U.S. Department of Transportation

FEDERAL AVIATION

ADMINISTRATION

REGULATORY EVALUATION

FINAL RULE

Student Pilot Application Requirements

(14 CFR 61 and 183)

OFFICE OF AVIATION POLICY AND PLANS

ECONOMIC ANALYSIS DIVISION

Esther Barto and Brian Seymour

APO-300

November 2015
2

Table of Contents

I. Executive Summary ..........................................................................................................................3

II. Introduction/Background...............................................................................................................5

III. Assumptions, Calculations, and Data Sources .........................................................................8

IV. Benefits .........................................................................................................................................10

V. Costs...................................................................................................................................................11

1. Sensitivity Analysis..........................................................................................................................23

VI. Discussion of Alternatives.........................................................................................................26

VII. Benefit-Cost Summary................................................................................................................29
3

I. Executive Summary

Currently, most student pilots are issued a combination student pilot/medical certificate by an 

Aviation Medical Examiner (AME), then they are vetted against the terrorist watch lists by the 

Transportation Security Administration (TSA). This final rule requires applicants to apply for a 

student pilot certificate with an aviation safety inspector (ASI) or aviation safety technician 

(AST) at a Flight Standards District Office (FSDO), designated pilot examiner (DPE), airman 

certification representative (ACR) associated with a part 141 pilot school, or certified flight 

instructor (CFI). AMEs will no longer issue a combination medical certificate and student pilot 

certificate. Student pilot certificates will be issued on the same medium as other pilot certificates

and will have no expiration date. All student pilot certificates issued before the effective date of 

this final rule will expire according to their terms unless they are replaced by another pilot 

certificate. 

This final rule responds to section 4012 of the Intelligence Reform and Terrorism Prevention 

Act (IRTPA) and facilitates security vetting of all student pilot certificate applicants before the 

FAA issues a student pilot certificate. This final rule withdraws the proposal for pilot certificates 

to include a photograph of the individual pilot. Section 321 of the FAA Modernization and 

Reform Act of 2012 supersedes section 4022 of the IRTPA, which provided the basis for the 

proposed rule. The FAA intends to propose a rule to implement section 321 (RIN 2120-AK33). 

Additionally, this rule withdraws the proposal to implement fees for student pilot certificates and 

the FAA intends to propose a rule to implement fees under section 122 (RIN 2120-AK37).

The FAA expects about 500,000 original applications and replacements for student pilot 

certificates between 2015 and 2024, given future projected growth in the student pilot category.

The three groups affected by this final rule are the student pilot applicants, the FAA, and 
4

authorized individuals.

1 Student pilots will incur costs associated with completing the 

application. The FAA will incur the costs of processing these applications. Once the application 

is processed, there is a mailing cost for the certificate sent to the student pilot. Offsetting these 

costs are the benefits which implement the direction of Congress as stated in section 4012 of 

IRTPA. Congress determined that the benefits to society from security vetting prior to issuance 

is greater than the quicker security application vetting process. 

This final rule will have an effective date of 60 days from the date of publication in the 

Federal Register. Current student pilot certificate holders may continue exercising the privileges 

of the student pilot certificate until the certificate expires according to its existing terms.

This rule will not have a significant impact on international trade, will not have a significant 

economic impact on a substantial number of small firms, and will not impose an unfunded 

mandate.

The estimated compliance cost of this rule ranges from $17 to $20.9 million. Although the 

potential benefits are not quantifiable, this final rule responds to the direction of Congress in 

section 4012 of the Intelligence Reform and Terrorism Prevention Act (IRTPA) and therefore

provides a sufficient reasoned determination to justify the costs.

 1 An authorized individual is an AST or ASI at a FSDO, a DPE, an ACR at a part 141 pilot school, or a CFI who 

may accept a student pilot certificate application and verify the applicant’s identity.
5

II. Introduction/Background 

This final rule responds to section 4012 of the Intelligence Reform and Terrorism Prevention 

Act (IRTPA) and facilitates security vetting by the TSA of student pilot applicants prior to the 

issuance of an FAA certificate. This action withdraws the proposal for pilot certificates to 

include a photo of the individual pilot. Section 321 of the FAA Modernization and Reform Act 

of 2012 supersedes section 4022 of the IRTPA, which provided the basis for the proposed rule. 

On December 17, 2004, the President signed into law Public Law 108-458,2 the IRTPA. 

Section 4022 of that law requires the FAA to issue improved pilot certificates that are resistant to 

tampering, includes a photograph, and is capable of accommodating a digital photograph, a 

biometric identifier, or any other unique identifier the FAA Administrator considers necessary. 

In section 4012(a)(1) of IRTPA, Congress required the TSA, in coordination with the FAA, 

to ensure that individuals are vetted against the terrorist watch lists prior to the issuance of an 

FAA student pilot certificate. Currently, student pilots are vetted after they are issued a student 

pilot certificate.

This final rule requires a student pilot applicant to apply for, obtain, and carry a plastic pilot 

certificate to exercise the privileges of the pilot certificate issued by the FAA Civil Aviation 

Registry prior to exercising the privileges of a student pilot certificate. Additionally, it modifies 

the process by which student pilots apply for a certificate. Student pilot applicants will be able to

apply for a certificate using one of the following options:

• Appear in person at a Flight Standard District Office (FSDO) before an Aviation 

Safety Inspector (ASI) or Aviation Safety Technician (AST);

• Through a Designated Pilot Examiner (DPE);

 2 Codified at 49 USC 44903(j)(2)(D).
6

• Through an Airman Certification Representative (ACR) associated with a part 141 

pilot school; or

• Through a Certified Flight Instructor (CFI).

