements? If not, what then? Oh, but the real goal is to advance, step by step, the bureaucrat\\'s drem of a 1984-style totalitarian control society, isn\\'t it? Or do you think pilots are too thick to realize that? Will the photo really make any true impact?   The $22 is steep.  You should be able to use US Passport photos.   Yes, create a cross information function to use other government photos.    Omit any photo requirements for non pilot id\\'s, ie- a&p, ia, etc. COMMON SENSE SHOULD PREVAIL HERE!!  THE REGS REQUIRE A PILOT TO CARRY A PHOTO ID.   IT IS OBVIOUS THAT HAVING DUAL ID IS BETTER THEN WASTING MILLIONS ON A NEW CERTIFICATE WITH A PHOTO.  THIS IS UNNECESSARY IT IS A BAD RULE AND A WASTE OF MONEY.  RICHARD WYEROSKI I am the testing center supervisor for a part-time FAA Knowledge Testing Center associated with a flight school, as well as a private pilot and basic ground instructor.  I believe the proposed photo requirement is unnecessary since pilots are already required to carry a photo ID with their pilot certificate.  The suggestion that Knowledge Testing Centers might be \"a logical venue for verifying identity and taking digital photos\" is inappropriate because it would impose a new and different function upon the testing centers.   The proctor\\'s function is to review the identification presented, not to create new IDs for the test-takers.  Our testing center does not currently have a photo studio set-up and since we offer tests by appointment only, we would not ordinarily  be able to accomodate walk-ins for this service.  I assume there would be an additional charge by the testing center to cover the costs of this service, as well.    This proposal is burdensome, expensive and does nothing to enhance security. While the addition of a photo on the Pilot Certificate doesn\\'t seem like a bad idea on the surface, I have two issues with the proposed ruling.  1. The current state of requiring another photo id is sufficient and even meets the photo renewal standards.  Making this proposed rule simply an additional UN-NECESSARY expense to the taxpayer.  2. Requiring a renewal at an 8 or 10 year interval completely makes this ruling useless.  This creates an ongoing UN-NECESSARY tax burden on the aviation community and the taxpayers.  A simple effective solution is already in place.  Use it!!!!! Pilots already have all the documentation that is needed through previous regulations. Additional costs to the taxpayers and burden on governmental employees is not acceptable. We do not need photos on the pilot certificate because we are already required to possess the photo on another \"government issued identification\". Thank you. I say no.  The time effort and money it takes to get a private license is already prohibitive.  Adding another kink in the process is only going to make matters worse.  Additional cost and hassle will quickly be transferred to the student, driving the cost and time that it takes to complete training even higher. What does this actually accomplish? We already are required to have a photo ID when we fly.  This is not going to make anybody safer! This is an additional level of bueracracy that does not contribute to security. The current requirement to carry a government issued photo ID is more than sufficient to meet this need. It seems to be nothing more than a money making scheme. As pilots, we all ready meet the requirements to have a govt issued photo ID in our possession.  This proposed rule is a waste of both our resources (our time and money) and a waste of government resources.  I OPPOSE the implementation of this rule. The proposal for a new type of certification which includes a photo and has to be renewed every so often seems an unneccesary approach to diminishing risk of terrorism and identity theft. One huge reason why is that if as (student) pilots we are required to have in our possession at all flying times and within airports, our certificates PLUS a governement ID ( Drivers license, passports, etc) a required photo on the pilots certificate is just costly and an extra burden. If the reason for this proposal is the elimination of identity theft on a lets say, fake license or gov. ID, don\\'t you think if someone is able to produce fake drivers licenses they can do the same to an FAA pilot certificate? but of course they can! criminal minds have their way with things if they choose and the falsification of a gov. ID can be easy to make. This idea will increase jobs and personnel within the FDSO but decrease the chance for pilots to fly often and for new student pilots to follow their dreams, in other words it\\'s just a setback and another burden financially and time consuming(ly). Please rethink this proposal, I am sure there are many other ways to increase aeronautical and within airport security, and this proposal does not seem sufficiently valid to help. Thank you for reading. have a nice year (flight)!!  :) There is absolutely no reason to place a photo on a pilots license.  It does nothing but burden pilots and tax payers.  It does not keep bad people from doing bad things.  As long as the political climate forbids profiling, the country will be at risk. There are enough photo Id venues in pllace without adding another. Adding a new Section 61.6 to require all pilots to have an FAA-issued pilot\\'s certificate with the pilot\\'s photo does nothing to enhance security.  As the NPRM conceded, Sec. 61.3 requires all pilots to carry government-issued photo ID in order to operate an aircraft.  In point of fact, the proposed rule does not address any tangible gains to be had by implementing this rule.   This is, to put it bluntly, another exercise in \"security theater\".  It is a rule that shows the government is \"doing something\" to supposedly enhance security, but it does nothing of the sort.  The rule also casually dismisses the issue that every pilot in the nation will have to appear at the door of a FSDO or a Knowledge Testing Center for the sole purpose of obtaining a pilot\\'s certificate with his or her photo on it.  There is no thought given to the point that those entities also will have to deal with a steady stream of pilots who will be appearing there for no other purpose.  The rule assumes that pilots will apply evenly throughout the transition period.  That is pure fantasy.  Every other implementation period has resulted in a rush to comply as the deadline approaches.  If you doubt this, go visit a post office any April 15th, when Federal tax returns are due to be mailed.  Pilots are no different than mere mortals.  Finally, the \"security theater\" aspect is apparent in that these photo certificates will be goof for life.  A pilot who does not obtain a new rating for ten, twenty, thirty years will have a certificate with a very old photo.  This rule should be rescinded.   Sec. 61.3 should be left as is. Currently the FAA requires all pilots to have their Pilots Certificate, Medical Certificate and Government Issued Photo Identification on their person when operating an aircraft.  Adding a photo to the Pilots certificate is a duplication of the Photo ID all ready required.  In this current fiscal crisis I think the government should spend the taxpayer money on more impotrant projects.  I just don\\'t see the need for the upgrade.    I object to this proposed rule, and do not believe that it will do anything to enhance security.  Like many recent government regulations, it only provides for another layer of beauracracy and an additional burden (money and time-wise) on pilots.  Those who would like to attack us or somehow harm our citizens are not going to comply anyway.  Like the new eAPIS, it is just another burden on law-abiding pilot citizens.  Please do not let this rule making take effect. The proposed rule is severe over-kill. What is this supposed to fix anyway? I don\\'t use my license for an ID, I have other government issued photo IDs for that purpose.  Rather than create yet another \"ID\", which is superfluous, we should rely on existing state issued IDs/drivers licenses.  If we must convert the pilot\\'s license into a photo ID, put the photo on the medical and make the medical a plastic card.  The proposed rule is way too expensive and onerous, not to mention of questionable utility given people aging, etc. How many government documents must I carry with my photo?  I have a drivers license, military ID card and a carry permit.  Those should be good enough without spending an additional $50.00 that should be going to buy fuel.  Foreign pilots flying into the US aren\\'t required to have a picture ID.  I guess they\\'re not as much of a threat as our own citizens. This proposal is a solution for NO problem, and will be costly and time consuming.   We have never had a photo on a pilot\\'s cert and there has never been an issue. Why change?  Absolutely a waste of time and money. I am a certified flight instructor but not very active.  I fly mostly for pleasure, perhaps 100 hours a year.  I understand that the proposed photo requirement cost will be borne by the pilot and will be $50.  That would not be so bad if it would contribute something, however small, to homeland security, but in my case it contributes absolutely nothing.  The same is true for other pilots as well.  No-one has ever asked me for a photo ID when exercising my privileges.  In the case of our small hometown airport, the government has spent at least $10,000 per active pilot on a perimeter fence, and I was never asked to pay a part of that.  It has improved the security environment for my aircraft, so there is a benefit there for me.  I have a big problem with paying for something that has no benefit.  If FAA thinks there is a benefit to this proposed requirement, how would it be calculated?  Government actions are supposed to be cost-effective.  Thanks for the opportunity to comment.    W K Benham 2000748CFI Please make provisions for designated air carrier personnel to upload and validate photos. These designees should, as a minimum, be Directors of Operations, Chief Pilots, Directors of Training and Check Airmen. The requirement to have photos on the airmens certificate is not going to increase security at all. It will be a burden and a inconvience to pilots with no benefit to anyone. This is just a way to fill their coffers, is a waste of time and effort, and is not in the best interest of making the airways more secure, if that is their real intent then there are better ways to do it. The current screenings and what airlines do is more than addiquit to keep someone from taking over an airplane. This is unnecessary and redundant. Pilots are already required to carry Government issued photo ID. Drivers licenses are updated every few years and there is always a current photo. Plus most companies issue a photo ID to their pilots which is worn with the TSA airport security badges and visable either from a lanyard or on the lapel. Student pilots already go through the TSA procedure before being allowed to enroll in flight instruction. Adding more cost would simply cut the already short supply of new pilots in the USA. This is about generating income for a government which has shown over the past three decades it cannot manage the money it already has. This proposed rule is totally unnecessary and will do nothing to make the USA more secure. I oppose this NPRM in its entirety.  The areas of cost and security, in themselves, warrant the withdrawal from consideration of the whole NPRM.  Any imposition of this new certification process will result in costs that will further damage a faltering U.S. economy, both immediately and on-going.  In addition, the costs would do nothing to improve the nation\\'s security through \"photo identification\"; recall that hijacked airplanes in 9/11 were flown by men who didn\\'t need IDs.  In this economy we are facing reduced operations due to the very cost of fuel. This is reducing income and causing family disruptions. If there was credible proof that this change was necessary and much lower cost to the pilot, I might find it acceptable.  BUT i am not required to carry photo ID as well as the new plastic pilot certificate. How does this additional expenditure increase safety? As it is you have multiple agencies involved to make a fake would require more than one fake document. By reducing that to only one expensive document does not make it more difficult to produce a fake document. It actually reduces safety.  Very few hijackers have any use for a pilot\\'s license and adding the photo will not reduce their activities.     Years ago I was required to get and carry a pilot ID card with my photo in addition to my pilot\\'s license. This has been forgotten over time and I feel that it was worthless. It\\'s biggest advantage was the cost was very low.       Why is it that government agencies do not care how much of my money that they spend. This is after taking almost 50% of what I earn.  The requirement to affix photos to the pilot certificate is redundant and completely unnecessary.  Any government issued ID card with photo is adequate.  Exactly the same positive identification is available today when a pilot is flying or about to fly an aircraft.  This proposed requirement is completely unnecessary, wiill cause expendature of personal funds with no benefit to the individual or government, will place an unnecessary burden on pilots to take or have photographs taken, and, in the end, there will be no security improvement over today\\'s existing requirements.  I repeat - there will be no security improvement over today\\'s requirements.   The proposal states: \"The FAA has determined two photo identifications are unnecessary and do not serve a safety or security interest\" but neglects to show how a single piece of identification would serve a safety or security interest.  In fact two, separately issued (and federally recognized) pieces of identification, it seems, actually would server a security interest.  This proposal is not well thought out, and serves only to create another level of bureaucracy to contend with with no return on investment.    The rationale that payment is simply being transferred is completely bogus.  These fees are absurd and if enacted, will run completely unmonitored and will continue to drive potential pilots into other fields.  There is nothing that can be done to make this proposal any better.  Please discard it all together.  I feel it unneccessary to have a photo on the document so long as bearer has another gov\\'t issued I.D. bearing a likeness, and even if a photo is decided upon, I object to having to pay for it. If the Agrncy wishes to have photos let THEM pay for it. We are letting this security thing be taken to extremes.  Please REJECT the proposal.  Thank YOU We just went through having to get new certificates that meet the requirements.  Don’t waste the money.  This is just another way to tax a group and for what gain.  You will lose money on the program.  We take a bi-annual flight review where we show a CFI our certificate and medical.  What is the point of having our picture on it?  Again, the scheme is a half-baked idea to tax. Pilots are already required to have a photo ID with their pilot\\'s license.  There is nothing to be gained.  Mechanics are never asked to show their ID.  If there is a security issue they have their employer\\'s ID  or an airport ID.  Only the FAA can ask a mechanic for his ID and if there is a question about that being the correct person then require mechanics to have another ID with a picture.  There is no problem to solve and no reason for more government burden on aviation.  We are on the margins already.  Will you not be happy until there are no more aircraft except government owned or in museums?   This is another attempt to penalize the law abiding citizens of our country for the illegal activities of others. It is redundant. Pilots are already required to carry a government issued photo ID with their pilot certificate. In addition to this they have to have TSA security clearance to have access to the larger airports. This also requires a government issued photo ID. How many photo IDs are going to protect us from these hard working and law abiding pilots? 5? 10? 100? I don\\'t understand the need to appear at an FSDO or Testing Agency.  I can get a US passport (initial issue) at any Post Office.  And the card form of a passport (initial issue) costs only $55, and it includes electronic verification. Also, I don\\'t follow the economic analysis.  Does it mean that if the FAA charges us $22, then refunds the money there\\'s an additional $22 created?  Transfers from private individuals to government agencies reduce the funds available in the private sector, no matter what the justification.  This is another unnessary knee jerk reaction.As was the  english language indorcement.IE: after questioning some Korean Airlines pilots about how they will comply with this as most of there english is SUB LEVEL 1. There answer was we have our own KOREAN EXAMENERS on STAFF. This new proposel is yet again  another waist of TAXPAYER $$$. I think that this is a terrible idea as the current system of using a driver\\'s license or other government issued photo ID is perfectly adequate. Why complicate matters and make it more expensive to issue the new pilot\\'s license? All it accomplishes is creating more bureaucratic jobs and unnecessary government waste. I am vehemently against this proposed rulemaking! I don\\'t feel that this is necessary, for we all have other forms of ID with our photo on it, mainley our drivers lic. which we carry at all times. The government should stop waisting money and help get this country back in good financial shape.  Why does anyone think this is a good idea? I cannot remember the last time anyone even asked me to show them my pilot\\'s license. Do you honestly think that the time and money are worth it? Do you honestly think that it would be difficult for someone one to make their own? I understand and support the requirement for better, more secure pilots licenses and identification, but I do not support the current proposed rule. My objections are to the cost and delays built into the proposal. The waiting time restriction on student pilot\\'s licenses is completely excessive. Flight instructors and flight schools are currently required to verify identity and citizenship before starting instruction. This should be sufficient. The requirement to visit a FSDO for picture and license issuance is also a significant burden. The FSDO\\'s are not staffed for this and are already very difficult to access for the ordinary pilot. I believe that the submission of a digital photo along with a completed 8710 via the existing IACRA system should be sufficient and much more cost effective.  We already have a requirement for Certificates, Ratings, and Authorizations, which requires all flight crewmembers of an aircraft to carry a pilot certificate and government-issued photo identification. Additional requirements and fees increase user costs and offer no additional security. They increase the size of goverment and take resource away form other more useful activity such as infrastructure changes which dirctly affect aviation safety . The horrible people that flew planes into the towers , the pentgon and a field taking live needlessly would have not be stopped by a picture id.What a wasto of government time and resouces this is. I am a retired airline pilots and can see no good reason to add another fee and burden for pilots in the form of photos on certificates.  There are a number of govenment issued IDs that can be used other than a drivers license.  A passport, military id, etc.  I am also a flight instructor and this would be a burden on my students as they can\\'t just be issued a student certificate when they need it for their first solo flight.  Flight schools already have to verify citizenship before instruction.  The cost and administrative structure will be a huge burden in a time when the government should be trying to cut costs.  Finally this proposal does nothing to improve safety or prevent unauthorized use of aircraft. We dont\\' need another fee to discourage those that wish to fly. The requirement to have a photo on pilot certificates is bureaucratically unnecessary and financially burdensome. All airman are required to carry government issued photo id already, this is more than sufficient to identify an airman. Having a photo on a certificate does not provide any additional safety or security above that of carrying another government issued photo id when exercising the privileges of one\\'s certificate. I urge reconsidering this rule. I am opposed to this rule as written.    Certificated pilots are already required to possess government issued photo identification when operating their aircraft.  Thus, the rule is redundant.  