### DRAFT REGULATORY EVALUATION, INITIAL REGULATORY FLEXIBILITY DETERMINATION, TRADE IMPACT ASSESSMENT, AND UNFUNDED MANDATES

DETERMINATION

NOTICE OF PROP OSED RULEMAKING

PHOTO REQUIREMENTS FOR PILOT CERTIFICATES

(14 CFR 61)

OFFICE OF AVIATION POLICY AND PLANS

OPERATIONS REGULATORY ANALYSIS BRANCH

APO-310

David F. Teitelbaum

May 2009

### TABLE OF CONTENTS

I. Introduction and Background __________________________________ 1

II. Proposal _________________________________________________ 1

III. Cost of Compliance ________________________________________ 4

IV. Discussion of Benefits _____________________________________ 19

APPENDIX A - Tables 20 APPENDIX B - Foreign Pilots 33

APPENDIX C – Costs for Photo ID 35 APPENDIX D - Anticipated Equipment and Software 38

Executive Summary

This proposal would require digital ph otos on all pilot cer tificates. The FAA proposes a 5-year phased implementation sc hedule. This schedule includes a “Trigger-based” approach to issue pilo t certificates with photos to people interacting with the FAA during the impleme ntation period. The schedule also includes a “Non-Trigger-based” approach th at requires a pilot certificate with photo to exercise pilot priv ileges after a 3-, 4-, or 5-year period dependent on the type of certificate.

This proposal would modify the applicatio n process 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 because of the increased costs of producing certificates with photos. Because the accuracy of a photo degrades as time goes on, the FAA proposes to limit the duration of pilot privileges for pilot certif icates with photos. Consistent with the Real ID Act, the FAA proposes an 8-year duration.

There are currently about 740,000 pilo ts and 93,000 CFI’s that would be covered by this proposal. Given future pr ojected growth in all pilot categories and given the requirement to renew ever y 8 years, the FAA anticipates that the FAA would process 4.40 million photo ID’s from 2010 to 2029.

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, either a Knowledge Testing Center, Designated Pilot Examiner, or Flight Service Distri ct Office. These portals would incur costs of $33.2 million to process th is information and pass it on to the

### Airman Registry at the FAA. The FAA would incur costs of $239.7 million to process the cards. Total costs, over 20 years, sum to $718.7 million.

This proposal responds to the Intellige nce Reform and Terrorism Prevention Act (IRTPA) by requiring digital photos on all pilot certificates. Congress, which represents the will of the Amer ican people, has mandated that the FAA improve pilot licenses by including a ph oto on the license. The proposal requiring owners to personally appear befo re authorized persons and to produce proof of identity including photo identif ication would be a significant help in the prevention of fraudulent an d fictitious registration.

The proposed rule is not expected to ha ve a significant impact on international trade, a significant impact on a substa ntial number of small firms, or an

unfunded mandate.

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### I. Introduction and Background

This proposal would require digital ph otos on all pilot certificates. This proposal responds to th e Intelligence Reform and Terrorism Prevention Act (IRTPA), which was signed into law in December 2004. As part of the Drug Enforcement Assistance (DEA ) final rule (published February 28, 2008) the FAA required all pilots to obtain a pla stic certificate (exempting temporary certificates or student pilot certificat es) that meets all of the relevant requirements of IRTPA, except for inclu ding photos of pilots on their pilot certificates. This proposal includes th e requirements that the certificate be resistant to tampering, alteration, and counterfeiting; include s a photograph of

the individual to whom the license is issued; and is ca pable of accommodating a digital photograph, a biomet ric identifier, or any ot her unique identifier that the Administrator considers necessary. In the DEA final rule, the FAA also exempted holders of temporary pilot certif icates and student pilot certificates from the requirement for plastic certif icates. The intended effect of this proposal is to fulfill the remaining requirement of IRTPA by requiring digital photos on all pilot certificates.

In 2003, the FAA discontinued issuing pa per certificates started issuing plastic certificates only. The current rules state that as of March 31, 2010, all pilots, except student pilots, must have plastic cer tificates. The plasti c certificates are manufactured from high quality plastic card stock, and have micro printing that contains certain words and phrases, a hologram, and an UV-sensitive layer to resist tampering, altera tion, and counterfeiting.