All student pilot certificates will be issued by the FAA Civil Aviation Registry. All those 

accepting student pilot applications will be referred to as authorized individuals throughout this 

document. In general, the FAA requires pilots to appear in person since the application involves

identity verification; an examination of skills or knowledge; verification of records; or a 

combination of these requirements. However, the FAA will allow current pilot certificate holders 

to continue exercising privileges of the student pilot certificate until the certificate expires. This 

final rule does not require the holder of a paper student pilot certificate to surrender that 

certificate and replace it with a plastic student pilot certificate. Student pilot applicants will no 

longer be able to obtain paper student pilot certificates at the time of application. If a pilot 

certificate is lost, stolen, or destroyed, the pilot may apply for a replacement online or by mail 

under current rules. The majority of those seeking replacements will be due to their student pilot 

certificate expiring.

This rule will discontinue an Aviation Medical Examiner’s(AME) authority to issue a student 

pilot certificate. Today a student pilot’s first contact with the FAA is usually through an AME 

due to the medical certificate requirement. 

Currently, there are more than 60 ACRs associated with part 141 schools, over 99,000 CFIs, 

about 1,000 DPEs,3 and FAA personnel at 80 FSDOs. While the DPEs and FSDOs can accept 

student pilot applications under this rule, the FAA believes, in practice, that all applications will 

be processed by ACRs associated with part 141 schools and CFIs. Each authorized individual is 

required to verify the applicant’s identity, verify any supporting documents, and submit the 

applicable material to the FAA’s Civil Aviation Registry.

 3 The number of active DPEs fluctuates between 950 and 1,000 over the course of a year, so the FAA is using 1,000 

as a reasonable estimate. 
7

The subsequent sections herein specify the assumptions and data sources for the analysis.

Then an analysis of the benefits and costs to this final rule is presented in sections IV and V, 

respectively. Section VI discusses the alternative considered, which is similar to the final rule 

except that the alternative does not allow CFIs to be an authorized individual.
8

III. Assumptions, Calculations, and Data Sources

In this analysis, the FAA estimates the costs to comply with this rule over a ten-year period, 

from 2015 through 2024. As required by the Office of Management and Budget (OMB), the 

present values of these costs are calculated using discount factors of 7 percent and 3 percent. 

Below is the overview of assumptions and data sources:

• All costs are presented in 2014 dollars.

• Ten-year time period of analysis is from 2015 to 2024.

• 75 percent of student pilots will apply for a student pilot certificate with a Certified Flight 

Instructor (CFI) and 25 percent of them will apply with an Airman Certification 

Representative (ACR) associated with a part 141 school. 

• No student pilot applicants are expected to apply for a student pilot certificate with a 

Designated Pilot Examiner (DPE) or a Flight Standards District Office (FSDO).

• A range of $13 to $25.22 is used as the hourly rate of an student pilot’s time as advised 

by Department of Transportation (DOT) guidance.

4

• $23.59 is the hourly rate for a CFI and ACR associated with a part 141 school.

5

• $2.00 is the FAA fee for issuing a replacement pilot certificate.

• $0.235 is the cost per mile for an automobile.

6

 4 The lower rate of $13.00 is based on the Revised Departmental Guidance on Valuation of Travel Time in 

Economic Analysis, Table 4: Recommended Hourly Values of Travel Time Savings for in-vehicle local travel. The 

higher rate of $25.22 is based on median income for all U.S. households in 2014 ($51,939) reported in U.S. Census 

Bureau, Table H-8.This range is used to estimate the value of personal time forgone by the student pilot to complete 

an application form and related tasks. Further, these values have been grown by 1% for every year past 2014 as 

advised in DOT Departmental Guidance. 

http://www.dot.gov/sites/dot.gov/files/docs/USDOT%20VOT%20Guidance%202014.pdf

http://www.census.gov/hhes/www/income/data/historical/household/

5 From the Bureau of Labor Statistics (BLS), Education, Training, and Library Occupations (code 25-0000) in the 

Air Transportation Industry (NAICS 481200) is assumed to be representative of CFI and ACR occupations 

associated with this final rule. http://www.bls.gov/oes/current/naics4_481200.htm 6 On December 6, 2013 the Internal Revenue Service (IRS) in Announcement IR-2013-95 announced that the 

mileage reimbursement rate for a privately owned vehicle driven for medical or moving purposes is $0.235 per mile. 

http://www.irs.gov/2014-Standard-Mileage-Rates-for-Business,-Medical-and-Moving-Announced
9

• 55 miles per hour is the average speed used for calculating time spent traveling by 

automobile.

• The FAA will allow an authorized individual to charge a fee for its services.7 The charges 

differ for each authorized individual assuming 20 minutes of processing time:

• The FAA assumes that the ACR associated with the part 141 school will charge $7.86.

8

 

• The FAA assumes that the DPE will charge $25 for an application (provided in the 

NPRM). 

• The FAA assumes that the FSDO will impose no additional charge.

• The FAA assumes that the CFI will charge $7.86.