Financially this rule would impose regulatory costs on the FAA and burden pilots with needless time and expense.  According to the FAA\\'s supporting document FAA-2010-1127-0003.1 it would cost an airman $153.22 for a photo license every 8 years.  For existing pilots, this is an imposing burden, considering at most it cost $2.00 to replace the paper license with the plastic one and there is no renewal fee.  Finally, the continued effort by the FAA to add and increase fees can promote the depletion of the current pilot ranks, and hinder the recruitment of future pilots. Student pilots are already required to show a photo ID and proof of citizenship in order to begin training. Flight schools are a good first defense in the identification process. Requiring that students not solo prior to the US Government\\'s lengthy process of processing and creating a photo student certificate would hamper the ability of flight training schools to conduct business. This is an unnecessary duplication of current requirements and provides no benefit to pilots, administrators nor law enforcement. A government issued photo ID must be carried already. The burden of additional time, expense, and paperwork for insignificant results is more than enough reason for this rule not to be enacted. The proposal, as written, will cause unnecessary financial hardship for pilots and would not increase the current level of security in the United States.  An existing requirement already has the \"photo ID\" satisfied.  Why create more work and waist time and money on such a redundant requirement?  This proposal should be killed. This proposed rule is an absolute waste of time and money.  Existing Federal Aviation regulations (FAR 61.3) already require pilots to have in their possession at all times a form of government issued, photo ID.  The question becomes one of \"who prospers\" from such a form of duplication of effort?    This is such an absolute waste of time any money, that it can only be an outgrowth of someone who believes that duplication of rules is a good thing.  Woe betide all of us if such stupidity is enshrined in our Federal Code. I am opposed to this rule. Pilots are already required to carry photo ID, which can include a drivers license, and the mechanism to provide this already exists. There is no purpose or reason to add such a huge cost burden to pilots, and expand the already overgrown FAA. I am opposed to this rule. This proposed requirement is unnecessary since pilots already are currently  required to carry a legal  photo ID. Adding a photo to a pilot certificate is a complete waste of time and resources that could be used in a more efficient manner.  The pilot community, and the public at large have made it clear that wasteful and unnecessary  government interaction should be avoided and this proposal would be a striking example! These requirements do not help pilots or others involved in GA, do not increase security in any way, and only slow down an overburdened agency with complying to further regulation. A few key points:  1. It\\'s always difficult to forge multiple ID\\'s correctly than a single one. So by requiring a single photo ID now forgers/bad guys can simply forge one instead of two? As an aside any ID that is produced will be just as forgeable as any other ID is, thus rendering any security benefit inert.   2. Anyone flying anywhere needs a driver\\'s license when they land, so asking a pilot to carry a second ID is not redundant, and produces no additional burden on the pilot as-is.   3. As the first two points are obvious, it seems this is nothing more than an attempt to increase fee collection (taxation) through the regulatory process. It\\'s hard to take any government agency seriously when proposals like this don\\'t provide any benefit, yet burden the very activity they claim to encourage.   In summary if there is a legal requirement to add Photo ID\\'s in the name of security, however patently stupid that requirement may be, then the FAA must find a more cost effective solution to the problem.  The need for a photo on our license is not necessary, with the technology available to the average person, if they want to duplicate any security feature it can be done, this is just another way to nickel and dime American citizens to offset the insane spending of the government.  My guess, just like the FAA has done with the registration fee for our airplanes, you will require us to reregister every few years.  And the excuse you will sell the average American who is not a pilot - \"it\\'s in the intrest of safety\".  It is not, it\\'s a way of getting more money out of our pockets while the government spends with no conscience. The pilots already are required to have in their posession a government picture ID.  This rule seems to only propose bigger government, FAA Kingdom building, and raising fees.  This also confirms what was taught in my classes when preparing to instruct other countries govnmetnts on how to develop an aviation oversite system.  The main purpose for the expiration and reissuance is to raise revenue (TAXES).  As \"The worlds leader in aviation\" we don\\'t need to lead in redundance, stupidity, and taxes.  This rule proposes no additional benefit to the flying public, but only serves those in the government who are building their kingdoms, causting the tax payers, pilots, and flying public a lot more money.  Unfortunately, I have little confidence in those proposing this rule.  I have seen it at work.  Those in Washington making rules for aviation often have little to no knowledge of aviation and propses rules such as this or are empire building.  Otherwise they wouldn\\'t feel proposing an additional rule that is already handled by existng rules, especially when it would be at great expense to those whom they claim to be serving. As a pilot, government contractor, and citizen concerned about the wasteful spending of our federal government, I urge this proposed rule to not be enacted.    It will add no value to the pilot certificate nor add any value to the theater of false security the government is attempting to display. Why are we wasting hundreds of millions of dollars on this when we all carry a photo id in the form of a drivers license or a passport or both?  This is typical of the Federal government and the FAA in particular of spending our money on things of little or no value.  This will do nothing to enhance safety or security in the aviation community.  There is no real or perceived threat that this will address.  In other words, this is just more government waste that has become famous.  Just drop this whole idea before you add more hassle from our government that has no value. I feel this would be a waste of time and money. Most if not all pilots carry picture id. already and to waste time,energy and taxpayer money for anther picture id. is dumb. We also just went through getting plastic counterfeit proof pilot certs. I read the entire document front to back and the only benefit to anyone that I could find was in the area on page one titled Authority For This rulemaking. I quote, “…modifications to the airman certification system to make the system more efficient in serving the needs of those enforcing laws related to combating acts of terrorism by ensuring verifiable identification of individuals applying for airman certificates”. Whew! There are 36 words in just that portion of a single sentence. Can’t you people state anything in simple terms.  Since there are no stated or implied benefits for the pilots as a result of the proposed system revisions, I think that the entire cost of the new requirements should come out of the budget of the government agency that might benefit from the revisions. Namely the Homeland Security bunch.  I also wonder why you people cannot use the photographs and thumb prints already available at the various state motor vehicle departments. This information has been serving state, county, and local law enforcement agencies for many years.  I am a commercial pilot who is collecting ratings every year or so and would like to continue to do so.  The cost and hassle of obtaining a photo ID pilots license that provides zero additional security simply another burden on an already over regulated segment of industry.  While providing no additional security it will simply continue to drive the number of pilots down and make aviation more expensive for everyone including the consumer. License every entity, tax every breath and activity, prohibit independent thought, silence all resistance and invade every constitutional right to privacy.  That\\'s not the way that our founding fathers did things.  And if it is not stopped, America hasn\\'t got a chance at freedom in the future.  But people never seem to learn.  The modern mentality that says rights have been replaced by privileges that are granted only by government will enslave the very people who are pushing all of these new programs in everything from bio-metrics and microchip implants, to ADS-B for closer monitoring of aircraft, to TSA sexual molestation of the public and total control and taxation of every move.  For my own safety and the continued freedom of my fellow countrymen, I want to be on record as being against all such legislation as this.  I hope that if there is any common sense left in the U.S. government that it will be applied. Comments to Proposed modifications to rules for pictures on pilots docs (FAA-2010-1127)  This proposed procedure and its associated costs both financially and productively serves no practical purpose. FAR already clearly state that a Pilot must have in his possession of government issued Photo ID while exercising the rights of his/her license. Any move to further create additional costs and roadblocks for the aviation community is counter productive. This proposed rule would NOT enhance any form of security. It would NOT create ANY benefits to any involved person. It would add additional costs to Pilots, the FAA and the public at large. The minimal amount of additional \"Convenience\" of not having to carry a second form of ID is an almost mute point based on the fact that almost all Pilots carry either a state issued DL, a DOT issued security pass or a passport.  I would STRONGLY suggest the reviewers of this proposed rule make every effort to thwart the attempt to cause additional hardship and costs that result in very little or NO benefit to any person, agency or security concern.  This rule SHOULD NOT be adopted and should be terminated.  Don Keylon I recognize that the reason for the new rule springs from an external requirement being imposed on the FAA, but this change seems utterly pointless.  It does nothing substantial to improve security, and I think both pilots and the FAA should push back on the legislators and other experts proposing this change.   We pilots are already required to carry positive government-issued ID when we exercise our privileges.  We, of course, already comply with this requirement.  Adding the same credentials into the pilot certificate just duplicates the material we must already carry.   It also wastes a tremendous amount of money.  Unlike driver\\'s licenses that must be renewed, pilot certificates do not expire.  Given that this change adds no useful security to the existing system, there\\'s no reason to add information (a photo) that must be updated periodically.  All that will do is create more expense.   And whom are we defending against?  Pilots who must already undergo background checks?  And many of whom already are in direct control of tons of machinery overhead?  What precisely is the threat model that we\\'re prepared to spend nearly half a billion dollars to defend ourselves against?  Is there any instance in which this new system would stop a criminal act, but where the existing system would not?   We need real security, and not just theater.  Unfortunately, this proposal doesn\\'t enhance security in any obvious way. This new rule is absolutely ridiculous. It is nothing but another fleecing of American pilots. I have been instructing for 32 years & this make no sense whatsoever. It has no merit & would serve no purpose with regards to security issues. There is already a way to have a photo Id issued by the government. It is cheaper and a lot easier to get. The passport card would be a lot better way for ids. Any post office and a law to carry it on airports or planes would take care of this problem. I am against this ruling. This requirement would force me to travel a minimum of 150 miles, one way, to get a photo taken for a document that has no real identification use. It raises cost by more than triple the current amount for no effective increase in anything but hassle. There is no rational reason for this rule.  I am completely opposed to this rule.  It does not provide any additional security and in fact just increases the cost of flying for pilots.  Nothing proposed here would have prevented what happened on 9/11.  In case you were not aware, by their very nature, criminals are not all that concerned with breaking laws.  The only people that you will be affecting with this rule is the honest pilots out there. The proposed rule requiring a photograph on pilots certificates is not necessary since we are already required to carry a government-issued photo Identification card.   It seems to be just one more expense with no benefit.   Since Flight attendents are not included in the current proposed rule, it only stands to reason that they will be subjected to this same type of thing in the future. That will require the expenditure of more money for something not needed to start with..   Thanks Thomas E. Cartier I am strongly opposed to this rule proposal. It is not going to make airport and pilot operations any safer. It will cost us a LOT of money. It will make pilots\\', instructors\\', and pilot students\\' lives a lot more difficult. 1) We were just required to obtain a new plastic certificate.  Why was this not implimented then?? 1a)  I assume there will be be no cost implication. 2)  This is another requirement for 99.9% of law abiding citizens having to accomodate a government who refuses to effectively profile known potential threats to our national security, which would virtually eliminate the threat.  Based upon ALL current indications, a photo ID bearing resemblance to a \\'twin towers 911\\' pilot would grant the individual a free pass anyhow.  Enough already!  High time to wake up! This isn\\'t going to provide any more security of people operating aircraft than the bar code info on the licence itself. Rather than make it manditory for a \"photo I.D. Why don\\'t you make it manditory they can provide either a passport, Drivers licence or other document that they use like international I.D. so you don\\'t hyave to pin it on the pilots.   This ploy is just another example for \"EVER EXPANDING GOVERNMENT TO EXTRAPOLATE MORE UNNECESSARY FUNDS FROM THE PEOPLE\" ! MANAGE FUNDS CORRECTLY THEN YOU WON\"T HAVE TO BEAT IT OUT OF THE HIDE OF EVERY AMERICAN  TO SUPPORT DEFECIT SPENDING!   This rule is superfluous and therefore ridiculous.  We pilots are already required to carry government issued Photo ID when we fly.  Therefore the pilot certificate is useless on its own.   Building the photo id into the certificate is just an expensive replication of work.  This won\\'t make us any safer.  It will just be more paperwork and more money to change the whole system. I objsect to the proposed rule based on the cost to individual pilots.  I feel that simply requiring pilots to carry some government issued ID would acomplish all that is necessasry for added security.  Most everlyone has some sort of Gov\\'t issued ID today.  Most everyone has a driver\\'s license and the states will issue a photo ID to someone who does not drive.  I feel that this minimal change would accomplish all that is necessary. In my humble opinion FAR part 61.3 is sufficient as it requires pilots to carry a photo id.  This new requirement may just discourage people from keeping/getting their license. It will not increase security in any way. It is just added expense for both the government and pilots. It is a solution to a non-existent problem. It makes no sense to have student pilots get plastic cards for several reasons, including endorsement of CFI for solo operations. The current system works fine. There are so many negatives they eclipse any possible positive. Here is a chance for the FAA to step up and protect the aviation industry by putting a stop to this unnecessary and potentially very expensive regulation.  Thanks for your time and the opportunity to comment on this proposed regulation.  We have regulations requiring pilots to carry a picture ID and this new rule is redundant. It would cause hardship on pilots in a bleak economic time. The additional government cost is unnecessary. I am totally opposed to passage of this rule. I think there are enough hardships on aviation that adding more is not the answer. What are we trying to fix? It looks like to me it\\'s just another way to raise revenue. No one is against having pictures on their license, we are against the added fees, hassles, time, and burden put on the pilots to do so. We have pictures on drivers licenses that will do just fine if needed for a photo ID\\'s. We are struggling financially to be able to fly and this will just add more hardship. And for what reason? Enough taxes and fees! In my opinion the proposed rule will unduley increase pilot cost and agency red tape. Pilots have photo identification in place from other agencies. I fly for a living and see no need for this. Leonard Marden The intent of this proposed rule can be satisfied by requiring all pilots to possess a valid government issued photo identification such as a state drivers license.  Creating a system to generate a new photo identificateion is a duplication of effort.  Requiring the the current pilot certificate to be accompanied by another government agency\\'s photo identification would cost zero.  Don\\'t try to fix what ain\\'t broke!  Don\\'t add to the burden the FAA already carries, they don\\'t need a higher work load. This is unnecessary. Currently, We are required to carry photo id issued by Government sources. This is a waste of resources to satisfy a requirement that is already being met. Nothing can be gained at all from this rule. Please retract it immediately. This rule is redundant and provides nothing towards security and everything towards creating another level of beauracricy that will drive more people from Aviation. The costs to the pilots are grossly understated and are more on the lines of $250 per licenses.   At this point we are required to carry a Government issued Photo ID with us when we fly. We have also been required to get the new plastic licenses. These steps are enough to provide positive ID of pilots.  In these times of trouble do not waste hundreds of millions of dollars of taxpayers and pilots funds to provide a \"feel good\" program that is redundent and creates nothing but more government and no additional security.   John Majane I might be in favor of this proposal IF I could see any benefit in it.  I cannot!!  Most of  us already have numerous photo IDs which can be used to supplement the requirement.  This is nothing more than another unfunded government mandate which accomplishes nothing.  We do NOT need this! In detail, could the agency please explain exactly what purpose this serves that the current requirement of carring a GOVERNMENT ISSUED ID and the FAA issued pilots license does not? In particular, please explain the complete administrative  cost associated with this and the benefits that will be realized by the public, and elaborate on what benefits the pilots will receive for their expenditure here. Could not it be just as effective to educate all proper authorities that are empowered to ask to see such identification to simply also be reminded that a pilot is already required to to carry a government issued photo id, and that they should ask to see that also? Would this be above their pay grade or competency levels? WIth budgetary concerns already, may I ask how the agency is being a steward of our funds here? I  would like to see implimented sooner. Such as; (1)first time student pilots immediately. (2)established student pilots, ATP pilots, Air and Ground Instructors = within 6 months. (3) Commercial Pilots = within 12 months. (4) Private Pilots, Mechanics and \"all others\" that require a FAA license = within 18 months. I also think each person be required to submit one finger print from each hand,  preferably thumbs, unless missing..  