II. Proposal

The FAA proposes to fulfill the requirements of the IRTPA by requiring a photo of the pilot on all plas tic pilot certificates. This proposal encompasses student pilot certificates, which would be issued with a photo of the student pilot on plastic card stock. The FAA would continue to allow the use of paper temporary pilot certificates when upgrad ing a pilot certificate (such as going from a student to a sport, recreational, or private pilot certificate) or adding a rating (such as an instrument rating) to a pilot certificate provided that the temporary paper certificates accompanie s the underlying plastic certificate.

The FAA proposes a 5-year phased imple mentation schedule. This schedule includes a “Trigger-based” approach to is sue pilot certificates with photos to people interacting with the FAA dur ing the implementation period. The

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### schedule also includes a “Non-Trigger-b ased” approach that requires a pilot certificate with photo for a person to exerci se pilot privileges after a 3-, 4-, or 5-year period depending on the type of certificate, as discuss ed below. This proposal would not revoke or otherwis e cancel a previousl y-issued plastic

certificate.

This proposal would modify the applicatio n process 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 because of the increased costs of producing certificates with photos.

Currently, the FAA does not charge for issuing or replacing an airman certificate, except for a $2 fee to replace a lost or destroyed ai rman certificate. Although the FAA has statu tory authority to charge a fee for issuing a pilot certificate, the FAA previously has not ex ercised that authority; 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 (CPI-U). The FAA proposes to charge this maximum fee for issuing a new or replacement pilot certificate with photo. The FAA may adjust this fee periodically to correspond with changes in the CPI-U. The FAA acknowledges that the cost of producing pilot certificates exceeds the proposed fee, but the FAA may not exceed statutory authority to recover costs.

The FAA anticipates using designees (also known as por tals) to accept and verify applications to minimize the in convenience to pilot certificate holders and new applicants when applying for a pilot certificate with photo. The FAA anticipates that designees would also charge a fee to accept and verify an application for a pilot certificate with photo.

Many pilots would already interact w ith the FAA during one of the following “triggering” events. Specifi cally, the FAA is proposing to require all persons to provide a photo when the follow ing “triggering” events occur: 1. Obtaining a new pilot certificate or rating (including Student Pilot certificate) 2. Obtaining or renewing a flight instructor certificate The pilots interacting with the FAA during one of these “triggering” events

would not have an additio nal meeting with the FAA to get their photo ID. Often, when interacting with the FAA, pilots update FAA records to record changes to vital information, such as changes in name, gender, and/or citizenship.

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### If pilots do not receive a pilot certificate with photo resulting from any one of the above “triggering” events, the FAA proposes a phased-in approach to requiring pilots to obtain a nd carry a pilot certificate with photo to exercise the privileges of the certificate. To exercise the privileges of the pilot certificate, persons holding an airline transport pil ot (ATP) certificate must obtain a pilot certificate with photo within 3 years afte r the final rule becomes effective; those holding a commercial pilot certifi cates must obtain a pilot certificate with photo within 4 years; and th ose holding private, recr eational, and sport pilot certificates must obtain a pilot cer tificate with photo within 5 years.

The FAA assumes that applications for the pilot certificate with photo would be evenly spread throughout the implementatio n period. If all pilots wait until close to the end of the pe riod to apply for the certi ficate, there undoubtedly would be delays in processing and receip t of the new certificate. The phased implementation period balances the F AA’s ability to receive and process applications for replacement certificates, while allowing the FAA to maintain its existing range of services.

Because the accuracy of a photo degrades as time goes on, the FAA proposes to limit the duration of pilot privileges for pilot certificates with photos. Consistent with the Real ID Act, the FAA proposes an 8-year duration.

Under this proposal, it would be the pilo t’s responsibility to provide a current photo before the expiration of that pilot’s privileges associated with that pilot certificate. If a pilot requests changes to a certificate, such as changing the certificate level of or adding a rating to the certificate, the FAA would issue a new certificate with the current photo on file. That new certificate would have the same pilot privileges expi ration date as the certificate that it is replacing. However, if a pilot wishes to submit a new photo with the certificate, the FAA would issue a new certificate that expires eight years from the month of issue.

The FAA includes student pilots in th is proposal to meet the IRTPA requirements. The DEA final rule, which required plastic pilot certificates, did not include student pilots. The FAA pr oposes to make conforming changes to require all student pilot certificates to be made of plastic and include a photo of the certificate holder. As a result, student pilot certificates would be issued by only the FAA’s Airman Certification Branch (AFS-760).