9

 7 The costs that FSDOs will incur in processing these applications will be part of the overall FAA costs and the FAA 

will not charge a separate fee for the work done by the FSDOs. 

8 The FAA estimates an hourly rate of $23.59 for an ACR associated with a part 141 school. $23.59/hr × 20 mins/60 

mins = $7.86. 9 The FAA estimates an hourly rate of $23.59 for a CFI. Calculation: $23.59/hr × 20 mins/60 mins = $7.86.
10

IV. Benefits

This final rule responds to section 4012 of the Intelligence Reform and Terrorism Prevention 

Act (IRTPA) and facilitates security vetting of all student pilot certificate applicants before the 

FAA issues a student pilot certificate. The FAA notes that following the direction of Congress 

provides a sufficient reasoned determination to justify the costs. These potential benefits are not 

quantifiable. 
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V. Costs

The compliance costs have three distinct components. The first component is the student 

pilot applicant’s direct and indirect costs. The second component is the costs incurred by the 

FAA’s Civil Aviation Registry to process and issue a student pilot certificate. TSA will not incur 

any additional costs as it already vets student pilots. Under this rule, TSA will conduct the 

vetting prior to the issuance of an FAA student pilot certificate. The third component is for the 

mailing expenses incurred by an authorized individual to mail the applications to FAA’s Civil 

Aviation Registry. 

Costs are calculated as follows:

1) Student Pilot Costs = [(# of Student Pilots (Original) × ($/time to fill out form/student + $/authorized 

individual processing time/student + $/authorized individual charge/student)],

2) FAA Costs = One time Software Costs + (Recurring Costs to issue a Student Pilot 

Certificate10/student × # of Student Pilots (Original and Replacements)),

3) Mailing Costs = (25% × # of Student Pilots (Original)) × Mailing Charges11/ student,

4) Total Cost = Student Pilot Costs + FAA Costs + Mailing Costs.

Student Costs

Under the final rule, an Aviation Safety Inspector (ASI) or Aviation Safety Technician (AST)

at a Flight Standard District Office (FSDO), a Designated Pilot Examiner (DPE), or an Airman 

Certification Representative (ACR) associated with a part 141 pilot school will continue to be 

able to accept an application for a student pilot certificate but will not be able to issue a student 

 10 Currently, paper student pilot certificates are issued by an AMEs and ASIs or ASTs at FSDOs. Under this final 

rule, the recurring costs will cover the FAA’s costs to issue a plastic student pilot certificate by the FAA’s Civil 

Aviation Registry.

11 Under this final rule, AMEs, DPEs and FSDOs will no longer be allowed to issue student pilot certificates. Since 

25 % of new student pilot applicants are expected to go to an ACR associated with a part 141 school to submit their 

application, the ACR will mail the application to FAA’s Civil Aviation Registry.
12

pilot certificate. In addition, a CFI will be permitted to accept an application for a pilot 

certificate. Student applicants can submit their application in one of two ways: 

1) Submit a paper application, or 

2) Submit application electronically (through the Integrated Airman Certification and Rating 

Application (IACRA)).

12

The FAA encourages authorized individuals to submit applications electronically for the 

purpose of accepting a student pilot application.

There are 2 types of student pilot applications. 

• For Issuance of an Original Student Pilot Certificate; and

• Replacement of a Student Pilot Certificate. 

 An “original pilot certificate” is a certificate that a pilot initially receives as a student pilot. A 

student pilot could have requested a replacement certificate in 2014 for two reasons: (1) the

student pilot certificate has been lost, stolen, or destroyed; and (2) the student pilot needs to

renew the certificate before it expires. 

Currently, student pilot certificates have a duration of two or five years, depending on the age 

or aircraft rating of the student pilot.

13 For student pilots under 40 years of age, the duration of 

their student pilot certificate is 60 months; for student pilots 40 years or older, the duration of 

their certificate is 24 months. Under the rule, current student pilot certificate holders will 

continue to exercise privileges of the student pilot certificate until the certificate expires. This 

final rule does not require the holder of a paper student pilot certificate to surrender that 

certificate and replace it with a plastic student pilot certificate. Furthermore, this final rule 

requires all future student pilot certificates to be issued on the same medium and have the same 

 12 IACRA is the web-based certification/rating application that guides the user through the FAA’s airman 

application process. https://iacra.faa.gov/iacra/ The system helps ensure applicants meet regulatory and policy 

requirements through the use of various data validation. 13 For student pilots seeking a glider rating, balloon rating, or a sport pilot certificate, the duration of their student 

pilot certificate is 60 months, regardless of the person's age.
13

duration as other pilot certificates, which will eliminate the need for a student pilot to obtain a 

replacement certificate due to expiration. 

Once the final rule is in effect, all replacements will be essentially zero by the third year of 

analysis. At present, student pilots under 40 years of age have student pilot certificates good for 

60 months. The FAA expects nearly all of the student pilots under 40 are using this license as a 

stepping stone towards a career as a commercial pilot. Given the training time and cost industry

rule of thumb of roughly $10,000, the FAA expects most of these students either advance, or 

lapse (drop-off). Thus within the 5 year analysis period, the only reason these students would 

need to replace their certificates is if these are lost, stolen, or destroyed. For those student pilots 

over 40 years of age, if they do not advance they will need to replace their certificate once it 

expires after 24 months. Therefore, three years after the rule is in effect, there will be essentially 

no one requesting the FAA to replace their paper certificate. 