Thank you, Curtis Martin, Farmington, NM Photo requirements for Pilot Certifidates will not add any security as all Forms of ID can be faked with today\\'s technology. The requirement will only add to the cost and administrative burden of FAA records section as well as cost to the pilot. We already carry photo ID\\'s to support driving, banking, boarding airlines and entering the country. This would be just another unnecessary government regulation requiring the hiring of more personnel to enforce it. This regulation does nothing to enhance security.  All pilots are currently required to carry a govt issued photo identification.  The identity of pilots of lawfully operated aircraft is never in question. If a person is purposefully operating an aircraft in a manner to conceal his/her identity, a requirement to carry a photo embossed pilot license will be certainly be disregarded. The only result of this regulation will be to increase the burden on aviators and increase the processing time for airman certificates.    This regulation SHOULD NOT be enacted. Pilots are already required to carry a photo ID. The time, costs of travel, and government expense to duplicate existing regulations will impose an unecessary cost on this select group equal to a half a billion dollars over 10 years. Aviation is already strangled with government mandates that have cause its cost to increase at twice the rate of inflation over the last 50 years. These costs are causing economic hardship and the shrinking of the important general aviation industry that currently employs over a million people. A number well below  just a few years ago.  Use efficiencies and connect the dots by using passport photos and technologies that incurr zero costs on the aviation pilot tax payer. If the government is not efficient enought to do these simple things abandon duplicate feel good regulation that does nothing to accomplish intended purposes. The cost of this proposed rule is exceeds any value it may have.  Other government issued photo ID is currently readily available.  The current requirement of carrying that with the pilot certificate is clearly sufficient.  The additional cost of complying with the proposed rule for Certificated Flight Instructors will cause many to allow their certifications to lapse.  I am a flight instructor that may well give it up rather than pay the increased cost of maintaining my flight instructor status.  Times are tough: increased costs just to maintain status quo may drive many out of aviation all together.  The pilot population is decreasing as it is.  Please do not implement this. i AM ABOUT TO COMMENCE TRAINING FOR MY PRIVATE PILOT\\'S CERTIFICATE, AND THE EXISTING TRAINING COST IS A SEVERE BURDEN THAT i MUST BEAR. THE ADDITIONAL COST OF COMPLYING WITH THIS PROVISION IS SIMPLY UNAFFORDABLE, AND IS UNFAIR.   THE LACK OF A LOW AND MODERATE INCOME PROVISION TO AMELIORATE THE COST BURDEN BEING IMPOSED IS UNACCEPTABLE - YET THE FEDERAL GOVERNMENT HAS MADE NO PROVISION IN THE GOVERNING LEGISLATION THAT SPONSORED THIS REQUIREMENT THAT ADDRESSES FINANCIAL HARDSHIP TO LOW INCOME EARNERS.   This new rule is redundant.    The current requirment that all pilots must carry some sort of photo ID while exercising their rights to aviate already complies with the intent of the Intelligence Reform and Terrorism Prevention Act.   This simply adds an additioanl financial burden and task to the pilot community without enhancing security. Having just completed the reading of this rule, I saw absolutely no justification for it, other than a method to increase the bureaucracy and the increase of budget and personnel to go with it. It does absolutely nothing to increase security.  We are already required to carry a Government identification with our picture in order to exercise the privileges of our pilot certificate. I am beginning to understand what it is like to live under a \"Police State\" where everything and everybody is regulated until all freedom and individual responsibility is gone.    Freedom is very precious and once it is lost...it is lost forever.   In all seriousness, anyone in government who believes this proposed rule should go through as written is an idiot. Aside from the incredible assumption that someone should have to drive no more than 100 miles to pay $22 every 8 years to get a picture of themselves on their pilot license (!), has anyone seriously considered the complete lack of necessity for this rule to the thousands of grass roots pilots like myself? We live in the middle of nowhere, fly about 25 hours a year, almost never go to an airport that has a control tower and many times don\\'t even have a radio in our aircraft, thus never communicating with ATC. But a picture of us on a license that stays in our wallet and is never seen by anyone but our spouse is going to make America safer? As I said, anyone who believes this is an idiot. Aviation is already overregulated. Additional regulations should only be imposed for reasonable measures. My picture on my license will not - I repeat - WILL NOT make any difference to the war on terrorism WHATSOEVER!!!! If \"someone\" in \"government\" feels this is important, figure out why. Do we have imposters at the large airports showing up to steal airplanes? Then address that. But treating every single pilot in the United States like a potential terrorist/criminal is counterproductive. This is just one more nail in the coffin of lagging numbers for new pilot starts. EAA is trying to encourage new pilots. Rules like this encourage existing pilots to shrug their shoulders and say it\\'s time to throw in the towel. The point is, while one group is trying to revitalize aviation, government regulation drags it down. Think about what you are doing. Eliminate this proposal. Leave pilot licenses the way they are. Thank you for the opportunity to comment.  Why is the FAA trying to create an issue when there is not one?  I am 110% for safe and secure skys.  How does this make our skys any safer?  Why not simply require a pilot to have on his/her person a \"government issued photo identification\" in addition to his/her pilots license?  A military ID, a State driver\\'s license or identification card, passport, etc?  How many pilots do not currently have some sort of government issued identification? I would guess less than one percent?  This would easily solve the photo issue at zero expense to the vast majority of pilots and could be implemented immediately with one line in the FARs \"When excersizing the privledges of the airman\\'s certificate, the airman must have in his/her possession a government issued photographic identification card.\" To Whom it may concern,  Upon reading the NPRM to require pilots to obtain new photo identifying pilots licenses, I would like to express my objection to this proposal.  We currently are required to carry a government issued photo identification with our pilots license, and do not see where this proposal can improve security, but will simply burden pilots with further challenges of obtaining and maintaining a current photo identification.  Further this simply is a waste of the funds spent to transition to the current plastic \"Wright Brothers\" license a process which has just been completed less than one year ago, as well as the significant expense of issuing photographic pilots licenses.  I feel the funds and manpower required to implement this proposal would be better spent in other areas.  I therefore respectfully request that this proposal be dropped as an ineffective expenditure of funds.   Very Truly Yours, K. Alan Uhler, Jr. The proposed rule for photo ID is already covered under existing with out the pilot having to pay over $200 per to compy with this rules. There is no economic benefit. only the pilots have to shell out $250,000,000.  I suggest you trash this As an ATP Pilot, I already have an Encrypted Military ID, A State issued Drivers License and credit cards with my photo.  Now a wasteful bureaucracy wants more infrastructure, staffing and money to justify their existance.  More Waste, Fraud, and Abuse.  I hope that the new congress gets ahold of this.    The government does not need an ID to keep the terrorists and radicals in control. This is absolutely a waste of time and money.  Don\\'t you dare do this Photo requirement.    I see this proposed rule as old and redundant.  Pilots already have to carry a driver license, airport badge and, in some cases, company credentials all with photos.  This requirement would not make flying safer in any way and only adds to the financial burden of flying!! I think it is another way for our government to make more money because of poor spending habits of our senators and representatives.  I am totally against this rule! Please, do not insult us anymore by trying to pass this photo i.d. proposal off as a safety issue.  As you know, we already have a photo i.d. in our possesion when we fly.  Remember, if you want less of something you tax it.  This is nothing more than an addtional tax on general aviation and will further shrink an already dying industry.  Please, at least come clean, and tell us the truth why you are doing this.  I just hope you aren\\'t intentionally trying to kill one of the few industries in the world that we still dominate.   This is not going to stop terrorism of any kind. It\\'s just another power and money grab from our out of control government. If I have a driver llicense with a picture on it how could putting my picture on my pilot license possibly make things more secure? Just another $22.00 for BS regulations that doesn\\'t solve a thing. As a licensed private pilot (Cert# 2798055) I have to express my strenuous objection to the proposed photo requirement for pilot\\'s license. As usual, this is simply another way of a government agency to \"feed the kitty\" as this requirement will serve no useful purpose other than the forementioned. Most (if not all) pilots already carry a photo ID in the form of their driver\\'s license and having a second photo ID will not enhance security in any manner.  $22. X 500K pilots = an easy $11M! As is the case with all other fees, this will only increase on renewal and is simply a way to glean more monies from the dwindling GA community of pilots. More government control is the only purpose for which this proposed rule is being created and nothing more than that! Suggest that the TSA (which is the driving force behind this ruling) do some real work and earn their money like the rest of us. It would be very difficult and costly to have all pilots get their photo on their certificate. Why not just require that the pilot carry a form of official government procured I.D such as a driver\\'s license with them when they fly, just like we do with our hunting and fishing licenses. It already has a photo of the individual  on it. :EmRTMENTOF :-NSPORWION :K£T OPERATIONS Docket Operations, M-30; n^,, rr-R iii o n -in U.S. Department of Transportation \\'\"\\' \"^° \\' ^ H z^ JU 1200 New Jersey Avenue, SE. Room W12-140 West Building Ground Floor Wasliington, DC 20590-0001 Subject: Docket # FAA-2010-1127 Photo Requirements for Pilot Certificates Dear Sir, I presently hold a Commercial Pilot\\'s license, and Airframe and Powerplant (A&P) repairmen\\'s license and have Inspection Authorization (lA) for airframe and power plant. I believe the requirement for a photo ID for pilot\\'s licenses is not necessary for the following reasons. 1. The present ruling in effect requires pilot\\'s to carry a plastic pilot\\'s ID card along with a goVernrr^ent issued photo ID card such as a driver\\'s license. 2. According to the FAA, the FSDO\\'s are already short handed. The additional time required to implement this ruling would place an additional burden on an all ready taked system. 3. The time required to obtain a photo ID by pilot\\'s and flight crews would place an additional, time consuming, burden oh\\'them\\'.^\"\"\" \"\\' \"^ \" \\'^^\\'\\'\"\" 4. The pilot shortage is projected to be critical in the not too distant future. This expense would place an additional financial burden on all pilots, especially for flight instructors, who don\\'t make much money anyway, and for students, many of who are all ready strapped for money. The present requirements are more then ^deq[uate and have been implemented successfully for a number of yeafs\\'. \\'\\' Ł ThankS^dd,-lichaeTR. Elite POBOX1575 Friendswood, TX 77549    ˘ˇˆ˙˝ ˛˚˜˜ˇ ˇˇ˝ ˆ! ˇ ˇ\" !ˇˇ˝˝˘ ˇ#  #ˆ#  # ˆ˙˝˝ $˚   ˇ   ˇ˝ ˝%%˝ ˇ˝ˆ  &  ˇˇ˘ ˇ  \\' ()*ˇ+\\'(),˝ ˇˆ!\\'()˝  ˇ ˇ-   ˇ\\'ˆ!*ˇˇ ˚˜˜ ˝ˇ./01%0 -˝ ˇ ˇˆ ˚˜$2˜˝*ˇ  ˇ  ˇ ˇˇ ˘ˇˆ!˘   ˛ˇ˝  +314%/34,ˆ! *ˇˇ   ˇˇˇ  ˝  ˆ!˝ˇ5 ˘ˇ ˆ ˜˝ ˚6\\'\\'()   ˛( ˇˇ  6\\'ˇˆ  &7(2&ˆ ˜*ˇ.14˝˘ ˇ    ˆ˚   ˝8%.˝-˝ˇ ˝ ˇ ˆ&  ˇˇˇ  ˝ˇ ˆ7  -%%  ˇ ˘ˇ ˚˜˜  .14˝˝ˇ ˇ5ˆ& ˇˇ 5-˛  ˇ ˝ ˘   ˇ%\\' ˆ˚˜˜˝   ˚˜˜˝ ˇ  ˇ\\'˝˝  ˆ!ˇ ˇ ˝ˇ   \\'()˚˜˜ ˆ !-- ˇˇˇˇˆ  9ˇ˙  02/17/2011 13:24 FAX 7604465180 1002/003 \\'0/VS Sheldon K. Siinonovich /5\\'i rep , ^ PO Box 2227 \\' \" \"\\'\"\\'\\' \\' \\' ^ 3:5 s Ridgecrest,C;ilifoniia 93556 15 February 11 Re: U CFR Parte ei and 163 (Docket No. FAA-2010-112< Notice No. 2010-16] RIN2120-AJ42 Photo Requirements for ilot Certiftcatas The FAA had leas such as the means terrorists used on September 11,2001 but dismissed them as imj jssible or improbable. It ignored other signs also, as did thu FBI, etc. They are undei fire now for allowing the airlines to get away with mainterance and other things the FAA was si ^posed to supervise and regulate. This has gone on for decades now. Congress and < ir presidential administrations have totally ignored the problems caused by illegal aliens in the :ountry in huge numbers. Now, rather than take action against them, however, we natuial-b )m Americans are treated like criminals by those such as congress, tihie administration, the FA V, TSA, etc who have abdicated their responsibilities and leadership to pander to a bunch off feigners, aliens or whatever you wish to call them. Our government policies even encouraj 5 our enemies and create new ones, I spent over 23 ^ears in the US Marine Corps defending this wonderful country plus another twenty-some; ;ars in weapons development while the lawyers and politicians have worked just as diligeni y to give away our country. Many of those doing so were draft-dodgers and/or just plain venal Our country today is the only one of about two hundred with absolutely no concept of sovereif ity which even the most illiterate and uneducated person anywhere else in the world understands It is a license, j ist as doctors and lawyers hang on their office walls proudly, as they should, but how do we know for certain the person is even the one indicated? I am sick and t %d of being treated and considered like a criminal by those in power who often are. .People who or good reason cannot trust themselves don\\'t trust others. When lawyers ind doctors get their photographs on their hcenses, then perhaps I\\'ll change my mind but fi r the time being, I fail to see how my picture will save the 1 A A, TSA or any other incompetent organization by pulling their irons from the fire. We pilots are tired of being considered as cr tdnais-to-be while the government ignores the real problems and usually is part of it. We also d« n\\'t want to have our pictures on every piece of paper we o^vn. No doubt there eventually will b a popularity contest among the various photo IDs in our pockets once the US Gestapo really get joing. There also is tl- ; matter of stealing our money for dubious benefit - periodic renewal. First, $22 per photo lie ;nse is too much. Our FSDO, by the way, is about 155 miles south of here - a three-hour drive to he LA area assuming no heavy traffic but of course the FSI>0 isn\\'t open at 0300 so that would 1 e an unlikely easy drive. Then there is the return trip Of course we c lUld fly there but parking your plane is expensive at the FBO even if the weather is good enoug i and Ihere is no TFR in the area. Flying there makes sense but what if the FSDO doesn\\'t issue th new license for some reason? Now what; how do we get home? You 02/17/2011 13:24 FAX 7604465180 1^003/003 cannot just walk into; FSDO either, you will recall, so it becomes much more inconvenient for us if easier for you to iemonstrate your officiousness. People alread) are screaming here in Cahfomia because we don\\'t drive 100 mpg cars and so we add to fuel cons nnption (w/o tax break), pollution and time wasted to get our pictures taken. Don\\'t ignore th possibility of exposure to accident, drive-by shootings or other mishaps that could ruin your d; y even if you are not killed in some of the heaviest traffic in the world. I feel strongly hat this photograph on the pilot hcense is just BS & black magic with large cost to us and vi cually no benefit to the country. jdihci^.f y^^^y^-\\'^ Sheldon K. Sir lonovich 1464524 Commercial pi ot ASMEL SL glider; CFIASMEL, ASES and CFII Instrunient - Airplane Owner of two \\'essnas, one Mooney and one Piper Apache Flying since 1! 56  ',\n",
       " 'I fail to recognize the problem that this proposed rule will solve.  Current regulations already require that pilots carry a government-issued photo ID.  Requiring the FAA to issue pilot certificates with photo IDs will add regulatory burdens to the FAA, further burden pilots, and add cost with no equivalent benefit.  Adding unnecessary and redundant requirements undermines public confidence in regulatory agencies and support for measures that are truly needed. It is ridiculous to propose to charge $22, or more, and possibly a fee to a designated examiner for these pilot certificates with photographs. I\\'m assuming that this fee, or more, would also apply every 8 years when the photo needs to be renewed. If the government is requiring them, and pilots certificates should have a photo like a drivers license, the government should absorb the cost. Otherwise, this is just another revenue generating scheme or another tax. By the way, I currently hold an ATP certificate. What terriorist has used his certificate to gain access to any aircraft and then use that aircraft to threaten or endanger the public of these United States of America.  None of them.  The terriorist or law breaking section of the public will not have to get a cartificate with thier picture to gain access to aircraft to complete thier mis-deads.  This will only cause undue expense and trouble to the law-a-bidding section of the public and will not in any way stop or even slow down the people that intend to do harm with an aircraft.  It is just another way to over regulate an industry that has already been hit hard by the terriorist attcks. It is usless to put a photo on the certificates when everyone already has  to have another form of ID to get a cartificate in the first place. Just require every one to have a photo ID in thier possession in order to exercise the privledges of thier certificates.  No one except the FAA and one, out of state  FBO, where I was renting an aircraft has ever asked to see my cartificates. Below the ATP level this proposal will do nothing to increase safety or security.  It would be a non-value added additional cost.  It\\'s administration would distract from other more worthwhile activities.  The FAA and the TSA have not provided credible documentation where the current pilot certificates have been inadequate in protecting the public\\'s safety.  Further, neither agency has provided a reasonable justification for how this proposal, compared to the existing certificates would significantly facilitate safety procedures at airports.  To me, this sounds like a solution that is trying to find a problem.  \"If it ain\\'t broke, don\\'t fix it.\" I am opposed to the proposed change in pilot certificates.  The temporary solution made sense in that it combined two existing forms of identification to provide some assurance that I am really me and that I am permitted to operate an aircraft.  The new certificate seems to be redundant.  To get the new certificate I would have to present my old one, my drivers license (issued by the State of Ohio) and my passport (issued by the Federal Government).  There would be no additional proof of my existence than already exists.  Why do we need this extra form of ID.  I suspect that my passport already includes or references much more about me than I would be comfortable with.  What more could you want?  I protest any cost to provide the information that you (local, state, and federal governments) already have, just in another form.  It should not be my burden.  Repeating the effort to identify me three times is not necessary and I hope that this can be avoided.  Thank you, John D Price The NPRM says “The cost of issuing these new certificates is substantial.”  In light of the need to reduce government spending, these requirements could be suspended until the deficit is eliminated.  There would be no loss in safety of flight or security.  Comments invited on Photo Requirements for Pilot Certificates.  