The FAA proposes to disc ontinue use of an Aviation Medical Examiner (AME) for the application and issuance of a stude nt pilot certificate. Currently, except in the case of glider, balloon, and light sp ort aircraft, a student pilot’s first

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### contact with the FAA usually is thro ugh an AME because of the medical certificate requirement. The AME may is sue both a medical certificate and a student pilot certificate (often referred to as a combination certificate). Under this proposal, a student pi lot would obtain a student pilot certificate with photo that is issued by AFS-760 pr ior to conducting solo flight s. A person wishing to obtain a student pilot certifi cate would still obtain a me dical certificate from an AME; however, that person may not apply for a student pilot certificate with an

AME.

Also, under this proposal, Designated Pilot Examiners (DPE’s) no longer would issue student pilot certificates. However, DPE’s would be authorized to accept an application for a student pilot certificate. In addition, designated computer testing centers, designated airm en certification representatives, local Flight Standards District Offices (FSDOs), and International Field Offices also would be authorized to accep t an application for a Student Pilot certificate.

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. In the future, however, the FAA anticipates accepting a dig ital photo; the FAA would revise its guidance material as technology advances and additional methods ar e available for photo

submission.

III. Cost of Compliance

In this analysis, the FAA estimated futu re costs over a 20-year period, from 2010 through 2029. As required by the Office of Management and Budget, the present value of this stream of costs wa s calculated using a discount factor of 7 percent. All costs in this analysis are in 2008 dollars.

Assumptions

$37.20 – Hourly rate of an airman’s time 1

4 1 To estimate the wage rate for aircraft owners, the FAA used the value of air travel time, as

discussed in Economic Values for Evaluation of Federal Aviation Administration Investments and Regulatory Programs (Values), FAA. This measures the value that an individual places on their time spent traveling. Time is a valuable economic resource, which may be devoted to work or leisure activities, and is measured as an oppor tunity cost equal to the amount of foregone activity. Economic theory postulates that individua ls will adjust the amount of time they devote

to work and leisure such that the value of an add itional small increment of either will be valued at the wage rate.

### $54.42 – Total cost to the F AA of producing a Certificate $22.00 – Proposed fee for issuing a ne w or replacement pilot certificate with photo 2 

### $8.00 – Cost of two hard copy photos $0.585 – Cost per mile for an automobile 3



### Analysis of Proposed Changes

Section II described proposed changes to part 61. In this section, the FAA will first look at the total number of photo ID’s that would need to be processed. Next, the FAA will look at the costs of the “trigger-based” approach, the “nontrigger-based” approach, and replacement ce rtificates. Finally, this analysis will look at the costs to the FAA and the portals.

Total Number of Pilots

As of January 15, 2009, there were 740,400 active pilots. 4 

### Table 1 shows the distribution of these pilots among the different license categories: Table 1 – Pilots by License Categories Airline Transport Pilot 149,685
Commercial - Domestic Based 139,469 Commercial – Foreign Based 29,171
Total Commercial 168,640

Private - Domestic Based 240,048 Private - Foreign Based 97,873

Total Private 337,921 Recreational and Sport 2,908

Table 1-1 in Values discusses and calculates the time value for three types of activities for both air carriers and general aviation passengers – these three types of activities are personal, business, and all purposes. Since the majority of aircraft owners are general aviation rather than air carrier pilots and since the ‘all purposes’ category constitutes the broadest measure of passenger time in calculating costs for this analysis , the FAA will use this hourly rate to calculate the time needed to fill out this form. The hourly rate is $37.20 per hour.

2 While this is a real cost to the pilots, these paym ents to the FAA are consider ed transfer payments; OMB Circular A-4 defines transfer payments as “monetary pa yments from one group to an other 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.

3 In July 28, 2008 Federal Register, GSA announced a change in privately owned vehicle mileage reimbursement rates for the use of privately owned vehicles effective August 1, 2008. The increase for privately owned automobile w as raised from $0.505 to $0.585 per mile.

5 4 Source: AFS-760, Airmen Certification BranchTotal Private, Recreat ional and Sport 340,829

Student Pilots 81,288

TOTAL 740,442 

### In addition, there were 93,400 Certified Flight Instructors (CFI’s); all CFI’s have either an Airline Transport Pilot (ATP) or Commercial license. The FAA will base projections on the FAA annual forecast. 5



### There were a total of about 106,200 or iginal pilot certificates issued in 2008 (which includes approximately 4,400 orig inal flight instructors). Original certificates are when the pilot received their original student, recreational, sport, private, commercial, or ATP rating. An original certificate is a “triggering” event. Also, a pilot can ear n one or more additi onal ratings, and these additional ratings qualify as “trigger” events. In FY 2008, there were approximately 38,300 addi tional ratings issued.