Table 1a depicts the number of active student pilots and total original and replacements 

issued from 2011 to 2014. In 2014, there were 120,546 active student pilots with paper

certificates. 14 Of these 120,546 active student pilots, 49,95915 (41.44 percent of the total) 

certificates were issued in 2014. Of these paper certificates, 37,164 (30.83 percent of the total) 

were original student pilot certificates issued and the remaining 12,790 (10.61 percent of the 

total) were replacement certificates. Since the total number of active student pilots is relatively 

stable over the years, the FAA assumes that the new certificates are offset by an equal amount of 

students are leaving the program each year. The FAA estimates that this offset continues into the 

future and these percentages will remain constant during the entire forecast period of this 

analysis. This estimate is lower than the average over the historical period which results in fewer 

replacements per year into the future. The number of new student pilots is the key driver of 

 14 FAA U.S. Civil Airmen Statistics, 2014, Table 1, Estimated Active Airmen Certificates Held, 

http://www.faa.gov/data_research/aviation_data_statistics/civil_airmen_statistics/ 15 FAA U.S. Civil Airmen Statistics, Table 16 and Table 17 minus 1,854 since 1,854 is accounted for in Table 16

(49,261 – 1,854) + 2,552 = 49,959
14

future costs for this rule. Table 1b below contains the FAA forecasted number of future student 

pilots for the years 2015 through 2024.16 

In 2015 (the first year of the analysis period), Table 1b shows the FAA forecasts that there 

will be 119,550 active student pilots. Table 1a shows that for 2014, there were 30.83 percent 

original certificates and 10.61 percent replacement certificates compared to the number of active 

student pilots. The FAA believes that this percentage is the best forecast for future original and 

replacement certificates. Table 1c shows the number of replacements and the balance of paper 

student pilot certificates for years 2015 to 2017. To obtain the number of original and 

replacement certificates issued in 2015, the FAA multiplied 30.83 percent and 10.61 percent to 

119,550 respectively to obtain 36,857 original student pilot issuances and 12,684 replacements. 

Once we subtract the 12,684 replacements and the 36,857 student pilots that dropped out or 

acquired their next pilot license, we have a balance of 71,005 paper student pilot certificates. For 

2016, the FAA forecasts that there will be 118,950 active student pilots. In 2016, the FAA 

assumes that 30.83% of the 118,950 active student pilots or 36,672 will drop out or move on to 

their next pilot license of those 71,005 left in the balance of student pilot paper certificates. 

10.61%, or 12,621, of the 118,950 forecasted Active Student pilots need replacement certificates. 

So for 2017 the balance of Student Pilot Certificates is 71,005 – 36,672 – 12,621 = 21,712. In 

2017 only 21,712 of the 120,546 Student Pilots with Paper Certificates are left. Factoring in the 

drop off rate, we are left with 0 Paper Certificates in 2017. 

 16 Source: Table 30 in “FAA Aerospace Forecasts Fiscal Years 2014 – 2034, U. S. Department of Transportation 

Federal Aviation Administration, Office of Policy & Plans.” Table 30 has estimated 2013 year-end totals for 

domestic ATP, Commercial, Private, Recreational, Sport, and Student pilots; these totals are based on a report from 

FAA U.S. Civil Airmen Statistics.
15

TABLE 1a

HISTORICAL ACTIVE NUMBER OF FUTURE STUDENT PILOT CERTIFICATES

(2011 – 2014)

Year Active Student Pilots 

Original and 

replacement 

certificates 

issued

Original 

Certificates 

to Active 

Student 

Pilots

Replacement

Certificates to 

Active Student 

Pilots 

2011 118,657 58,025 42,005 16,019

2012 119,946 57,042 41,645 15,401

2013 120,285 50,242 37,481 12,762

2014 120,546 49,959 37,164 12,790

*Row and Column calculations may not sum due to rounding

TABLE 1b

FORECASTED NUMBER OF FUTURE STUDENT PILOT CERTIFICATES

(2015 – 2024)

Year FAA Forecast

2015 119,550

2016 118,950

2017 118,350

2018 117,800

2019 117,300

2020 116,850

2021 116,500

2022 116,200

2023 116,000

2024 115,800
16

TABLE 1c

FORECASTED NUMBER OF REPLACEMENT STUDENT PILOT CERTIFICATES

(2015 – 2017)

Year FAA Forecast

Forecast Original and 

Replacement 

Certificates

Original 

Certificates

Replacement 

Certificates

Balance of Paper 

Student Pilot 

Certificates

2015 119,550 49,542 36,857 12,684 71,005

2016 118,950 49,293 36,672 12,621 21,712

2017 118,350 49,044 36,487 0 0

Table 2 depicts the breakout of the original issuance student pilot certificates, replacements,

and the total number of student pilot certificates affected by this final rule during the 10-year 

time period of analysis. 