Docket FAA-2010-1127  (1) identity verification: fraud-resistant documents are already required by TSA for a student to begin training and for pilot certificate processing by the DPE.  Drivers licenses are accepted by DPE, and passport or other proof of citizenship must be presented to the flight instructor to begin instruction.  History hasn’t shown a problem with confidence in the identity verification process.  (2) Let everyone continue to comply with14 CFR 61.3(a)(2) until a triggering event occurs.  The regulation will provide the same identity verification that IRTPA desires.  For ATPs, a type rating will most likely be added at sometime in a career.  So let that be the triggering event whenever it occurs.  For Flight instructors the CFI renewal every 2 years will certainly take care of it.  While many commercial pilots may not have a triggering event for the remainder of their flying career, a significant portion will be upgrading.  Again let 14 CFR 61.3(a)(2) compliance take care of IRTPA concept.  For private pilots, adding an instrument, multiengine, float plane rating will trigger.  For those that don’t have a triggering event, most will probably be giving up flying because of the increased cost.  Let them continue to use 14 CFR 61.3(a)(2) for identity verification and let attrition reduce the number of pilots who don’t have a photo pilot certificate.  (3) The identity was already validated when the pilot started training as required by TSA and again by the DPE when the checkride was given.  Perhaps notaries public, recorder of deeds, passport officials at POs, or other local officials could be used to look at the ID and the individ While features to make the forging of certificates are welcome we need to avoid requirements that do little toward achieving that goal.  The requirement to add a photo to pilot certificates will not stop those who are forging certificates. It will not likely even reduce the incidence of forging by any meaningful degree. The proposed rule for adding a picture to pilot certificates imposes significant new burdens on pilots (both monetary cost and time required) while offering very little (if any) security improvement...   Other existing forms of identification, such as a driver\\'s license already provide photo verification of identity- why the need for an additional photo on a pilot certificate?  It would be much simpler to focus on requiring a pilot to carry accompanying acceptable photo identification in the form of valid passport or drivers license.  FAA issued a Notice of Proposed Rulemaking (NPRM), Docket No. FAA-2010-1127, Notice No. 2010-16, entitled Photo Requirements for Pilot Certificates  This is not needed. we already have a Drivers License which has our photo on it. This would be a waste of money. Let\\'s solve problems, not create more of them. No, we do not \"need\" yet another Government Photo ID Program.  The FAA Budget does not need to be used to create an additional Photo ID Card. Most pilots already have a Government Issued ID that can be used; if not, as a minimum, States issue Photo ID\\'s to people without Drivers Licenses (Caution. California issues ID\\'s to Illegal Aliens/Immigrants). Passports have been used for ID\\'s for Pilot Trainees for some time now, so those could be used to answer the Photo ID requirement/concept.   No matter what you decide, The Design of the (new) Current Plastic Pilots Certificates/Licenses Needs to be Changed as follows:      1. The nice/cute historic aviation picture background masks the printed Pilots Info, which fails to show clearly when the Certificates are copied for/by local FBO\\'s, Insurance Companies, or Flying Clubs. The design needs to support being copied.     2. Ratings and Limitations are on the back. They need to be on the Front with the Name, for use by the same entities as indicated in 1. above.       3. Please Fix the Design of the Plastic Licenses with some of the funds intended for the Photo ID Certificates.   Thanks,  Bill Sanders CFI & Flying Club President This requirement has no benifit for the pilot over current and existing regulations. There is no benifit for the community at large as well. This regulation needs to be discarded. If the desire is to listen to the IR&TSA as well as Rep John Mica they need to go back to the drawing board and think about what they really trying to accomplish. There is no material improvement gained over the current means of official identification, by requiring a photo on an airworthiness certificate.  The only changes will be in terms of expense and resource usage.  When I am stopped by a policeman, I have to surrender my driver\\'s license, which has a photo on it (admittedly speaking, Vermont licenses only don\\'t have photos).  If I were to receive a ramp check, I would have to do the same.  Are two thumbnail photos better than one?  I think it would be more meaningful to require the states to conform, so that all individuals with official identification have photos on their IDs.  And in so mandating this, wouldn\\'t airman certificates with photos be obviated?  This is a dumb, expensive and unnecessary proposal that is going to give some people money that they don\\'t deserve. What problem is this measure trying to fix?  Has criminal/terrorist activity been detected trying to use stolen pilot certificates?    While trying to comply with the IRTPA, it appears that another bureaucracy will be created in order to manage this program.    With the same funding, I suggest that random ramp checks would go farther to detect fraudulent use of pilot certificates than merely putting photographs on certificates.  This measure would also probably increase overall aviation safety.   Requiring photos on pilot certificates is a waste of time and valuable resources, not to mention the burden on pilots. We are already required to carry a valid government photo ID. A pilot is subjected to background checks, fingerprints, and photos through the government ID process already. Having the photo on the pilot certificate is just duplication and a huge cost and inconvenience to the airman. As a part time flight instructor, I am very concerned about the additional burden placed on pilots and instructors to add photos to certificates, especially since as a flight instructor, new students are already required to provide a government issued photo identification, such as a passport or driver\\'s license. Therefore, since another photo on a flight certificate is a duplicate effort by the FAA, following are several considerations that I believe will relieve the cost burden for both the FAA and pilots: 1) As both pilot and flight instructor, the only individuals who ever view a flight certificate are typically flight instructors, designated examiners and employers.  Since in all preceding cases another form of government ID is required in addition to the pilot\\'s license, this is a duplicate and needless effort.  Renewing a photo that no one will find relevant seems to add an extra unnecessary cost for a function that is currently filled by other government agencies.  Therefore setting an expiration date for photos does not have any relevance and adds an additional cost to both the FAA and pilots. 2)  Since Flight Instructor Certificates are not the same as flight certificates (are held in addition to flight certificates), I propose that photos are unnecessary for any certificates in addition to the pilot\\'s license itself. 3)  Since photos are easily stored digitally, I propose that any time a renewal or replacement is requested, the FAA use the most currently stored digital photo rather than a new photo.  Since the date of the photo is not relevant as mentioned in point 1 above, this step will save both time and cost. Thank you. I am a commercial pilot and aircraft owner and oppose this proposal.  Current regulations require a pilot to carry a current government issued photographic identification when they are exercising their pilot privileges. (See 14CFR§61.3.a(2).)   A  passport or drivers license accomplishes the needs for a photo identification and is more efficient for those who hold multiple FAA certificates. There is no meaningful reason, in terms of aviation safety or homeland security, for this proposal to be seriously considered for approval. Rather than create more bureaucracy by requiring a pilot license with a photo, why not just enforce FAR 61.3(a)(2), which requires a pilot certificate holder to also have a valid photo ID in their possession? The entire U.S. pilot population presumably already meets this requirement today, without any extra burden to them or to the agency, which would have to set up–at great expense–new infrastructure to be able to issue pilot licenses with photos. Pilot certificates with photos, as proposed by this NPRM, would also provide no discernible additional security over the requirements of FAR 61.3(a)(2) and the already-existing forgery-resistant plastic pilot certificates. Simply put, this NPRM is a regulatory power grab by the FAA that would not provide any security enhancements and instead would only increase government bureaucracy. We have each paid for a service with a state identification card. It is updated and thorough and more than adequate to supplement any other certificate. It is a personal burden both in time and cost to be forced to repeat the process and it is an insult to the taxpayer who will fund it. The knowledge of extreme security measures and added regulation undoubtedly is a major contributor to our loss of flight applicants. The uncertainty of obtaining a secure and unlimited certificate is discouraging to would-be students considering the cost and effort they will bear to obtain it. Additional regulatory burdens on student pilot certificates can only serve to interfere with the timely progression of flight instruction. Disgruntled or inactive pilots and instructors inadvertently pass on their cynicism to the nonflying public as it is increasingly difficult to defend these kinds of decisions. I am beginning to view my own certificates as magnets for personal Federal abuse and I am rapidly approaching the point where I can only say, “Stay completely away from aircraft!” December 03, 2010  US Department of Transportation Federal Aviation Administration Washington, DC (Submitted via electronic comment services @ Regulations.gov)   To whom it may concurs:  The FAA is proposing the addition of photographs on US pilot certificates and I feel that the addition of a photograph is an excellent idea.  It is long overdue and would increase the overall safety of GA flight / pilots.  However, I would recommend changing the proposal in the following ways:  1)  As the lack of a photo on current certificates is clearly an oversight by the FAA, the replacement certificates (with photo) should be issued to existing certificated pilots, free of charge.  Pilots spend an inordinate amount to get and maintain their certificates - this would be unfair burden to those that have already paid their dues.  2)  New certificates being issues, after the policy should take effect, would incur the same charge as with any state drivers license or passport identification.  3)  The existing organizations that supply driver\\'s licenses, passport photos and/or other government identification should be capable of handling paperwork and completing the photographs - this license should not require any special services.  These would be, but are not limited to, US Post Office, US Passport Offices, FSDO, Driver\\'s License Centers.  4)  The identification should qualify as government identification and would qualify for TSA Checkpoints, for example.  5)  Allowing Designated Pilot Examiners (DPEs) the ability to issue and validate these certificates is a clear security hole and should not be allowed.  There is sufficient policy in place for this type of identification.  Thank you for your time and consideration.  \\tSincerely,   \\tChristopher Ross \\tCommercial Pilot, CFI One good thing I read in this rule change is the fact that student certificates will no longer expire (until the photo does anyway). I think that is a helpful thought for student, although it will be overshadowed by the major inconvieniance of having to get the photo in the first place. Doing this every 8 years seems unnecessary to me and a waste of money. What does this new proposal intend to solve? I don\\'t believe there is much, if any, addtional security being accomplished. If a terrorist is going to use an aircraft, I highly doubt they have a certificate in the first place, or would be concerned about a photo or when it expired.  Are there instances of certificates being stolen or other acts that this will solve?  I believe the AOPA and BFA organizations should have a chance to speak on this issue if they have not yet done so to voice pilot\\'s concerns.  I believe the intention of this change is in good faith, but I ask, what does it really accomplish? This regulation is preposterous.    First, pilot certificates already must be accompanied by gov\\'t issues photo ID. So we already can identify a pilot visually and putting the photo in the certificate is just duplication of effort.  Second, pilot certificates barely ever get looked at, due to the nature of flying.  Making those more \"secure\" doesn\\'t really achieve anything.  You think a \"bad guy\" wanting to steal or hijack a plane will be concerned about producing identification after the fact to an FAA ramp check?  Please spend your time in something that is actually useful.  This is a boondoggle.  As a flight instructor, I am extremely concerned that the proposed rule for student pilot certificates, as well as flight instructor certificates will have a significant negative impact on the future not only of my business, but also that of other flight instructors. I recognize the need to comply with the Congressional mandate, but there needs to be a way for flight instructors to not have to upgrade their pictures every two years. The costs for doing this, while perhaps not significant to an airline captain, are quite significant for a flight instructor who might make $2000 a month (probably the high average around here) - with a significant portion of that going to living expenses. It will also likely discourage a number of fine American citizens who are interested in flight training with high start-up fees and initial investments into something they are just trying to figure out if they really want to proceed with.  I fully support the addition of photos on FAA certificates.  That being said, I do not agree with a few of the ideas contained in the NPRM.  The first point of contention is the requirement to include flight instructor certificates in this proposal.  I believe this is unnecessary for two reasons.  First, the flight instructor certificate is only valid when accompanied by a commercial pilot license, which would in theory already have a photo on it, it seems rather redundant, and imposes an extra cost on instructors.  The second reason I believe that photos on flight instructor certificates are unnecessary are the fact that they expire every 24 month.  This would create an increase in financial burden on the part of the flight instructor, as well as an increase in cost/workload on the part of the FAA.  I also disagree with the idea that student pilot certificates should be plastic.  Not only does this create an increased cost to both the FAA and the student pilot, but its not practical for real world training.  Accelerated flight schools fill a niche in the flight training world.  They depend on student\\'s who have a finite amount of time to dedicate to training, and cannot wait for a plastic student pilot certificate.  Where would the instructor endorse this new plastic pilot certificate for solo priveliges? The NPRM doesnt address these issues.  The last thing I think the FAA should change is the 8 year photo renewal requirement.  I feel it should valid for 10 years like the passport which is currently one method used for identification. In summation, pilot certificates with a photo on them are a great idea.  I wouldnt mind the extra cost of a photo added to my certificate.  The additional requirement for flight instructor certificates is burdensome and costly to both instructors and the FAA, and in my view impractical.  It is my view that the plastic student pilot certificate with photo is not a great idea because there would be no way to endorse it.   I am opposed to requiring photos on pilot certificates.  I hold two, soon to be three separate certificates, and the idea that there is no economic impact to have these reissued with my photo on all three is obviously not well thought out.  No one in 34 years of flying has asked me for my certificate as a form of ID, in fact most cops would rather look at a driver\\'s license as they are more familiar with that document and wouldn\\'t even recognize a pilot\\'s license. The requirement for photo pilot certificates should be rescinded. With the TSA overstepping their bounds and requiring photo ID to even enter the ramp area of many airports, and the current requirement for government issued ID to be carried, it is not necessary to have pilot certificates with photos. Current photo IDs are available immediately and in conjunction with other functions, such as a driver\\'s license. These photos are kept current and at no additional cost or inconvenience to the airman. The requirement for the airman to provide the photo, paperwork, arrange to meet with a DPE and then pay both the DPE and the cost of the certificate is just adding insult to injury.  Most FSDOs are a prohibitive distance from pilots\\' residences and the time involved would prevent pilots from getting new certificates in a timely manner and bog down the FSDO personnel as well.  With the current long wait just to get a new certificate after testing, what provision is there for people who try to renew in a timely manner and do not receive their certificates by the expiration date on the old certificate?  Since a student pilot certificate is not required until solo, many students would have to wait an excessive amount of time to be able to fly solo. The excessive wait to receive the plastic certificates now will be multiplied and we may lose many students who are not willing to wait two months or more for a photo certificate after they are ready to solo.  The current student pilot certificate also allows for the solo endorsements. How would I endorse my students\\' certificates? Flight schools could verify identity and students could keep paper certificates. The pilot population is already too small.  One comment I  hear from other pilots is that this is one more reason not to continue to fly. There are already too many requirements put upon us as pilots, especially those of us living near restricted airspace. This is one more requirement that discourages people from flying. Adding a picture to the current FAA pilot\\'s certificates is redundant and unnecessary, as well as a absurdly costly endeavor, estimated to cost pilots more than $200 every two years, in addition to what they pay now. Taxpayers will pay, also, as additional staff will be required to administrate the new certificates. The current rule already requires that pilots carry a government issued picture ID to correspond to their pilot\\'s certificate. This is entirely adequate for determining the identity of a pilot if that is required.      As it stands right now, most pilots hold picture IDs for access to their hangars at public airports, or picture IDs for access to their secured job sites. All of the others hold government IDs with pictures, either a passport, passport card, or state drivers\\' license. These IDs all prove that background checks and positive identification has been verified. Why do we need to add cost and extra paperwork to the issuance and re-issuance of a pilot\\'s certificate when we already can positively identify all current pilots?      I would like to state clearly that I am against any addition of a picture to the current plastic pilot certificates that will cost pilots and taxpayers more money than they are already paying into the FAA system. I am against any change to the pilot certification system that will result in the hiring of more FAA staff to administrate pilot certification.     I believe that we already have adequate systems in place to positively identify pilots with U.S. FAA certifications. There is no need for change to this system.  Since many of us just paid to have our paper pilot certificates replaced with plastic ones, this new requirement for photo certificates should be at no charge to pilots who have already paid once for the government-mandated reissuance to obtain the soon-to-be-obsolete plastic certificates. This is a good idea.  I have both U.S. Certificates and foreign Certificates.  