Pilots have to replace their certificates for a number of reasons. A certificate needs to be replaced if the certificate is lost or destroyed, if the pilots needs to remove a Social Security Number (SSN) or change the certificate number from an SSN, if the pilot has obtain the “Engl ish Proficient” endorsement, or if the pilots is complying with the paper to plastic rule. Requests for these replacements can be made via written requ est or on the AFS website. The FAA processed about 205,400 replacements in 2008. However, this number was inflated that year because of the latte r two reasons – the “English Proficient” endorsement and the paper to plastic ru le. Looking at the numbers from 2004 to 2007 yields an average of 104,900 replacements.

5 Source: Table 29 in “FAA Aerospace Forecasts Fiscal Years 2009 – 2020, U. S. Department of Transportation Federal Aviation Administration, Office of Policy & Plans.” Table 29 has estimated 2008 year-end totals for domestic ATP, Commercial, Private, Recreational, Sports, and Student pilots; these totals are based on a re port from AFS-760 dated 1/5/2009. These totals differ from the 1/15 report in two ways: - the 1/15/2009 data includes foreign pilots; and - the domestic pilot figures will differ between the two to a small extent because they’re dependant on the pilot’s medical status, which co rrelates with an expiration date on the medical

certificate.

6 To project th e number of certificates, the FAA took a ratio of the number of pilots from the 1/15 report to those used in the Forecast, and a pplied this ratio to the forecasts in Table 29. For example, the number of ATP certificates from the 1/15 report, as shown in Table 1 above, is 149,700, while the number from Table 29 is 146,800, so the ratio is 1.019 (calculation: 149,700/146,800). Thus, the projections in Ta ble 29, from 2009 to 2025, were multiplied by 1.019 to obtain the data used in this analysis . Table 29’s data only goes to 2025; to get projections from 2026 to 2029, this analysis took the difference between the numbers for 2024 and 2025 and applied this difference to the out years. For ATP certificates, the number of projected certificates in 2024 and 2025 are 158,200 and 158,600, respectively, for a difference of 400; this difference was applied to each of the years 2026 through 2029.

### As discussed in the Preamble, a “trigger-base d” event is one in which pilots are already interacting with the FAA during the implementation period, so adding the photo is simply one additional step in the process. A pilot interacts with the Agency when they obtain a new pilot certificate or rating, obtain a new flight instructor certificate, or renew a fligh t instructor certificate. The pilot is already there, so for the costs, as will be described below, there would be no additional time, transportation, or proce ssing costs. When these pilots renew in 8 years, however, this renewal would n ot be considered a “trigger-based” event as the pilot would not be in teracting with the FAA for any reasons other than

renewal.

The FAA examined the number of original and additional ratings broken down by pilot type from 1998 to 2008 and used this data in making projections. 6


### Both of these categories hit a peak in 2002. The number of original ratings leveled off from 2003 to 2007, but de clined in 2008, while the number of additional ratings has stayed roughly th e same since 2003. The decline in the number of original ratings in 2008 ma y be due to the slowing economy. In making these projections over the next 20 years, the FAA will use the average of the last 4 years of da ta to project the number of certificates in each pilot certification category type.

Number of ATP Certificates

In 2008, there were about 149,700 ATP certificates. Of these, there were about 5,100 original certificates and approximately 15,700 a dditional ratings certificates. Both of these are “trigger” events. The total “trigger” events sum to 20,800 certificates or 13.9% of the total number of ATP certificates. The number of “non-trigger” events woul d be the difference between total ATP certificates and the number of “trigger” events: 128,900, or 86.1% of total ATP

certificates.

For future “trigger” events, the FAA assumes the same percentage of original

and additional certificates to total ATP certificates, 13.9%. From 2010 to 2012, given a projected 151,200 certificates, there would be 21,000 “trigger-based” certificates processed (calculation – 151,200 x 13.9%). These 21,000 would have to renew their certificates eight year s later. In 2011, there would be an additional 700 pilots; these new pilots would be intera cting with the FAA in the

7 6 Source: Table 17 and 18 from http://www.faa.gov/data_research/aviation_data_sta tistics/civil_airmen_statistics/2007/. This gives data through 2007; 2008 data was obtained directly from AFS-760.