TABLE 2

NUMBER OF STUDENT PILOT CERTIFICATES 

Year Original Replacements Total 

2015 36,857 12,684 49,541

2016 36,672 12,621 49,293

2017 36,487 0 36,487

2018 36,318 0 36,318

2019 36,164 0 36,164

2020 36,025 0 36,025

2021 35,917 0 35,917

2022 35,824 0 35,824

2023 35,763 0 35,763

2024 35,701 0 35,701

Total 361,728 25,305 387,033

As previously mentioned, a student pilot applicant can apply for their certificate with an 

Aviation Safety Inspector (ASI) or Aviation Safety Technician (AST) at an FSDO, a DPE, an 

ACR associated with a part 141 pilot school, or a CFI. Nonetheless, this analysis assumes that 75 

percent of student pilot applicants will apply with a CFI, 25 percent will apply with an ACR 
17

associated with a part 141 school, and no student pilots are expected to apply at an FSDO or 

DPE.

Upon submission of the application package by the student pilot, the authorized individual

will verify the airman's identity, provide and sign FAA Form 8710-1, and forward the entire 

application package to FAA’s Civil Aviation Registry in one of two ways:

1) One piece of 8.5 × 11 sheet of paper (8710-1) individually mailed to the FAA at a cost of 

$3 (provided in the NPRM). Given the number of application packages that each 

authorized individual will process, the FAA determined that it will cost them $15 per 

batch mailing of 20 applications (provided in the NPRM). 

2) Utilizing IACRA, the authorized individual can also verify the airman's identity, retrieve 

the application initiated by the student pilot, and electronically sign Form 8710-1. The 

IACRA package will be electronically submitted to FAA’s Civil Aviation Registry.

The FAA assumes that CFIs will submit applications electronically through IACRA. While 

an ACR associated with a part 141 pilot school can send a student pilot application either

electronically or by mail to the Civil Aviation Registry, the FAA has taken the conservative 

approach (greater cost) by estimating this cost associated with mailing an application.

The DOT assigns the value of personal time of a student pilot to a range of $13 to $25.22 per 

hour (see Assumptions and Data Source section). This range of hourly rates used in the analysis 

is derived from U.S. median household income and DOT guidance on valuation of travel time. 

The FAA expects an original student pilot applicant will take 30 minutes ($6.50 - $12.61)

17 to 

 17 Filling out form 8710-1 is an additional requirement for the majority of the student pilot applicants. Student pilot 

applicants completing paperwork for an original certificate issuance will need to fill out the entire FAA form 8710-1 

application, which should take about 30 minutes. Multiplying 0.5 hours (30 minutes) to the personal travel time of 

$13 equals $6.50 for the lower-bound. Similarly, multiplying 0.5 hours to the personal time of $25.22 equals $12.61

for the upper-bound.
18

complete Form 8710-1and 20 minutes ($4.33 - $8.4118) for the student pilot applicant to be 

processed. Given the value of time, 50 minutes is valued from $10.83 to $21.02.

19

The CFI and ACR associated with a part 141 school could recoup their expense from the 

student pilot applicant by charging $7.86.

20 Thus, the student could incur an additional cost of 

$7.86. Consequently, the total incremental cost for a student pilot applicant is expected to be

from $18.69 to $28.88.

21 Although mailing charges will be incurred for submitted paper 

applications, this expense will be covered by the authorized individual (discussed later).

Table 3 depicts the value of 50 minutes of the applicant’s time ($10.83 - $21.02) and the 

processing cost ($7.86) multiplied by the number of original student pilot applicants affected by 

this final rule during the 10-year time period of analysis. Student pilots requesting a replacement 

certificate (due to expiration) from the Civil Aviation Registry will not have to follow the 

application procedures under this final rule, but will have to pay a $2 replacement certificate fee

consistent with existing 14 CFR § 187.5.

 18 Airman being processed by an authorized individual will need to have their identity and documents verified as 

well as have their application signed which should take about 20 minutes. Multiplying 0.33 hours (20 minutes) to 

the personal travel time of $13 equals $4.33 for the lower-bound. Similarly, multiplying 0.33 hours to the personal 

time of $25.22 equals $8.41 for the upper-bound. 19 Student processing for lower-bound is $13/hr × 1hr/60 minutes × 50 minutes = $10.83; and upper-bound is 

$25.22/hr × 1hr/60 minutes × 50 minutes = $21.02. 20 A weighted average calculation of the authorized individual processing expense is as follows: $7.86 × .25 to ACR 

+ $25 × .0 to FSDO + $0 × .0 to DPE + $7.86 × .75 to CFI = $7.86. 21 Calculation: $6.50 - $12.61 to fill out application + $4.33 - $8.41 for student’s time with an authorized individual

+ $7.86 recouped authorized individual expense = $18.69 - $28.88.
19

TABLE 3

ORIGINAL STUDENT PILOT APPLICANT COST TO FILL OUT FORM 8710-1, 

AUTHORIZED INDIVIDUAL PROCESSING TIME, AND MAILING CHARGE

(2015 – 2024)

Year

Time to Original Applicant 

(Filling out Form, Processing 

time)

Authorized 

Individual 

Charge (Original)

Total Cost to Student

lower-bound upper-bound lower-bound upper-bound

2015 $403,153 $782,481 $292,762 $695,915 $1,075,243 

2016 $405,141 $786,339 $294,205 $699,346 $1,080,544 

2017 $407,128 $790,196 $295,648 $702,776 $1,085,844 

2018 $409,294 $794,402 $297,222 $706,516 $1,091,624 

2019 $411,635 $798,943 $298,921 $710,556 $1,097,864 

2020 $414,153 $803,831 $300,750 $714,903 $1,104,581 

2021 $417,040 $809,436 $302,847 $719,887 $1,112,283 

2022 $420,120 $815,413 $305,083 $725,203 $1,120,496 

2023 $423,599 $822,165 $307,609 $731,208 $1,129,774 

2024 $427,095 $828,950 $310,148 $737,243 $1,139,098 

Total $4,138,358 $8,032,156 $3,005,195 $7,143,553 $11,037,351 

Since a student pilot will go to an ACR associated with a part 141 school or a CFI for pilot 

instruction, the FAA assumes there are no travel expenses incurred when either the ACR or CFI 

accepts the application.