One is from Chile and it has a photo on it from 30 years ago.  I also believe that long as it is valid the pilot should be able  to get expedited service through check points operated by the TSA.     Perhaps the biometric mechanism could be scanned along with the cornea of our eye to expedite passage. The pilot certificates are certificates; not licenses. It certifies that at one point in a person\\'s life, requirements to be a pilot were met and demonstrated. A pilot certificate is not a form of I.D. besides, how many I.D.\\'s does one person need?  We already have driver\\'s licenses, state I.D. cards, passports, military I.D. cards. This makes as much sense as requiring a birth certificate to be updated every 4 years at $22 or more with a photograph.  The current requirement to carry a legitimate form of I.D. while flying is quite sufficient. One more I.D. card is not going to stop a terrorist from doing the dastardly deed. I am opposed to this proposed rule requiring a photo for Pilot Certificates.  We already have to have a photo ID which is more than adequate.  All this rule will do is require a new fee and more government workers to administer this.  We do not need this. I am pleased to see the addition of a photo on pilot certificates as this should make security easier for pilots of private aircraft.  TSA security directive 8G requires airport specific ID for many airports.  This adds time, cost and complication to those of us who fly from these airports including one day when I thought I would not be allowed to get to my aircraft until the next morning due to not having ID on me beyond my pilot certificate and driver\\'s license (which are what the law says I must have).  I would hope that once the pilot certificates include a photo, the airport specific badges will no longer be required to access general aviation aircraft. The proposal to require photos on pilot certificates must be rejected as a waste of resources and a pointless burden -- to both pilots and the agency -- that yields no benefits.  Pilots will suffer both the monetary cost of the imposed fees and the burden of maintaining their certificate in compliance -- not just initially, but over-and-over again. The agency, too, will suffer the initial and recurring expense and massive overhead of processing photographs, issuing new certificates and replacing those certificates over-and over-again. Currently, pilot certificates are issued once and have no fixed expiration. The current system is a model of efficiency. This proposal is a nightmare of waste.  This proposal simply offers no benefit. Pilots already carry some form of government sanctioned photo ID, in the form of a driver’s license or a passport. If the agency feels the need to have pilots carry a photo ID along with their pilot certificate while operating an aircraft, a simple rule to that effect would suffice. A photo on the pilot certificate adds no value.  In an age demanding fiscal responsibility of both citizens and government alike, this proposed rule is not just pointless and ill-advised, it’s downright irresponsible.   I support the proposal to issue pilot licenses with pictures.  I don\\'t object to the fee structure. I think it\\'s reasonable  I would ask that there be a 10-year renewal period, the same as passports, rather than the proposed 8-year period. It will do nothing for security.  I\\'ve been asked for my pilot license only when I applied for a new rating or a job.  The 9-11 hijackers had paper certificates.  Plastic certificates with or without photos would have made absolutely no difference.  This requirement is a total waste of taxpayer money.  After just requiring plastic licenses, which are darn near unreadable, here we go yet again with another useless requirement. Strongly support the proposed photo requirement for Pilot Certificates. Agree with others that submission should be like passport applications with appropriate photo sent my USPS rather than having to apply in person somewhere.  Also strongly advocate the idea of a plastic license. The current use of paper-based licenses is open to counterfeiting, loss due to water saturation (sweat), and easily damaged. Most pilots laminate their licenses, but that is technically not legal.  Recommend a 10-year expiration (same as US Passport) vs. 8-years.   Also recommend colorizing licenses based on type (Private, Commercial, ATP) for easy and quick status ID.  Smart, effective, and timely proposed rule! I strongly oppose any requirements for photographs on airman certificates. I further oppose the fees and expiry of those certificates. The old paper certificates worked for decades. Why, other than to attempt to charge a fee, is the move to the proposed certificates necessary? I believe most people are amiable to a Photo on their pilot certificate.  The main issues that will create opposition  would be monetary repercussions and the overall inconvenience of identity verification. As per the proposal it is estimated that implementation will cost a staggering 385 million dollars.  In 2006 the estimated number of pilots in the US dropped to < 600,000.  Assuming the number has risen to 1 million US pilots in the last 5 years that mean we are looking at 385.00 per pilot to implement a program that basically changes what is printed in a 1\"x1\" portion of the existing pilot certificates.  It will then cost approximately 35.00 per year to administer on a continuing basis per Pilot.  Where these cost are being generated is nearly a mystery, especially when the proposal places the burden on the pilots and DPE\\'s to do the photo/identity verification and obtain a photo to submit.  There is simply no reason this program should cost so much and add additional fee\\'s to obtain a certificate. As far as Identity verification is concerned, many pilots already have a passport.  I can see no reason why this would not be sufficient for a DPE/ Medical Examiner/ Testing center to verify an applicants Identity with.  In cases of Pilots who do not poses a Passport, other forms of verification such as a birth certificate, Drivers license or  other government issued Photo ID\\'s should suffice.   The implementation of a Photo on Pilot certificates should not have the goal of additional layers of security screening.  To do so will add cost and complexity and do virtually nothing to improve security.  IF implemented it should be done in a way that proves to be a convenience to Pilots and those they interact with at a minimum of cost. I do not believe there should be a fee for the Congressional ordered photo pilot certificates.   I feel that as a citizen of this country, I already pay more than my fair share of taxes, which fund the FAA. If Congress wants to place demands onto the FAA, then Congress needs to find a way to pay for it themselves.  Raising ANY tax or fee during a recession is the worst possible maneuver any governmental agency can make.   Whatever happened to the land of the free? Has it become the land of the fee? Adding a photo requirement for pilot certificates will not enhance safety or security on the ground or in the air in any way, because FAR Part 61.3 already requires that a pilot carry, in addition to his or her certificate, a government-issued photo ID and a valid medical certificate.  The photo requirement will introduce only counterproductive redudancy to the existing requirements.  Furthermore the eight-year photo renewal requirement appears to serve more as a method for collecting a $22 fee than to contribute to anyone\\'s safety or well-being.  As a private pilot I strongly oppose this requirement.  Compliance with such a requirement will cost far more than it is worth. Submission of Photographs I would like to suggest maintaining Aviation Medical Examiners (AMEs) in the mix, however, gathering of photographs should be shifted from them to the licensee.  I would suggest the licensees would be required to submit their photographs as part of the current TurboMedical process.  This is an online system that permits applicants for an medical certificate to fill out their application online, and permit the AME to review and comment on the application before submitting it to the FAA.  This would simply add a step for the AME to verify the photograph submitted in TurboMedical was indeed the airman examined.  No additional equipment or requirements would be imposed upon AMEs to gather or upload photos into the system, and this verification would be a minimal additional burden upon them.  The majority of active airmen are required to have medical exams at least every 5 years, well below the proposed 8 year validity of the photographs.  Similarly, Designated Pilot Examiners (DPEs) have an analogous application, IACRA, to interact with airmen seeking certificates.  Again, the applicant would be responsible for having a photo taken, then uploading that photograph into IACRA.  The DPE would, in the same manner as the AME above, simply need to validate that the airman examined was the same as the photo already uploaded into IACRA.  Student Certificates My final comment relates to Student Pilot certificates requiring photographs.  This requirement, in my opinion, imposes an undue burden for a certificate with limited privileges granted.  An individual on a Student Pilot certificate is only permitted to fly with another certificated pilot.  Their solo flight privileges require reauthorization every 90 days by a certificated CFI.  They are, therefore, in frequent contact with known, already authenticated, individuals who have a responsibility to ensure safety To Whom It May Concern;  Regarding the proposed rule for photo identification on pilot certificates and methods by which a person could or would submit such a photo, FAA should consider as an option following the procedures and protocols for the issuance of U.S. passports through the U.S. Postal Service (at least in terms of submitting photo identification).  The processes for same are already in use, and have been tested and proved effective and reliable over time. It is a relatively convenient process (passport photo ID submittal and verification) using the U.S. Postal Service offices, and indeed in terms of ready access, more so than would be the case using only a FSDO.  If this approach for issuance or submittal of passport information meets the stringent requirements of the Department of State, one would hope it would be adequate for other agencies (FAA, etc.).  Regards, Robert R. Lude Commercial Pilot If we must have a photo on our pilot certificates, please do NOT require one on our flight instructor certificate, as well.  Our CFI certificates aren\\'t valid without the commercial pilot certificate anyway, so why require a photo on that one, too.   You are fixing something that is not broke!   Leave Student Pilot Certificates alone.   Our FAA physicians can deliver them faster and better.   Leave the Pilot Certificates alone.  We all carry Driver\\'s Op. Lic. and that has its own expiration period.   We don\\'t need anymore fees or bureaucracy. There is already enough paperwork for aviation.   Please find something else to do like reduce our fuel bills.   We are all aware of security and feet on the ground is the best way to keep the country safe not more paperwork.  Thank you for the opportunity to give my opinion.  I am a Commercial Multi-Engine Instrument Pilot Comment on Document ID: FAA-2010-1127, Rule: Photo Requirements for Pilot Certificates. The photo requirement for pilot certificates is unnecessary as pilots already carry a photo ID.  The cost for the pilot certificate photo in an individual’s time, inconvenience and fees will do nothing to improve security.  I have been flying for 30 years and have never been asked to show my pilot’s license.  The general aviation community contributes to local and federal economies and tax revenues through fuel, maintenance costs, ancillary pilot supplies, hotels and restaurants and county aircraft property taxes. General aviation pilots provide a service by donating time and aircraft through organizations like Angle Flight and other relief agencies.  The general aviation community is faltering; current financial conditions along with increased costs imposed by cities and counties, and the ever increasing costs to park and hangar planes along with increasing insurance costs and constantly escalating fuel costs are all combining to force many pilots to abandon general aviation forever.   The pilot photo ID is not needed and if imposed will not improve safety or security.  The pilot photo ID will only serve to further financially burden pilots and will likely contribute to a continued loss of general aviation pilots which in turn will eliminate general aviation revenues that would have been generated by former pilots and former plane owners.  I oppose the requriement of a photo on pilot certificates. I base this on the fact that I have had my pilots liscence for over 45 years and have NEVER been asked by anyone to show that I even posses it. In light of this and many other facts I see no possible improvement to safety or anti-terrorism efforts. The current system of requiring pilots to carry government issued photo IDs is sufficient. Requiring pilots to obtain, and periodically replace pilot certificates with photo ID on them, adds unnecessary complexity, and cost. The FAA is trying to solve a problem that doesn\\'t exist.  We do not need Photo IDs on our pilot certificates.  Each State already has acceptable photo IDs (driver\\'s licenses and state issued ID cards, et al), and the Federal govt has acceptable photo IDs as well (passports, et al).  The issue of identification is being resolved and handled everywhere, including by the TSA at commercial airports.    If we need anything, it\\'s more enforcement, not more laws and more hidden taxes/fees.  The relative freedom of our skies is a tremendous birthright and privilege for all of us.  Let\\'s not make it more costly and burdensome to experience.  Please. I am in favor of requiring pilot certificates to contain a photograph. I would hope this would be the first step in enabling the use of pilot certificates to be used for identification for unrestricted access to airport ramp areas (non-air carrier areas) uniformly at airports across the US.  I suggest that the means for submitting photographs to the FAA include via Aviation Medical Examiner (AME) offices and US Passport application locations (designated Post Offices, etc.). The use of AME offices makes the most sense, as periodic AME examinations are already required, and identification verification proceedures are in place.  US Passport application locations similarly make inherent sense, since these locations already have procedures and trained personnel in place to receive and submit similiar information.  Sincerely, Jeffrey Oslick The requirement for a photo on Pilot Certificates is unnecessary and places an undue financial burden on U S Pilots. The current requirement for government issued photo ID is sufficient to provide security.   Crews of foreign airlines regularly fly over the U S and into and out of U S airports without photo pilots certificates.  This November I will have held a U S pilot certificate for 50 years. I flew for American Airlines for 34 years. I hold ATP and CFI.  L. Logan Boles ATP, CFI 1555058 My name is Josh Davis and I am a private pilot, certificate 3370518, with approximately 120 hours.  I support adding the pilot photograph to airman certificates.  Certificates are required to be on hand in order to exercise their privileges.  As such, they function as a form of identification.  Identification without any sort of biometric information is not identification at all.  I recommend that all FAA issued certificates include a current photograph of the individual who has earned that certificate.  Further, a signature, or any additional information required to meet the expectations of 14 CFR 61.3 regarding government issued photo identification should be included.  I recommend that mandated compliance be within 24 calendar months following the effective date of this rule in order to exercise the privileges of the certificate.  However, it may be beneficial from a paperwork standpoint to tie this to performance/flight review timetables.  I believe this would not be an undue hardship on the airman community, nor to the FAA.  This would would simplify ramp checks and ID checks at semi-secure areas.  This would appease some of those who feel that pilot certificates are at risk for misuse. Adding security to pilot certificates seems like a reasonable idea. As a student pilot, I was a bit surprised to learn that the certificate doesn\\'t carry my picture. But given the tamper-resistance of driver\\'s licenses, and the existing requirement that I carry that (or some other form of ID) with me when I fly, I see no point to adding the recurrent expense and administrative burden of putting a picture on the pilot certificate itself.  It would also create another possible way to be citied for the inadvertent violation of flying a few days after teh picture expires. This could easily happen,  especially if the \"administrative burden\" ever results in a greater delay getting us our replacement certificates than expected.  Larry Zubel, PP#3137976 Please consider my submission as a vote against the proposed rulemaking!  The proposal to issue new photo IDs is not justified. Current regulations require a pilot to carry a current government issued photographic identification when they are exercising their pilot privileges. (See 14CFR§61.3.a(2).) Placing a photo on the actual pilot certificate does nothing but create a duplication of efforts and add to the cost of obtaining pilot training and certification.  This rule is especially burdensome on those of us who hold multiple airman certificates. As a pilot, flight, and ground instructor I would personally be required to obtain three separate photographic airman certificates every eight years. Is this really rational considering each certificate would essentially be a duplicate of the others except for the designation of the type of license it represents? A single passport or drivers license accomplishes the needs for a photo identification and is more efficient for those who hold multiple FAA certificates. Yes, some people hold five or more certificates!  Is this program being justified under the need for \"security\" or is it merely intended as a revenue generator for the government? Color me skeptical! Technology Drawing on the experience of law enforcement at traffic stops, the ID card is merely a starting point.  What counts is the online record, which FAA and other officials should be able to access, including photos, using a portable computer or handheld device.  Photo Verification Verifying an updated photo should be a simple process conducted online by an authorized individual.  IACRA should display the existing photo, if any, and the updated photo.  The individual authorizing the update need only look at the two photos side by side and determine that they appear to be the same person.  In such cases, the pilot applicant need not appear in person.  In addition to FSDOs and DPEs, AMEs should be authorized (but not required) to perform photo verification, charging extra if they wish.  Student Pilots Student pilots operating single-engine reciprocating engine airplanes or helicopters, gliders, and balloons should be exempted from the requirement to carry a plastic card because their operating privileges are already limited.  However, these pilots should have photos in IACRA, uploaded by the pilot and verified by the AME or by the CFI who endorses the student pilot for solo privileges.  Student pilot certificates, including the photo, should be printed by the student or CFI.  Instructors\\' endorsements can either be printed on the paper certificate or handwritten, as they are today.  Duration Pilot photos should be valid for 10 years, similar to passport photos.  As the Department of State updates its procedures for collecting passport photos, including online submission, the FAA will realize cost savings by aligning with those procedures.  In addition, airmen will benefit from a streamlined process of updating both passport and pilot photos at once.  Temporary Certificates The FAA should continue to issue temporary 60-day certificates.  Rather than issuing them by fax, they should be issued online, complete with photo, printed by the airman.  .RiViRTMENTOF ; ANSPORWION \" ^HOPER/VTIONS Docket Operations, M30 ^^H Jf\\\\N ! 