### process of getting their license, so these would be “trigger” events. From 2011 through 2029, there would be an additi onal 9,000 pilots getting their ATP licenses, and these would all be “trigger events”. As can be seen in Table A-1 in the Appendix, over 20 years, there wo uld be 30,000 pilots registering to get their new photo ID. 7



### ATP pilots getting their licenses due to “ non-trigger” events would need to do so over a 3 year period. The FAA assu mes that this would happen uniformly, so that 1/3 of these pilots would ge t their licenses each year. Given the projected “non-triggered” 130,200 pilots in 2010 (calculation: 151,200 x 86.1%), about 43,400 license s would be processed in each of the three years – 2010, 2011, and 2012. They would need to renew these licenses every 8 years. In addition, as mentioned above, all pilots who got their licenses through “trigger” events would renew them as “non-trigger” events. As can be seen in Table A-1, over 20 years, there would be 130,200 pilots re gistering to get their new photo ID and 310,100 renewing their ID.

Number of Commercial Certificates

In 2008, there were approximately 168,600 commercial certificates. There were about 8,800 original certificates and approximately 9,300 additional ratings certificates. Both of these are “tri gger” events, so total “trigger” events sum to 18,100 certificates, or 10.7% of total commercial certificates. The number of “non-trigger” events w ould be the difference between total commercial certificates and the number of “trigger” events, 150,500, or 89.3%

of total commercial certificates.

For “trigger” events, the FAA assumes the same percentage of original and

additional certificates to total commerci al certificates into the future, 10.7%. Thus, from 2010 to 2013, given a projected 168,200 certificates, there would be 18,100 “trigger-based” certificates proces sed (calculation – 16 8,200 x 10.73%). These 18,100 would have to renew their certificates eight years later, and as described above, these renewals would be considered “non-tri gger” events. In 2011, there are an additional 800 pilots, and as above, since these pilots would be interacting with the FAA, these w ould be “trigger” events. However, in 2012 through 2014, the FAA projects a decrease in the total number of commercial certificates; in 2012 and 2013 , this decrease would be subtracted from the number of “trigger-based” events, but in 2014, the number of new

8 7 The FAA Forecast had 146,800 ATP in 2008, so this analysis multiplied the ATP forecast numbers by 101.9% (calculation: 149,700/146,800)..

### commercial certificates processed would be zero. As can be seen in Table A-2 in the Appendix, over 20 years, there wo uld be 52,400 pilots registering to get their new photo ID.

Commercial pilots getting their licenses due to “non-trigger” events would need to do so over a 4 year period. The FAA assumes that 1⁄4 of these pilots would get their licenses each year. Given the projected “non-triggered” 150,200 pilots in 2010 (calculation: 168,200 x 89.3%) , 37,500 licenses would be processed in each of the four years – 2010, 2011, 2012, and 2013. They would need to renew these licenses every 8 years.

As can be seen in Table A-2, over 20 years, there would be 150,200 pilots registering to get their new photo ID and 342,200 renewing their ID.

Number of Private, Recreational, and Sport Pilot Certificates

Private, recreational, and sport pilots wou ld have a 5-year licensing process. In 2008, there were approximately 337, 900 private certificates. There were about 2,900 recreational and sports certificat es in that year as well, for a total of 340,800. Of these, there were ab out 20,500 original certificates and approximately 13,300 addition al ratings certificates. Both of these are “trigger” events. Total “trigger” events sum to 33,700 certificates, or 9.9% of total private, recreational, and sport licenses. The number of “non-trigger” events

would be the difference between tota l private, recreational, and sport certificates and the number of “trigger” events, or 304,200, 90.1% of total

certificates.

For “trigger” events, the FAA assumes the same percentage of original and additional certificates to total private, recreational, and sport certificates into the future, or 9.9%. Thus, from 20 10 to 2014, given a projected 349,500 certificates, there would be about 34,600 “trigger-based” certificates processed (calculation – 349,500 x 9.9%). These would have to renew their certificates in eight years. From 2011 through 2014, the FAA projects a decrease in the total number of these certificates, so the number of new certificates would be subtracted from these “trigger-based” ev ents . In 2015, the FAA projects an additional 1,300 pilots, a nd as above, since these pi lots would be interacting with the FAA, these would be “trigger” ev ents. As can be seen in Table A-3 in

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### the Appendix, over 20 years, there would be 5976,800 pilots registering to get their new photo ID. 8



### Private, recreational, and sport pilots gett ing their licenses due to “non-trigger”

events would need to do so over a 5 year period. The FAA assumes that 1/5 of these pilots would get their licenses each year. Given the projected “non-trigger” 314,900 pilots in 2010 (c alculation: 349,500 x 90.9%), between 63,000 licenses would be processed in 2010, 2011, 2012, 2013, and 2014. They would need to renew these licenses every 8 years. As can be seen in Table A-3, over 20 years, there would be 314,900 pilots re gistering to get their new photo ID and 612,400 renewing their ID.