FAA Costs

The FAA will incur one-time costs estimated at $130,000 to update software and recurring 

costs for processing and issuance of the student pilot certificates. The FAA will update the 

FAA’s Civil Aviation Registry’s software to allow authorized individuals to review and

electronically sign applications through IACRA. Software changes will be made for the Civil 

Aviation Registry to issue the student pilot certificate after successful completion of TSA 

security vetting. Additionally, software changes also will be made to the MedXpress system to

remove the word “student” as appropriate in order to reflect that an AME will no longer issue a 

combination medical certificate and student pilot certificate. 
20

In addition to the software changes, the FAA will incur costs to process each student pilot 

certificate application. This cost includes the expense of FAA staff to review the paperwork, then 

process, scan, and print the plastic certificate, and finally mail the certificate to the student pilot 

applicant. The regulatory impact analysis for the Photo Requirements for Pilot Certificates 

NPRM estimated the cost of including a photograph for future pilot certificates in the FAA 

processing costs. This final rule withdraws the proposed photograph requirement; therefore, the 

FAA has removed this cost element from the processing cost estimate. As a result, the FAA’s 

estimated cost for processing each student pilot certificate is $25, including the FAA’s cost for 

processing replacement student pilot certificates (due to expiration). We provide a range 

estimate from $20 to $50 as a sensitivity test. While the details are separately discussed later, the 

total cost of FAA processing is about $10 million; about $8 million for a $20 per application 

processing cost and increasing to about $20 million with a processing cost of $50.

Table 4 displays the total FAA expenditures for one-time software updates and recurring 

costs for processing and issuing the student pilot certificates.

TABLE 4

FAA ONE TIME AND RECURRING COSTS

(2015 – 2024)

Year Original Replacements

FAA Recurring 

(Original and 

Replacement)

FAA OneTimeTotal Cost 

FAA

PV FAA 

Cost (7%)

PV FAA Cost 

(3%)

2015 36,857 12,684 $1,238,525 $130,000 $1,368,525 $1,278,995 $1,328,665 

2016 36,672 12,621 $1,232,325 $1,232,325 $1,076,360 $1,161,585 

2017 36,487 0 $912,175 $912,175 $744,607 $834,769 

2018 36,318 0 $907,950 $907,950 $692,671 $806,702 

2019 36,164 0 $904,100 $904,100 $644,611 $779,885 

2020 36,025 $900,625 $900,625 $600,124 $754,259 

2021 35,917 $897,925 $897,925 $559,183 $730,095 

2022 35,824 $895,600 $895,600 $521,247 $706,995 

2023 35,763 $894,075 $894,075 $486,318 $685,234 

2024 35,701 $892,529 $892,529 $453,716 $664,125 

Total 361,728 25,305 $9,675,829 $130,000 $9,805,829 $7,057,832 $8,452,314 
21

Authorized Individual Costs

As previously mentioned, the third component of the costs is for the mailing expenses 

incurred by the authorized individual to mail the applications to FAA’s Civil Aviation Registry. 

While an ACR associated with a part 141 pilot school can send a student pilot application either 

electronically or by mail to the Civil Aviation Registry, the FAA has taken the conservative 

approach (greater cost) by estimating this cost associated with mailing an application. Twentyfive percent of the future original student pilot applications will be submitted in paper form by 

the authorized individual. This analysis estimates an average of 20 application packages will be 

sent together each costing $15. Table 5 shows the number of original certificates that are 

estimated to be mailed over the ten year time period of analysis. 

TABLE 5

NUMBER OF ORIGINAL STUDENT PILOT CERTIFICATE APPLICATIONS MAILED

(2015 - 2024)

Year Original

Mailing 

Charges 

(Original)

PV Cost 

(7%)

PV Cost 

(3%)

2015 9,214 $6,911 $6,459 $6,710 

2016 9,168 $6,876 $6,006 $6,481 

2017 9,122 $6,841 $5,584 $6,260 

2018 9,080 $6,810 $5,195 $6,051 

2019 9,041 $6,781 $4,835 $5,849 

2020 9,006 $6,755 $4,501 $5,657 

2021 8,979 $6,734 $4,194 $5,475 

2022 8,956 $6,717 $3,909 $5,302 

2023 8,941 $6,706 $3,648 $5,140 

2024 8,925 $6,694 $3,403 $4,981 

Total 90,432 $67,825 $47,734 $57,906 
22

Cost Summary

Table 6 lists range of total costs to all parties over the next 10 years, as well as for 7 and 3 

percent discount rates.