1 A % U3 U.S. Department of Transportation 1200 New Jersey Avenue SE Room W12-140 West Building Ground Floor Washington DC 20590-0001 Gentlemen: As my perspective on the photo pilot certificate is that of a GA pilot (paid for all my ratings), I inquired of other local pilots in four different clubs, and we all have had nearly the same e3q>eriences regarding our certificates. The request to check our credentials by any authority has been between extremely rare to I can\\'t remember the last time, and there were several of the latter. Loc^ooks, however, get annual scrutiny during annuals and biennials, and that is from A&P\\'s/CFI\\'s, not FAA. It makes no sense to require photo certificates, when there has been shown that no need exists. Further, possession of any certificate has no bearing on threats, and since a known threat can be dealt with now, a photo is superfluous. As there is no need for photo certificates, it would seem that the FAA\\' s proposed rule is an attempt to generate income and maintain enqployment. And that should be done in Congress, not on the backs of the dwindling pilot population. Please withdraw the proposed photo certificate rule. Thank you. Harold P. Little FAA PPA SEL, SES, Glider  FAA proposal to require photos on pilots™ licensesThis Notice of Proposed Rulemaking is ill-conceived.  Here I mention just three of the groundsfor rejecting this rule.1) The rationale of averting terrorism (Section 4022 of the Intelligence Reform and TerrorismPrevention Act), cited as the foundation for this ruling, is not served by this proposed action. Photo IDs are not necessary for the TSA cross-checking against terrorist databases, since theexisting pilot certificates and government-issued photo IDs provide all necessary information. The NPRM states that the FAA has determined that carrying two photo IDs (FAA + othergovernment-issued) is redundant:  ﬁThe FAA has determined two photo identifications areunnecessary and do not serve a safety or security interest.ﬂ  Thus the NPRM admits that theinformation provided by the current system is fully adequate for all identification and securitypurposes.2) The statement regarding the burden to pilots is disingenuous, since the fees imposed constitutea small portion of the actual costs.These costs will include not only the FAA processing fee ($50 for initial, $25 for renewal), butalso any fees imposed by designees (e.g. Designated Pilot Examiner, DPE) to cover theirexpenses (which will include not only their labor but also capital expenditures for equipment,training and processing necessary to meet security concerns).  Most of all, for the pilots itwillinclude the costs of traveling to the few locations where FAA photo IDs can be issued.  Forpilots located in the vast areas of the middle U.S., this may entail a full day™s travel to & from thelocations.3) While the proposed rule is onerous for the entire pilot population, the process outlined forissuing Student Pilot Certificates is extraordinarily cumbersome.  Aviation Medical Examiners (AMEs) would still be required for medical exams, but could notissue student pilot certificates, nor could DPEs issue student pilot certificates.  Prospectivestudent pilots would be issued only by FSDOs and designated Knowledge Testing Centers(KTCs).  Obtaining a student licence would thus require a full day of travel just to get to a FSDOor KTC, in addition to the existing AME examŒ all of this followed by the estimated 6 to 8weeks of waiting for the application to be processed.In conclusion, this proposed rule is unjustified, unnecessary, excessively burdensome, anddamaging to the interests of pilots and the whole aviation community of the United States.ŒChristopher T. Cole, Ph. D., CFII 02/17/2012 17:18 13&02534958 RE BURTON PAGE 01 :.frv\\\\iiTr^FNTnF Ł TION TO: FROM: DAIt: RE: - FAX -1 page total FAA FAX 202-493-2251 Robert E. (Bob) Burton Jr. FAX 360-253-4956 Phoae 360-254-5146 Febninry 17,2012 NPRM - Photo Requirements for Pilot Certificates Docket No. FAA-2010-1127; Notice No. 2010-16 NO! NO! NO! NO! We don\\'t need to do this. Ft would be another nail in the coffin of General Aviation. R.E. Burton Jr Vancouver, WA Ł^\\'-KEiOPFR m Fc\\'3 ? 1 , Ł\\'iTiO\\'JO ^ 8-- 5S  December 03, 2010US Department of TransportationFederal Aviation AdministrationWashington, DC(Submitted via electronic comment services @ Regulations.gov)To whom it may concurs:The FAA is proposing the addition of photographs on US pilot certificates and I feel that the addition of a photograph is an excellent idea.  It is long overdue and would increase the overall safety of GA flight / pilots.However, I would recommend changing the proposal in the following ways:1)  As the lack of a photo on current certificates is clearly an oversight by the FAA, the replacement certificates (with photo) should be issued to existing certificated pilots, free of charge.  Pilots spend an inordinate amount to get and maintain their certificates - this would be unfair burden to those that have already paid their dues.2)  New certificates being issues, after the policy should take effect, would incur the same charge as with any state drivers license or passport identification.3)  The existing organizations that supply driver\\'s licenses, passport photos and/or other government identification should be capable of handling paperwork and completing the photographs - this license should not require any special services.  These would be, but are not limited to, US Post Office, US Passport Offices, FSDO, Driver\\'s License Centers.4)  The identification should qualify as government identification and would qualify for TSA Checkpoints, for example.5)  Allowing Designated Pilot Examiners (DPEs) the ability to issue and validate these certificates is a clear security hole and should not be allowed.  There is sufficient policy in place for this type of identification.Thank you for your time and consideration.Sincerely, Christopher RossCommercial Pilot, CFI     February  17 ,  201 1     Docket Operations, M - 30   U.S.  Department of Transportation   1200  New Jersey Avenue, SE   Washington, DC 20 590     RE:    Docket Number   FAA - 2010 - 11 27 , Notice of Proposed  Rulemaking, Photo  Requirements for Pilot Certificates     The National Air Transportation Association (NATA), the voice of aviation  business, is the public policy group representing the interests of aviation  businesses before the Congress, federal agencies and state governments. NATA\\'s  over 2,000 member companies   own, operate and service aircraft and provide for  the needs of the traveling public by offering services and products to aircraft  operators and others such as fuel sales, aircraft maintenance, parts sales, storage,  rental, airline servicing, flight traini ng, Part 135 on - demand air charter, fractional  aircraft program management and scheduled commuter operations in smaller  aircraft. NATA members are a vital link in the aviation industry providing services  to the general public, airlines, general aviation an d the military.       With this rulemaking ,   the Federal Aviation Administration (FAA) proposes  requiring that all pilot certificates include a photo of the certificated individual.  The     within the Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA).  IRTPA required that the FAA begin issuing pilots certificates that:     1.   Are tamper resistant   2.   Contain a Photo of the certificated individual   3.   Are c apable of accommodating a digital  photo or other biometric identifier       Section 4022 of IRTPA required  the  FAA to begin issuing these new certificates  within one year of   passage.     NATA understands and supports  the   that bear a phot o of the certificate holder. However ,   the processing and  issuance of  these new certificates  and the potential   negative effects  that  these  may have on the  industry are of concern to NATA and its membership.   NATA appreciates the  opportunity to submit these c omments  for consideration.       NATA Comments on Docket # FAA - 2010 - 11 27 , Notice of Proposed Rulemaking, Photo Requirements  for Pilot Certificates   February 17, 2011     Page 2 of 5       I.   Acceptability of Digital Photographs   Section 4022 of the Intelligence  Reform and Terrorism Prevention Act of 2004, which is cited as   of accommodating a digital photograph 1  help  relieve the burden on regulated parties by requiring the FAA to accept digital photographs  for incorporation into improved pilot certificates. This rulemaking notes that  the  FAA will  accept digital photographs at some point in the future but currently requ ires the submission of a       Technology allowing the capture and transfer of digital photographs is currently commonplace.  NATA assumes that  the   informational technology infrastructure or lack of development of the appropriate standards,  policies and procedures necessary for the acceptance  of  digital photographs within the  agency .      Proposal   NATA asks the FAA to withdraw this rulemaking until  it   is able to comply  fully  with the  requirements of section 4022 of IRTPA, specifically the accommodation of digital photographs.  Pursuing implementation of this rule prior to obtaining   the ability to accept digital photographs  places additional burdens on the pilot community, burdens that section 4022(b)(3) were  designed to prevent.      Although NATA strongly believes the rulemaking should be withdrawn until such time as  digital photograp h acceptance is possible, the association offers the following addition al   comment s   on other areas of the NPRM that are of concern.       II.   Proposed Changes to the Student Pilot Certificate   This rulemaking propose s   to change the student pilot certificate from a p aper certificate issued  by Aviation Medical Examiners (AME) in conjunction with a medical certificate to a plastic  certificate with a photo of the certificated individual. Under this proposal ,   a student pilot would  be required to submit  his or her  applicat ion for a student pilot certificate to, and appear before  (for the purposes of identity verification),  his or her  local Flight Standards District Office  (FSDO) or other FAA designee.   The  FAA then estimates a  six  to  eight  week processing time for  the  issuance of the actual certificate.                                                                 1   Intelligence Reform and Terrorism Prevention Act of 2004, Section 4022(b)(3)     NATA Comments on Docket # FAA - 2010 - 11 27 , Notice of Proposed Rulemaking, Photo Requirements  for Pilot Certificates    February 17, 2011     Page 3 of 5       NATA is concerned that  t he  six -   to  eight - week processing time estimated   by the FAA may be  overly optimistic ,   especially in the early stages of implementation of the new issuance process.  Even if a  six -   to  eight - week processing delay is realistic, a delay of that length will significantly  affect th e   scheduling  and curriculum  for facilities providing initial flight training. The length of   certificate (solo flight) can vary based upon a number of factors, including   training frequency  and na tural  aptitude, but is quite often less than  eight  weeks. In a regular, near - full - time or  full - time training environment ,   a student may reach the solo phase of their initial flight training in  just a few weeks. Under this proposal ,   a student would need to  submit their application for a  student  pilot   certificate well in advance of the commencement of their training to  ensure  that  their student  pilot   certificate is received prior to reaching the solo flight phase of their training.  In lieu of this, a facility   or instructor would need to revise the curriculum and training schedule  radically       In the NPRM,  the  FAA states that its reasoning  for requiring photos on student   pilot certificates  st ems from the   .  , the   FAA has  proposed an exception that allows the continued use of a facsimile temporary airman certificate  if an original certificate is lost. NATA concurs with this  exceptio n  and believes that a similar  rational should be extended to student pilot certificates.     By its very nature a student pilot certificate is temporary in nature. Its sole purpose is to provide  a  short - term authorization to operate an aircraft for the  purpose of training. Much like a  temporary replacement certificate ,   the student pilot certificate often does not have a defined   n   well in advance   by the applicant . Students choosing to begin flight  training will most likely be full y unaware of the certification requirements for student pilots  until immediately prior to  or after  the commencement of their training.   Thus ,   these students  have a need for a temporary authorization that is not subject to a  six -   to  eight - week or longer  wait ing period, much like an existing pilot whose certificate is lost or destroyed.      Proposal   NATA ask that  the  FAA modify this proposed rule  to continue the issuance and use policies and  procedures for paper student pilot certificates .             NATA Comments on  Docket # FAA - 2010 - 11 27 , Notice of Proposed Rulemaking, Photo Requirements  for Pilot Certificates   February 17, 2011     Page 4 of 5       III.   Expiration of Photographs   In this proposed rule , the   FAA sets an expiration time frame  of  eight  years  on photographs  included   on pilot certificates.  The  FAA states that it chose an  eight - year expiration time frame to  conform with the standards set forth in the Real   ID Act (although that conforma tion is not  required by th at   act   or IRTPA ). In choosing an  eight - year expiration time   frame ,   the agency  rejected other conforming choices that would have been less burdensome on the industry,  including the  ten - year standard utilized by the State Department for passport photos. In making  this choice between competing standards ,   the FAA has  not identified any concrete  benefit   to  adhering   to a Real   ID conforming standard. Lacking a compelling benefit for imposing a stricter  standard ,   NATA believes the agency should base its choice between competing existing  standards on reduction in burden.      Proposal   NATA requests that the FAA adopt a  ten - year expiration time frame for photographs on pilot  certificates, similar to the standard utilized by the State Department for passport photos.         IV.   Use of Designees   The language of IRTPA section 4022 allows  the FAA to utilize designees in the issuance of  improved pilot licenses. Currently, the FAA proposes allowing Designated Pilot Examiners and  Designated Knowledge Testing Centers to verify identity and photographs. NATA believes that  this will help to reduc e the burden on pilots in the conversion to certificates containing  photographs. NATA, however, believes that the FAA should go an additional step further and  recognize that there are existing entities that currently specialize in collecting and submitting   identity information to the federal government and utilize those entities to reduce the burden  on pilots further. Many pilots may not encounter a triggering event during the transition period  and, therefore, will be required to appear at their FSDO or bef ore a designee to have their  identity and photograph verified. Expanding designees to include entities that currently  provide identity verification services to the federal government will serve to reduce the burden  on pilots.                 NATA Comments on Docket # FAA - 2010 - 11 27 , Notice of Proposed Rulemaking, Photo Requirements  for Pilot Certificates                  February 17, 2011     Page  5   of 5       Proposal   NATA asks that the FAA create a designee classification that permits companies that are  au thorized to provide identity and photograph verification services for the federal government  to provide those same services for improved pilot certificates 2 .         Closing   NATA understands that the FAA is acting upon a congressional mandate requiring photographs  on pilot certificates. However, NATA fails to see the benefit to pilots or overall aviation security  by simply requiring photographs to be placed on those certificat es. As such, NATA believes that  relieving burdens on pilots and the industry in general must be a priority in this rulemaking.    NATA appreciates the opportunity to submit these comments and hopes the agency will  evaluate the herewith proposed and other met hods to alleviate additional burdens being placed  on the industry by this rulemaking.         Michael France   Director, Regulatory Affairs                                                                 2   As an example, NATA is aware of companies that provide general aviation industry - wide fingerprint collection and  identity verification for the performance of criminal history record checks on behalf of the Transportation Security  Administration (TSA).     ,-Response to Notice of Proposed Rulemaking: Photo Requirements for Pilot Certificatesl h 0 2: I 8 (Docket Number FAA-2010-1127) Submitted by: Robert lex, ATP, CFI 7Feb2011 The Notice  of Proposed Rulemaking (NPRM) proposes incorporation  of photographs on pilot certificates, and an implementation strategy for compliance, including fees. This response seeks to address answers to several questions posed in the published NPRM itself, and additionally address issues not covered in the NPRM. The requested supporting data cannot be provided in the time allotted. Fortunately, much of the response is derived from information already in the public domain. 1. The NPRM seeks ideas on improving the identification process \"to ensure a high level of confidence in the verification.\" There are several alternative methods that may be used together or separately to aid this process. If any are implemented, they should minimize the chance for human error on the part of the certifying official. Here are a few ideas, from simplest to most complex: a. Comparison of the submitted photos with some form of acceptable photo ID presented by the applicant. This method is simr.lest .md is available now. It is also more prone to tampering and fraud than the other methods herein. b. Advance submission of the photos in digital form example, a .pdffik or other recognized medium, to FAA Aianen Certification Branch (AFS-760)], as part of a simple authentication process yet to be deterrnlned. The submitted phOtc3 \\\\\\\\\\'culd be availab:e for comparison with the applicant\\'s appearance and photos by the certifying official at the time of application. TillS process parallels other processes already in place, such as with Letters of Verification of Authenticity and piiot re-eL\"Caminations. More technically challenging solutions c. Submission of fingerprints along with tHc photos. This method adds considerable public burden, and requires access to an out-of-agency database, but is a proven method of identif1c\\'ation. \\'Td ease public burden; fihgerptinting equipment\\'could-beitistalled at FSDO;s and training ptovided to ASI\\'s antl/or\\'\\'AST\\'s. \\'-\\' \\'.iG, d. FutUre installation of face recognition techbolbgy at FSDO\\'s, how beingilhplemented in otffer\\' arenas, such as airports and otherporls of entry. This method\\' also\\' requires icce\\'ss to an out-of-agency databaSe. . .\\' . e. Future installation of iris scahtriiIg tecnnology-at·FSDO\\'s, now being implemented in other arenas, such as airports and other pdrts of entry\\', and again, requiring access to an out-of-agency database. Applicants w6uld suthilift<Ya non-invasive iris scan as part of the application process.\\' The disadvantageofiris·scanning is the hurdle posed·by the 4th Mnendment to the US Constitution, preventing unreasonable search and seizure. Applicants would need to be apprised of, and have to waive, their Constitutional rights, and cannot be forced to do so. 2. The NPRM solicits discussion ofthe \"trigger\" and \"non-trigger\" approaches to implementation. The proposal makes sense on its merits, but a strong case can be made for adoption of a single compliance date (5 years, the least-common denominator), in order to permit the FAA time to take advantage of \"confidence-building\" technologies proposed in item 1 above, and to stave off perceptions of unequal FAA treatment of one or more pilot communities. The mere cost of compliance will be sufficient argument in and of itself to delay implementation for as long as possible for all pilot communities. The triggering proposal as worded in the NPRM overlooks another triggering event that should necessitate a new photo: permanent alteration of facial appearance, such as with cosmetic alterations. 3. The NPRM solicits ideas on less burdensome ways to establish applicant identity. Of course there are, and they are outlined in item 1 above, so the question now becomes, \"Are there less burdensome ways to establish applicant identity which have relevance to the FAA\\'s Knowledge Testing Centers, Designees, and FSDO personnel?\" On the one hand, it is possible to create fingerprint records, facial recognition and iris scan databases, and even DNA databases (all of which exist in the realm of criminal law enforcement), but if the FAA cannot ac(:ess those databases, there is little left to do in the field but compare the applicant-supplied photos against photos on other trusted documents also supplied by the applicant, a process potentially and inherently subject to tampering and fraud. For that reason, at least one of the other technologies, such as facial recognition software, should be implemented and deployed at least at the FSDO level. 4. No comment for question 4 of the NPRM, regarding duration of photograph. 5. The NPRM asks whether or not Student Pilot Certificates (SPC\\'s) should be treated like other pilot certificates. The proposal is long overdue. With the elimination of endorsements on the reverse side of plastic SPC\\'s, the SPC could now be treated like any other pilot certificate. SPC\\'s would bear the same limitation against carrying passengers as they now do. 6. The NPRM asks whether the FAA should accept only hard-copy photos or should it also accept digitally captured photos. Clearly, the Administration must evolve with advances in technology, and the advent of digital photography is one such advancement. Thus, the FAA has no choice but to embrace digital technology. 7. The NPRM solicits ideas on implementing a collection method for digitally captured photos. See also item 1 (b) above. The applicant could create a scan of the photograph, then upload to AFS-760 the digital image he will hand-carry to the FSDO. The imagery would be stored at AFS-760 and either downloaded to the FSDO or be made available for viewing in an on-line site like SPAS or in IACRA. The comparison with the digital image will be made -once in the field (with the applicant present), and once again at AFS-760 when final processing of the application takes place. Moreover, this would relieve FSDO\\'s and Knowledge Testing Centers of the burden of otherwise having to create digital imagery on all applicants, although, as stated in the NPRM, that capability already exists at the FSDO. 8. Additional proposals not solicited in the NPRM, but perhaps worthy of due consideration at this point in the regulatory process: a. Henceforth, when an ainnan orders a facsimile of his pilot credentials, the fax should also include the likeness of the ainnan, or wording to the effect that no photo is on file, on the faxed report. The likeness should also reflect the expiration date of the image. b. Create new backgrounds for pilot (and other ainnen) certificates to enhance the visual contrast between lettering and the background. Currently, the \"blue credit card\" certificates are hard to read because the tiny black lettering is imprinted against a dark blue-green or dark gray background. Not only is the certificate difficult to read, but difficult to copy legibly. Therefore I propose the following improvements to the appearance of pilot certificates, coinciding with the incorporation of photographs: 1. Creation of lighter-colored pilot certificate blanks that contrast better with the black lettering used; 11. Use of a larger font size on the certificate -there\\'s plenty of room for larger lettering, even larger than the revised fonts now in use; 111. Creation of different designs/colors for different levels of pilot certification: 1. Design / Color A for Student Pilot Certificates 2. Design / Color B for Recreational Pilot Certificates 3. Design / Color C for Sport Pilot Certificates 4. Design / Color D for Private 5. Design / Color E for Commercial 6. Design / Color F for A TP 7. Design / Color G for Flight Instructors, including Gold Seal 8. Design / Color H for Wright Brothers Master Pilots 9. Offer a choice of several optional designs as is often seen on checkbooks and license plates. Additional fees could be levied to offset any costs. If a pilot holds certification at multiple levels, the highest level would be depicted on the certificate design. I leave it to the Administrator and others to assign colors and create designs; I have some suggestions as well. Very respectfully, ;/fip R. Jex 407-812-7757  Daniel P. Cope 100 West 26 th Street, Apt 22B New York, NY 10001    February 15, 2011    John M. Allen  Director, Flight Standards Service  Federal Aviation Administration   800 Independence Avenue SW   Washington, DC 20591    Re: FAA-2010-1127: Notice of Proposed Rulemaking - Photo Requirements for Pilot Certificates       Dear Mr. Allen:    I am writing to submit comments regarding the  FAA™s proposal to add photographs to pilot certificates.  I hold a commercial pilot certificate w ith airplane single engine land and instrument  airplane ratings and fly regularly for recreational purposes.  As  you know non-professional pilots are particularly sensitive to additional burdens, both financial and administrative, on their flying.   I will address the NPRM primarily from the  perspective of a non-professional pilot.   Summary   Below I address each section of the preamble to  the NPRM and answer the specific questions  posed by the FAA.  In summary, I suggest:   The FAA not increase fees for the issuance of pilot certificates or at least should vary the fees in relation to the costs imposed on the FAA for issuance of certificates in different situations.   An entirely trigger-based implem entation approach and suggest this is consistent with the FAA™s obligations under the IRPTA.  Even if a non-trigger-based approach is included, the timeframe for compliance should not vary by certificate type.   Considering all CFIs to be designees for the purpose of verifying photographs to significantly decrease the burden on pilots.  Delaying implementation of this rule until such time as the FAA is prepared to accept digital  photographs uploaded by applicants through IACRA and verified by designees.  Investigating the possibility of integrati on with state DMV databases and the State Department passport database to allow applican ts to authorize the FAA to obtain these pre- existing, verified photos.  If photographs are to expire, though not required by the terms of IRPTA, expiration should  be set at eight years and the photo pilot certificate should conform to the Real ID Act so that  it may be used as photo identification, in  particular at TSA security checkpoints.  The FAA authorize the use of temporary pape r certificates by student pilots to avoid imposing a significant burd en on student pilots.   Fees for Issuing or Replacing a Pilot Certificate with Photo   My comments on the proposed fee structure fall into two areas:    I challenge the FAA™s authority to increase the  fee for a pilot certificat e based on the user-fee prohibition found in its annua l appropriations bill.  Even if a non-trigger approach is to exist, there is no reason to stagger the requirement based  on the type of certificate held.  All pilots  should be given five years to comply.   1. While the FAA has the statutory authority to co llect fees up to $22 for the issuance of pilot certificates under 49 U.S.C. 45302 as noted in the NPRM, the FAA™s ability to alter the current fee structure to fully utilize this statut ory authority is proscribed by the restriction  placed in the FAA™s annual appropriations bill 1 prohibiting the FAA from spending money to  enact user fees.  In particular the appropriations bill provides funds to the FAA provided,  ﬁThat none of the funds in this Act shall be available for the Federal Aviation Administration  to finalize or implement any regulation that  would promulgate new aviation user fees not  specifically authorized by law after the  date of the enactment of this Act.ﬂ   The FAA™s NPRM specifically states that the  purpose of increasing the fee is to better  recover the FAA™s costs in issuing enhanced pilot certificates and is therefore most certainly   a user fee.  Further evidence that the purpose of the fee incr ease is to generate more revenue through a  fee on users can be found in the fact that the proposal eliminates  the distinction made in the  current fee structure between newly issued certif icates or certificates with new ratings and replacement certificates.  The current distincti on, while currently financially minimal ($0 vs.  $2) can be justified as an incentive for pilots not to lose their certifi cates and not to request replacements simply to change their address,  which can be accomplished without issuing a  new certificate.  I do not consider this fee structure to amount to a  user fee as its intent is to accomplish FAA goals other than revenue generation, namely minimizing the unnecessary   issuance of certificates.     It is also noted that the FAA chose to discuss  the increased fees first in a proposal ostensibly related to satisfying the requirements of the IR TPA directive to issue photo pilot certificates.   I call the FAA™s attention to this restriction and  note that by the terms of the restriction it is  prohibited from using funds to finalize a  rule containing the proposed user fees2 given that the statutory authority cited by the FAA as aut horizing a higher fee was not enacted after the date of the appropriations bill.   I ask that the FAA drop the  proposed fee increase from the  final rule in order to remain in complian ce with the restrictions on its appropriations.                                                   1 Such a restriction has been placed in  the FAA™s annual appropriations for  many years.  For the most recent  example, see P.L. 111- 117 (123 Stat. 3040).  2 I view the proposed fees as ﬁnewﬂ user fees despite th e fact that the FAA currently  charges $2 for a replacement  certificate.  As discussed above, the $2 fee is not a user fee intended to recover costs.  It is a deterrent to minimize   unnecessary issuance of replacement certificates.  Even  if the FAA does not share this view, the fee for a new  certificate is certainly a ﬁnew ﬂ fee and thus prohibited.    2. Even if you reject the argument  above that the fee increases represent prohibited user fees, I suggest that you retain a price differential in the final rule similar to the current price difference between issuing a new certificate  and issuing a replacement certificate.  In  particular, I suggest three categories: a. A certificate with a new photo that the FAA must process, and  b. A new certificate with an unexpired photo, and  c. A replacement certificate.  I understand that the current statutory maximum fee  does not recover all of the FAA™s costs  in issuing certificates and the  purpose of a single fee set to the statutory maximum is to raise  as much revenue as possible to offset those cost s.  However, a single fee does not accurately reflect the fact that each of  the above activities generates different costs for the FAA.    The first category I propose constitutes a pilot certificate with a new photo.  This would include certificates issued because of an expi ring photo or issuances due to the achievement  of a higher certificate or new rating where a new photo is provided simultaneously.  I  propose that such a certificate have the highest fee as the burden on the FAA is the greatest  when processing new photos.    The second category would include cases where a pilot applies for a higher certificate or new rating but will utilize an unexpired photo.  As the current fee structure provides new and  upgraded certificates free of charge, I propose that this category retain the lowest price or even remain free.     The third category mirrors the current category where the FAA is asked to issue a   replacement certificate.  The FAA currently ch arges the highest, though still nominal, fee for  this activity, presumably to provide a disincentive to request replacements unnecessarily.   Given that the issuance of re placement certificates represents  the lowest burden on the FAA,  I see no justification for applying the full fee, but instead I suggest a fee between the issuance  of a certificate with a new photo and an upgraded certificate with an unexpired photo.  I note that requesting a replacement cer tificate is not always due to loss of the original.  For  example, the FAA recently added the ﬁEnglish Pr oficientﬂ notation to all certificates to  comply with ICAO requirements.  This required  pilots who regularly travel internationally to  request a replacement when they otherwise would not have.     Specifically I propose the following fees: $22 for certificates with new photos, no fee for an upgraded certificate with an unexpired photo, and $11 for a replacement certificate.     Implementation Approach  My comments on the Implementatio n Approach focus on two topics:  I challenge the FAA™s interpretation that the  IRPTA requires reissuing all pilot certificates  with a photo and propose implementing a trigger-based approach only.   Even if a non-trigger approach is to exist, there is no reason to stagger the requirement based  on the type of certificate held.  All pilots  should be given five years to comply.  1. The FAA has proposed a trigger-based and non- trigger based implementation approach to  ensure all pilot certificates are replaced with photo pilot certificates within five years of the effective date of the final rule.  The FAA stat es in the NPRM that, ﬁFor the FAA to comply  with IRPTA, it must reissue all  existing pilot certificates with a  pilot certificate with photo.ﬂ   I challenge this statement based on  the statutory text which reads:  SEC. 4022. IMPROVED PILOT LICENSES.   (a) IN GENERAL.ŠNot later than  one year after the date of enactment of this Act, the  Administrator of the Federal Aviation Admini stration shall begin to issue improved pilot  licenses consistent with the requirements of title 49, United States Code, and title 14, Code of Federal Regulations.  (b) REQUIREMENTS.ŠImproved pilots license s issued under subsection (a) shallŠ (1) be resistant to tampering,  alteration, and counterfeiting; (2) include a photograph of the individual to whom the license is issued; and (3) be capable of accommodating a digita l photograph, a biometric identifier, or  any other unique identifier that the Administrator considers necessary.  (c) TAMPERING.ŠTo the extent practical, the Administrato r shall develop methods to  determine or reveal whether any component or  security feature of a license issued under subsection (a) has been tamper ed, altered, or counterfeited. (d) USE OF DESIGNEES.ŠThe Administra tor may use designees to carry out  subsection (a) to the extent feasible in  order to minimize the burdens on pilots.   The IRPTA simply requires that the FAA  begin to issue ﬁimproved pilot licenses,ﬂ which are  later defined as requiring a photo.  Given this, there is no statutory requirement that the FAA  replace all current pilot certifi cates.  The FAA therefore should  avoid burdening pilots with the need to obtain a new certificate in the ab sence of a statutory requirement to do so.    In general, I question the necessity of including a photograph on pilot certificates at all.  I would challenge the FAA to produce evidence that a photo pilot certificate alone would decrease terrorism or any other significant crime in  the future or evidence  of a past trend of such crime due to the lack of photo certificat es.  I understand that the FAA™s hands are tied with regard to the issuance of photo certificates by congressional action through the IRPTA; however, I suggest that the FAA strictly interpret its duties thereunder and implement a  trigger-based approach only.   2. Even if the FAA chooses to unnecessarily increase the burden on pilots by utilizing a non- trigger-based approach in addition to a trigger-based approach, there is no reason why certain certificate holders should be required to comply sooner than others.  By failing to  differentiate certificate holders in the photo requirement, Congress clearly believes all pilots  to pose the same risk to aviation security wi thout photo certificates.  As I mention above,  while I seriously question the actual risk posed by non-photo certificates, to the extent one exists, I can see no difference between ATP,  commercial, and private pilots.  The FAA™s  gave the following reasoning in the NPRM for the difference:   The FAA chose different cut-off dates based on certificate level to provide the most time  for private, sport, and recreational pilots. Those pilots are the least likely to have regular  contact with the FAA. ATP and commercial pilot certificate holders usually have more   regular contact with the FAA than other types of pilots.   While it is certainly true that private, sport, a nd recreational pilots are deserving of five years to comply, the reasoning given for shorter tim eframes for commercial and ATP pilots is  merely a statement of fact.  Private, sport,  and recreational pilots certainly will have less  contact with the FAA than commercial pilots,  who will in turn have less contact than ATP  pilots.  This explains why the timeframe to  adopt photo certificates under a trigger-based approach alone would see ATP pilots with the fastest adoption and private pilots with the slowest; however, it fails to give any reason why ATP and commercial pilots should be required to adopt any sooner than their private pilot counterparts if their natural interactions with the FAA do not trigger it.  If aviation safety can be maintained and the FAA™s duties  under the IRPTA can be fulfilled with private pilots having five years to comply, the FAA  has provided no reasoning why they will not be  equally so and the IRPTA not equally  complied with by giving ATP and commercial pilots equal time to comply.      Applying for a Pilot Certificate with Photo   I suggest considering all FAA certified flight instructors to be ﬁdesigneesﬂ within the meaning of  the IRPTA.  The FAA already places great confidence in flight in structors to maintain aviation  safety.  They are permitted to authorize student pi lots to conduct solo flight; sign off pilots for  complex, high-performance, and tail-wheel opera tions; conduct instrument proficiency checks;  and give Biennial Flight Reviews.  Given this trust, the FAA can certainly trust them to verify a  photo of an applicant.  This verification  can be built into IACRA and the paper 8710-1  application.    Adoption of this suggestion will significantly reduce the compliance burden with minimal  decrease in the accuracy of the  photos and therefore minimal decrea se in aviation safety.  This  will decrease the compliance burden in a number of ways:    The NPRM notes that designees may charge for  their services and that these charges cannot be regulated by the FAA.  By providing a larg e number of designees, the FAA will decrease  the ﬁmarket priceﬂ for ﬁphoto verification serv icesﬂ and ensure there is little chance of  localized monopolies developing to drive up the price.   It will significantly decrease the burden on pilots living outside of the United States and  those living in rural areas which may be far fr om FSDOs, available DPEs, and testing centers.   It will decrease the burden placed on FSDOs  as pilots will be less compelled by price  considerations to submit thei r photos in person to FSDOs, where doing so would be free.  It will decrease the burden on new flight students as their instructor can submit the photo to  receive their student pilot certificate. 3  The hurdles that students face in beginning flight  training are already significant, especially for non-US citizens.  Ensuring this burden remains  as low as possible is critical to growing the currently shrinking pilot community.                                                   3 See the  Student Pilot Certificates  below for additional comments on the NPRM™s impact on student pilots.  By adopting my suggestion above to eliminate  the non-trigger-based requirements to obtain a  photo certificate, CFIs will typicall y only need to verify photos for student pilots and for pilots  whose photos are expiring.  DPEs would likely verify photos for most applicants where a new  application triggers the photo requirement.  Even  if non-trigger-based requ irements remain, CFIs  will likely handle most of these photo verifica tions.  FSDO and testing center burden will be  minimal in either case.      Photo Requirements  The FAA proposes that it will initially accept on ly paper photographs.  The necessary revisions  to IACRA to accept a digital photo would seem to be minimal; therefore, I suggest that the FAA  delay the effectiveness of this rule until such time as IACRA can accept a digital photograph   supplied by the applicant and verified by a designee.    I also suggest the FAA investigate the possibility of obtaining photos directly from state DMV  databases and the US State Department™s passport  photo database.  If applicants are willing to provide consent for the FAA to access these record s, it would allow applicants to provide the  FAA a pre-existing photo that has already been verified further reducing the compliance burden.     