TABLE 6

TOTAL AND PRESENT VALUE COSTS OF THE FINAL RULE

(2015 - 2024)

(Millions, 2014 $)

AFFECTED GROUP TOTAL COST

PRESENT VALUE

7 PERCENT 3 PERCENT

LOWER UPPER LOWER UPPER LOWER UPPER

STUDENT PILOTS $7.1 $11.0 $5.0 $7.7 $6.1 $9.4

FAA $9.8 $7.1 $8.5

AUTHORIZED INDIVIDUALS $0.07 $0.05 $0.06 

TOTAL $17.0 $20.9 $12.2 $14.9 $14.7 $18.0
23

1. Sensitivity Analysis

In the base case all student pilots over 40 will not have a paper license in 2017 (year 3 for 

those who obtained their license in 2014) due to the fact that they either upgraded licenses or 

needed to renew in two years. Also in the base case, the FAA assumes that by year 2017 there 

will be no requests made for replacements since the student pilots who have not dropped off are 

assumed to have advanced to the next license before the expiration of their paper certificate. The 

FAA provides a sensitivity analysis for the effects of having to process replacements for student 

pilots under the age of 40 who are requesting a replacement in years 2017 to 2019. Given that the 

number of drop-offs from the paper certificate is a best estimate, the FAA did a sensitivity 

analysis on years 2017 to 2019. Below are the replacement numbers for the low and high range.

For 2017 through 2019, in the low and high range, the FAA estimated that 10% of the 

drop-offs came from the holders of the paper certificates. With this new assumption, the balance 

of student paper certificates now gets exhausted by 2019 (the fifth year for those student pilots 

who obtained their paper student pilot certificate in 2014). We believe the replacements for 2017 

through 2019 will be low because the majority of the student pilots under 40 years of age will 

move on to the next license or drop-off before their student pilot certificate expires and that is

why we selected very small percentages compared to the 10.61% used in the base case. In the 

low range, in order to obtain the number of replacements for 2017 through 2019, the FAA 

forecast was multiplied by about .005 percent. In the high case range, the FAA forecast was 

multiplied by about .01 percent. The summary cost table is the same for both ranges. The FAA’s

cost increased from $9.8 million in the base case (no replacements after year 2016) to $9.9 by

varying the replacement numbers in the low and high range. 

Lower bound for replacements:

Year Drop offs from Paper Certificates Replacements

2015 36,857 12,684

2016 36,672 12,621

2017 3,649 628

2018 3,632 625

2019 3,616 622
24

Higher bound for replacements:

Year Drop offs from Paper Certificates Replacements

2015 36,857 12,684

2016 36,672 12,621

2017 7,297 1,256

2018 7,264 1,250

2019 7,233 1,245

Summary Cost Table for Low and High Range of Replacement Certificates 

(Millions, 2014 $)

AFFECTED GROUP TOTAL COST

PRESENT VALUE

7 PERCENT 3 PERCENT

LOWER UPPER LOWER UPPER LOWER UPPER

STUDENT PILOTS $7.1 $11.0 $5.0 $7.7 $6.1 $9.4 

FAA $9.9 $7.1 $8.5 

AUTHORIZED INDIVIDUALS $0.07 $0.05 $0.06 

TOTAL $17.1 $21.0 $12.2 $14.9 $14.7 $18.0

The FAA also provides a sensitivity analysis for the effects of using an alternative value 

regarding FAA’s cost to process each student pilot certificate application. As mentioned in the

previous section, the FAA estimates that the cost to process each student pilot certificate 

application could range between $20 and $50 per application. Table 7 presents the lower and 

upper bounds of the FAA’s cost, as well as the total cost of this final rule. Given the cost of $20 

to produce a student pilot certificate, the lower bound of FAA costs would be reduced by about 

20 percent compared to the final rule, and total costs would be reduced by about 10 percent. 

With a cost of $50 to produce a student pilot certificate, the upper bound of FAA costs would 

almost double compared to the final rule, while total costs would increase up to 50 percent.

TABLE 7

TOTAL AND PRESENT VALUE COSTS FOR STUDENT PILOT CERTIFICATE 

PROCESSING VALUE OF $20 AND $50

(2015 – 2024)

(Millions, 2014 $)

AFFECTED GROUP TOTAL COST

PRESENT VALUE

7 PERCENT 3 PERCENT
25

LOWER UPPER LOWER UPPER LOWER UPPER

STUDENT PILOTS $11.0 $7.7 $9.4

FAA $7.9 $19.5 $5.7 $14.0 $6.8 $16.8

AUTHORIZED INDIVIDUALS $0.07 $0.05 $0.06 

TOTAL $19.0 $30.6 $13.5 $21.8 $16.3 $26.3

*Student pilot personal time of $25.22

Note: The sum of individual items may not equal totals due to rounding.
26

VI. Discussion of Alternatives

For purposes of analysis, the FAA developed an alternative to the final rule. In that 

alternative, the FAA eliminated the AME’s authority to issue a combination student 

pilot/medical certificate and did not give CFIs the authority to accept a student pilot application. 

Without an AME’s authority to issue student pilot certificates or a CFI’s authority to accept 

student pilot applications, the student pilot applicant would incur a financial burden of additional 

travel expenses when applying with other types of authorized individuals, such as, DPEs and

FSDOs. In that case the FAA estimated that 70 percent of the student pilots would travel to a 

DPE, 5 percent to an FSDO, and 25 percent to an ACR associated with a part 141 pilot school.

Under this alternative, 75 percent of the student pilot applicants would incur additional travel 

expenses to and from the DPE and FSDO. The remaining 25 percent applying with an ACR 

associated with a part 141 school would incur zero travel expenses, because they are already 

expected to travel this location due to flight training. 

Just as in the final rule, the costs for the alternative also include the 30 minutes to complete 

Form 8710-1 ($6.50 - $12.61)

22 and 20 minutes ($4.33 - $8.41)

23 for the student pilot applicant 

to be processed with an authorized individual. In addition to these costs, the FAA developed two 

sets of travel estimates that depend on where the pilot lives in order to determine the time and 

mileage necessary for a pilot to visit a DPE or FSDO to submit the necessary materials for the 

application. 

 22 Airman filing paperwork for an original student pilot certificate will need to fill out the entire 8710-1 package, 

which should take about 30 minutes. Multiplying 0.5 hours (30 minutes) to the personal travel time of $13 equals

$6.50 for the lower-bound. Similarly, multiplying 0.5 hours to the personal time of $25.22 equals $12.61 for the 

upper-bound. 23 Airman being processed with an authorized individual will need to have their identity and documents verified as 

well as have their application signed which should take about 20 minutes. Multiplying 0.33 hours (20 minutes) to 

the personal travel time of $13 equals $4.33 for the lower-bound. Similarly, multiplying 0.33 hours to the personal 

time of $25.22 equals $8.41 for the upper-bound.
27

The FAA obtained zip code information for student pilots from the FAA’s Airmen 

Certification Database.24 The student pilot zip code files and a file with the authorized 

individuals zip codes were used with zip code matching software that takes two lists of locations 

and sorts them by geographic distance from one another. By doing this, the FAA obtained the 

average distance a student pilot would need to travel to reach the closest authorized individual. 

The first run included the DPE locations with zip codes. The second run included the FSDO 

locations with zip codes. On average a student pilot will need to travel 17 miles one-way to reach 

their closest DPE location and 55 miles one-way to reach their closest FSDO location.25 26 

Student pilots, under this alternative, would have to spend, on average, almost an additional 

32 minutes compared to the final rule traveling to and from the DPE and FSDO. This additional 

time increases the cost to the student applicant from $6.91 to $13.4 compared to the final rule. 

Thus, the average cost of total time spent by the student pilot applicant is from $17.75 to $34.42.

The student applicant would also incur expenses per mile traveling to the authorized 

individual location. Given a cost of $0.235 per mile of travel (see assumptions) and an average 

round-trip distance of 29.3 miles to an authorized individual, the cost of miles traveled per 

student pilot applicant is $6.89.

In addition to the time spent filling out the form, time being processed with an authorized 

individual, and the travel expenses, the FAA estimated the charges by authorized individuals to 

the applicants. Using the aforementioned percentage breakout of student pilot applicants at each 

type of authorized individual, the weighted average of these charges is $19.47.

27 Table 8

presents the details of time, mileage, and cost for a student pilot to complete an application.

 24 http://www.faa.gov/licenses_certificates/airmen_certification/releasable_airmen_download/

25 Round-trip of 34 miles (17 × 2) will take: (34 miles / 55 MPH) × (60 minutes / 1 hour) = 37 minutes. 26 Round-trip of 110 miles (55 × 2) will take: (110 miles / 55 MPH) × (60 minutes / 1 hour) = 120 minutes. 27 The percentage breakout is 25 % with an ACR associated with a part 141 school, 70% with a DPE, and 5% at an

FSDO: $7.86 × .25 + $25 × .7 + $0 × .05 = $19.47.
28

TABLE 8

TIME, MILEAGE, AND COST FOR A STUDENT PILOT TO COMPLETE A PILOT 

APPLICATION BY DISTANCE

Category

Pilot Location Weighted 

Average

Average Cost

ACR (Part 141 

School) DPE FSDO LOWER UPPER

Complete Form 8710-1 (minutes) 30 30 30 30 $6.50 $12.61

Process Form 8710-1 (minutes) 20 20 20 20 $4.33 $8.41

Round trip travel (minutes) 0 37 120 31.9 $6.91 $13.41

Total time spent 50 87 170 81.9 $17.75 $34.42

Miles traveled (round-trip) 0 34 110 29.3 $6.89

Portal Charges $7.86 $25.00 $0.00 $19.47 $19.47

Total Cost to Pilot $44.10 $60.78

In sum, the average cost for each student pilot applying at an authorized individual under the 

alternative is from $44.10 to $60.78.

28 Also, mailing expenses will be incurred by all authorized 

individuals (ACR, DPE, and FSDO) to mail the applications to FAA’s Civil Aviation Registry. 

 28 Calculation: $17.75 + $6.89 + $19.47 = $44.10 (lower-bound); and $34.42+ $6.89 + $19.47 = $60.78 (upperbound).
29

VII. Benefit-Cost Summary

This final rule responds to section 4012 of the Intelligence Reform and Terrorism Prevention 

Act (IRTPA) and facilitates security vetting of all student pilot certificate applicants before the 

FAA issues a student pilot certificate which helps to ensure aviation safety. As Congress 

understood there would be additional costs due to a quicker vetting process. As shown in Table 

6, the estimated compliance cost of this rule ranges from $17 to $20.9 million. Although the 

potential benefits are not quantifiable, this final rule responds to the direction of Congress and 

therefore provides a sufficient reasoned determination to justify the costs.