Duration of Pilot Privileges for a Pilot Certificate with Photo   If the FAA chooses to use an eight year validity period for photos, I suggest that the pilot certificate otherwise comply with  the Real ID Act and that the F AA ensure that it is considered  to be valid photo identification for all purposes under the Real ID Act.  In particular, it should be considered valid photo identification at a TSA checkpoint.   If the FAA chooses not to make pilot certificates  compliant with the Real  ID Act, I suggest a ten year validity period to coincide with passport photo validity and minimize burden.    Utilizing passport photos directly from the  State Department would require either:  a. extending the validity of all photos to the te n years permitted by the State Department, or  b. extending the validity of only photos obtained directly from th e State Department to ten  years with an eight year validity period for all other photos, or c. requiring pilots to provide a non-passport photo during the two-year period between the  expiration of the photo for pilot certificate purposes and the expiration of their passport.    Student Pilot Certificates  The application of the photo certificate requirement to student p ilot certificates is clearly the  most burdensome requirement in the FAA™s propos ed rule.  Furthermore, this burden is not  considered in the regulatory evaluation, an obvious oversight.  Many students currently solo faster than the FAA suggests it will be able to provide photo student pilot certificates.  I soloed approximately three weeks after beginning flight  training.  A friend comple ted his entire private pilot certificate in this time.  For many students,  especially those trai ning to be professional pilots, a multiple week delay in their training wi ll be unacceptable.  It wi ll also erect another  barrier to entry for new pilots.    Integrating many of the suggestions above, I pro pose the following scheme  for the issuance of student pilot certificates:   1. Allow the student™s flight instructor to verify his photo. 2. The Airmen Certification Branch could then i ssue a facsimile airman  certificate, including  the now-verified photo, via either IACRA or any of the methods currently  allowed for pilots whose original certificate is lost or destroyed.  The temporary certificate would be valid for  60 days and must be accompanied by anothe r government-issued photo identification.  3. The Airmen Certification Branch would then i ssue a plastic certificate with photo within 60 days.   Utilizing CFI™s as designees has many benefits as  noted above.  In the context of student pilots,  their use as designees is even  more natural.  A student would  not normally appear at a testing  center until he is ready for his written exam, which  may be after his first solo flight.  Similarly, a  student would not normally appear before a DPE be fore the practical exam at the conclusion of  his flight training.    The FAA proposes to treat the f acsimile pilot certificate the FAA issues to temporarily replace  pilot certificates that are lost or destroyed as sp ecial purpose pilot author izations.  I see no reason why the FAA cannot utilize the same reasoning to justify the use of the procedure I outline above.    The photo provided will have already been verified (one of the FAA™s justifications for permitting the facsimile certificate to remain).   The CFI would ﬁissueﬂ the certificate from an  administrative perspective; the paper facsimile  would temporarily replace the plastic certificate  that would arrive soon.   Furthermore, the FAA states in the NPRM that  it is required to issue plastic student pilot  certificates with a photo to comply with IRTPA.   I see nothing in the statute™s text that would support this assertion.  1. The IRTPA states only that the FAA must ﬁbeg in to issue improved pilot licenses.ﬂ  No  where does it say all pilot certificates must be ﬁimprovedﬂ (and, as noted above, it does not  say by when currently issued certificates must  be replaced with ﬁimprovedﬂ certificates).  2. It does not say the ﬁimprovedﬂ certificates must  be plastic.  It requires only that they be resistant to tampering, alteration, and counterfeit ing; contain a photograph; and be capable of accommodating a digital photograph, a biometric id entifier, or any other unique identifier  that the Administrator considers necessary.    While the FAA may find the analysis in (1) strained  as it would allow, taken to its extreme, the  FAA to issue exactly two ﬁimprovedﬂ certificat es and consider itself done, the less extreme  interpretation supported here is  not necessarily inconsistent with the intent of Congress.   Congress intended to add photographs to pilot certificates without significantly adding to the burden on pilots, which is a consideration specifically mentioned in subsection (d) in providing  for the use of designees.  Congress did not explicitly say which pilot certificates must be  ﬁimprovedﬂ and therefore the FAA may interpret  the intent of Congress in this regard through rulemaking.     The analysis in (2) is even more straightforwar d.  The FAA can use various techniques to ensure  that the temporary certificate cannot be tampered  with, altered, or counterfeited.  For example,  the FAA could require the issuing CFI to sign the temporary certificat e in ink or even require an additional signature across a portion of the photograph and/or the student™s name to prevent  tampering.  The certificate would already contai n a digital photograph (albeit in printed form)  and a student pilot certificate number (a uni que identifier) and would thus satisfy the  requirements of the IRTPA.  If a biometric iden tifier is considered necessary, students can be required to place a thumbprint on the pape r certificate with CFI verification.      Comments on the FAA™s Specific Questions  The FAA posed a number of questions in the NPRM, many of which I have answered in the   course of commenting on the specific sections of the rule.  Below I will respond to each posed question, either directly or by referencing the discussion above.   1. While this proposal does not outline specific id entity verification standards and processes,  the FAA may include such standards and proces ses in a final rule. The FAA seeks comment  on standards that should be used for identity verification to issue pilot photo certificates, either in person or remotely. Should the FAA  require applicants to produce fraud-resistant documents to verify identity? If so, which documents or other identity verification   procedures should the FAA implement to ensure  a high level of confidence in the verification process?   Response:  The purpose of this NPRM is to impl ement the statutory requirement to add  photographs to pilot certificates.  To be within the scope of this rulemaking, the identity  verification requirements must be minimal a nd for the purpose of furthering accurate placement of photographs on pilot certificates.   The verification process should consist of the  designee comparing the applic ant™s face to the provided phot ograph and ensuring that the photograph is genuine.    If the FAA believes further identity verification is required, it should publish a separate NPRM and seek comments as this would represen t a separate burden.  If the FAA rejects this analysis, applicants should at most be  required to produce a government-issued photo  identification as this is already required by regulation to exercise the privileges of a pilot  certificate.   2. Should the FAA consider an alternative implem entation approach to the ﬁtriggerﬂ and ﬁnon- triggerﬂ approach set forth in the proposal?  Should the FAA set one deadline, regardless of certificate level, for pilots to have a pilot certif icate with photo to exercise the privileges of  that certificate rather than implement the pha sed ﬁnon-triggerﬂ approach set forth in this proposal? What is the basis and supporting data  for a single deadline? If the FAA were to  implement a single deadline, what time period fo r conversion to a pilot certificate with photo adequately balances the FAA™s need to comply  with the statutory mandate and the burden on  certificate holders? Would lengthening th e implementation period significantly reduce  burden on a pilot? What is the basis and  supporting data for a longer time period?   Response:  I provide an alternative implementation approach above in  Implementation  Approach based on a trigger-based system only.  As  noted therein, no statutory requirement  exists requiring the FAA to ensure all pilot certificates contain a photo by any certain deadline.  The IRTPA requires only that the FAA begin issuing certificates with a photograph.  As I also note therein, if a firm deadline is to exist, I see no reason for  staggering the deadline based on certificate level as this does not  seem to be based on the risk  posed to aviation safety or any other regulatory goal.  If the point is to prevent a flood of requests from all pilots as the deadline approaches, the FAA should implement a staged  approach based on issuance date similar to the aircraft re-registration rule.    3. Currently, the FAA envisions using Knowledge Te sting Centers, DPEs, and FSDOs to accept pilot certificate applications a nd validate applicant identity. Are there alternative, potentially  less burdensome, methods for pilo ts within the U.S. and outside of the U.S. the FAA should consider? In addition, what should the FAA consider when designating service providers with identity verification authority?   Response:  As noted above in Applying for a Pilot Certificate with Photo, I highly encourage the FAA to consider all CFIs to be designees for the purpose of carrying out this rule.  This  would be extremely less burdensome for all pilots  to comply with.  Given the responsibilities  the FAA gives to CFIs to assist in maintaining aviation safety,  not trusting them to verify a  photograph would seem illogical.   4. Is the proposed 8-year duration for the photo, based on the photo duration for state driver™s licenses under the Real ID Act, a reasonable period of time that balan ces the security needs  expressed in IRTPA and the burden on certificate holders? Are there  other standards or guidance for photo accuracy the FAA should consider? What is the basis and supporting data   for a shorter or longer duration?   Response:  An eight year validity period is reasonable.  I encourage the FAA to consider  integration with state DMV databases and the  Department of State passport photo database.   In the case a passport photo is obtained directly from the State Department, I would suggest  extending the validity of the photo to ten years.  I also reiterate that the photo pilot certificate should be compliant with the Real ID Act and accepted as valid photo identification specifically by the TSA.    5. Is there any reason why student pilot certificates should not be treated like other pilot certificates for the purposes of meeting the  IRTPA requirements? What is the basis and  supporting data for your response?   Response:  See the discussion above under  Student Pilot Certificates.  6. With respect to the photo that is placed on  the pilot certificate, should the FAA accept only  hard copy photos, only digitally-captured photos, or either hard copy or digitally-captured photos? What is the basis and s upporting data for your response?   Response:  The FAA should accept both  paper and digital photogra phs.  In particular, the  FAA should delay implementation until IACRA  is able to accept a digital photograph  uploaded by the applicant.   7. If the FAA accepts digitally-cap tured photos, what are the adva ntages and disadvantages of  the following methods of acquiring the photo:  (a) An applicant uploading a self-captured photo to the IACRA subsystem;  (b) a FSDO capturing the photo when the application is submitted; (c) a Knowledge Testing Center  capturing the photo when an application is  submitted; and (d) a DPE capturing the photo when  an application is submitted? What is the  basis and supporting data for your response?   Response:  As discussed above, use of IACRA by applicants to self-provide a photograph would be the least burdensome option.  A self -provided photograph would be verified by a designee.      The FAA should offer the option of obtaining a digital photograph for free at a FSDO for applicants who prefer this method.     DPEs and Knowledge Testing Centers who choose to offer this service should be permitted   to do so, but the FAA should not impose a requir ement to offer this service on all DPEs and  Knowledge Testing Centers.  Doing so would impose a new burden on DPEs and testing centers and may impact th e availability of each to pilots in rural areas.     I thank you for your kind attention and consideration of the above comments.  You may contact me at the above address or at DaDaDan@hotmail.com.       Regards,    /s/ Daniel P. Cope    Daniel P. Cope      ']"
      ]
     },
     "execution_count": 8,
     "metadata": {},
     "output_type": "execute_result"
    }
   ],
   "source": [
    "mashed"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 99,
   "metadata": {
    "collapsed": true
   },
   "outputs": [],
   "source": [
    "# TESTING NEW THINGS TESTING NEW THINGS TESTING NEW THINGS TESTING NEW THINGS\n",
    "\n",
    "def mash_comments(all_comments):\n",
    "    big_comment = []\n",
    "    for cluster in all_comments:\n",
    "        mashed = \"\"\n",
    "        for comment in cluster:\n",
    "            mashed += comment\n",
    "            mashed += \" \"\n",
    "        big_comment.append(mashed)\n",
    "    return big_comment\n",
    "\n",
    "# Adapted from: http://www.markhneedham.com/blog/2015/02/15/pythonscikit-learn-calculating-tfidf-on-how-i-met-your-mother-transcripts/\n",
    "def top_words(all_comments, n_top_words):\n",
    "    mashed_comments = mash_comments(all_comments)\n",
    "    tfidf_matrix, tfidf_vec = vectorize_comments(mashed_comments)\n",
    "    feature_names = tfidf_vec.get_feature_names()\n",
    "    dense = tfidf_matrix.todense()\n",
    "    top_words = []\n",
    "    for i in range(0,len(mashed_comments)):\n",
    "        print(i)\n",
    "        cluster = dense[i].tolist()[0]\n",
    "        word_scores = [pair for pair in zip(range(0, len(cluster)), cluster) if pair[1] > 0]\n",
    "        sorted_word_scores = sorted(word_scores, key=lambda t: t[1] * -1)\n",
    "        temp_top_words = []\n",
    "        for word, score in [(feature_names[word_id], score) for (word_id, score) in sorted_word_scores][:n_top_words]:\n",
    "            print('{0: <20} {1}'.format(word, score))\n",
    "            temp_top_words.append(word)\n",
    "        print('\\n')\n",
    "        top_words.append(temp_top_words)\n",
    "    return top_words\n",
    "\n",
    "def cluster_comments(document, num_clusters):\n",
    "    cluster_dict = {}\n",
    "\n",
    "    comments = process_document(document)\n",
    "    tfidf_matrix, tfidf_vec = vectorize_comments(comments)\n",
    "    \n",
    "    km = KMeans(n_clusters=num_clusters)\n",
    "    km.fit(tfidf_matrix)\n",
    "    clusters = km.labels_.tolist()\n",
    "    \n",
    "    cluster_center_list = []\n",
    "    for c in clusters:\n",
    "        cluster_center_list.append(km.cluster_centers_[c])\n",
    "    center_distances = paired_distances(tfidf_matrix, cluster_center_list)\n",
    "    \n",
    "    comment_clusters = {'comment': comments, 'cluster': clusters, 'dist': center_distances}\n",
    "    comment_frame = pd.DataFrame(comment_clusters, index = [clusters] , columns = ['comment', 'cluster', 'dist'])\n",
    "    \n",
    "    central_comments = []\n",
    "    all_comments = []\n",
    "    for i in range(num_clusters):\n",
    "        central_comments.append(comment_frame[comment_frame.cluster==i].min().comment)\n",
    "        all_comments.append(list(comment_frame[comment_frame.cluster==i]['comment']))\n",
    "    \n",
    "    return all_comments"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 100,
   "metadata": {
    "collapsed": false
   },
   "outputs": [],
   "source": [
    "tfidf_vec, all_comments = cluster_comments(document, cluster_num)"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 101,
   "metadata": {
    "collapsed": true
   },
   "outputs": [],
   "source": [
    "mashed_comments = mash_comments(all_comments)\n",
    "tfidf_matrix, tfidf_vec = vectorize_comments(mashed_comments)\n",
    "feature_names = tfidf_vec.get_feature_names()"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 110,
   "metadata": {
    "collapsed": true
   },
   "outputs": [],
   "source": [
    "dense = tfidf_matrix.todense()\n",
    "cluster = dense[0].tolist()[0]"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 139,
   "metadata": {
    "collapsed": false
   },
   "outputs": [
    {
     "data": {
      "text/plain": [
       "matrix([[ 0.        ,  0.        ,  0.        , ...,  0.00100362,\n",
       "          0.00066908,  0.00066908]])"
      ]
     },
     "execution_count": 139,
     "metadata": {},
     "output_type": "execute_result"
    }
   ],
   "source": [
    "dense[0]"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": null,
   "metadata": {
    "collapsed": true
   },
   "outputs": [],
   "source": [
    "term_scores = [pair for pair in zip(range(0, tfidf_matrix[0].shape[1]), cluster) if pair[1] > 0]\n",
    "sorted_term_scores = sorted(term_scores, key=lambda t: t[1] * -1)\n",
    "for term, score in [(feature_names[term_id], score) for (term_id, score) in sorted_term_scores][:6]:\n",
    "    print('{0: <20} {1}'.format(term, score))"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 103,
   "metadata": {
    "collapsed": false
   },
   "outputs": [
    {
     "name": "stdout",
     "output_type": "stream",
     "text": [
      "mercury              0.6684115014722248\n",
      "n n n                0.1532194532904299\n",
      "n n n n              0.129467092627503\n",
      "n n                  0.12822664141359158\n",
      "n s                  0.08733927839680485\n",
      "et al                0.08130338866036364\n"
     ]
    }
   ],
   "source": [
    "term_scores = [pair for pair in zip(range(0, len(cluster)), cluster) if pair[1] > 0]\n",
    "sorted_term_scores = sorted(term_scores, key=lambda t: t[1] * -1)\n",
    "for term, score in [(feature_names[term_id], score) for (term_id, score) in sorted_term_scores][:6]:\n",
    "    print('{0: <20} {1}'.format(term, score))"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 9,
   "metadata": {
    "collapsed": false
   },
   "outputs": [],
   "source": [
    "def tokenize_text(corpus):\n",
    "    pattern = r'''(?x)     # set flag to allow verbose regexps\n",
    "    ((?:[A-Z]\\.)+)         # abbreviations, e.g. B.C.\n",
    "    | (?:(\\w+([-']\\w+))+)  # words with optional internal hyphens e.g. after-ages or author's\n",
    "    | ([a-zA-Z]+)          # capture everything else\n",
    "    '''\n",
    "    tokens = nltk.regexp_tokenize(corpus,pattern)\n",
    "    all_token = [word.lower() for token in tokens for word in token if word != \"\" and word[0] != \"'\" and word[0] != \"-\"]\n",
    "    return all_token"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": 10,
   "metadata": {
    "collapsed": false
   },
   "outputs": [
    {
     "data": {
      "text/plain": [
       "['a', 'b', 'abc', 'a-a', 'a', 'a', 'a.b.', \"a's\"]"
      ]
     },
     "execution_count": 10,
     "metadata": {},
     "output_type": "execute_result"
    }
   ],
   "source": [
    "test = tokenize_text('a b abc a-a a.a A.B. a\\'s')\n",
    "test"
   ]
  },
  {
   "cell_type": "markdown",
   "metadata": {},
   "source": [
    "# END TESTING"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": null,
   "metadata": {
    "collapsed": false
   },
   "outputs": [],
   "source": [
    "n = get_cluster_count(document)"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": null,
   "metadata": {
    "collapsed": false
   },
   "outputs": [],
   "source": [
    "test = cluster_comments(document, n)"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": null,
   "metadata": {
    "collapsed": false
   },
   "outputs": [],
   "source": [
    "test.keys()"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": null,
   "metadata": {
    "collapsed": false
   },
   "outputs": [],
   "source": [
    "len(test['central_comments'])"
   ]
  },
  {
   "cell_type": "code",
   "execution_count": null,
   "metadata": {
    "collapsed": false
   },
   "outputs": [],
   "source": [
    "for i in test['central_comments']:\n",
    "    print(i)\n",
    "    print('\\n\\n\\n\\n')"
   ]
  }
 ],
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