Number of Student Pilot Certificates

All student certificates would be “tri gger” events because a student can no longer obtain a combination medical certificate/student pilot license from an AME or a student pilot license from a DPE. 9 

### Thus, they need to be treated as different from all other “trigger” events in terms of costs. Under this proposal, student pilots would have a wide variety of choices in terms who they can submit their application to, and these include DPE’s, designated computer testing centers, designated airmen cer tification representatives, FSDO’s, and International Field Offices. The FAA assumes that student pilots would go to KTC’s, DPE’s, and FSDO’s in the follow ing percentages, 70%, 25%, and 5%, respectively. 10 

### Under current FAA rules, a stud ent pilot certificate is valid for 24 months; this rulemaking would extend it to 8 years. Under these proposals, the FAA anticipates that 

### no student would be renewing their pilot certificate. There would be initial applications fo r a student pilot certificate and in t his analysis, the FAA assumes that no studen t renews their photo ID – in the 8 years before they would have to rene w their photo ID, they would acquire

another certification.

In 2008, there were 81,300 student certific ates and 1,500 addi tional certificates, where student pilots got an additiona l rating. These approximately 81,300 certificates can be broken down as follows, in Table 2:

8 This analysis used forecast ratios of 151.8%, 101.2%, and 101.1% for private, recreational, and sport pilots, respectively.

9 Currently, almost all student pilots go to AME’s. This is because students also need a medical certificate. AME’s can issue a combination student pilot/medical certificate and there are over 3,700 AME’s. Going to AME’s is basically a matter of convenience.

10 10 Source: Certification and General Aviation Operations Branch, AFS-810Table 2 – Student pilot certificates – 2008 Designated Exam iner approved 565 FAA Inspector approved 258

No test 1,451

New student issuances from AME's 41,434

Renewal issuances from AME's 21,306 FSDO issuances, based on AME information 2,150 Carry-over from previous y ear (2007 or before) 14,124

TOTAL 81,288 

### The FAA assumes no renewal issuances under this proposal. Less than 20% of 2008 student certificates were based on 2007 or prior year issuances; given an 8 year “life” of a student certificate, the FAA anticipates no student certificate
reissuances, i.e., no 

### individual would maintain a student pilot certificate for longer than 8 years. In 2008, about 45,900 new student certificates would have been issued under this proposal, 11 

### or 56.4% of the total number of student pilots. In addition, ther e were approximate ly 1,500 additional student certificates (1.9% of total student pilots), thus that the total number of “trigger” events would be about 47, 400, or 58.3% of the total number of student pilots.

In 2010, the FAA projects 72,300 student certificates; 56.4% of these would be 40,800 original issuances. Adding this to the additional student certificates means that the FAA would have to pro cess 42,100 student certificates. In future years, the FAA would process both new original student certificates and

additional certificates. T his can be seen in columns (A), (B), and (C) in Table A-4 in the Appendix; over 20 years, the FAA would process 947,300 student photo ID’s. 12



### Number of CFI’s

In 2008, there were 93,400 certified flight instructors (CFI’s). In order to be a CFI, a pilot needs to either have a ATP or commercial license. While obtaining a CFI designation is a triggering event, th ere is no separate requirement to have a separate CFI certificate. Hence, there would be no addition al costs to those pilots who obtain orig inal or additional CFI certificates.

Number of Replacement Certificates

11 This is the sum of all the components in Table 3 except for renewals and carry-overs.

11 12 The numbers in column (a) used a forecast ratio of 100.4% for all student licenses, with column (b) being 56.4% of column (a) and column (c) being 1.9% of column (a).

### This analysis is using an average from 2004 to 2007 of 104,900 replacement certificates; the FAA does not have these broken out by pilot ce rtificate types. Some of these are covered by this proposal. There are two different ‘pools’ of certificates – those that are needed to replace certificates that: a) have been lost or destroyed – these can be handled through the mail or via the web; and 13



### b) are due to other reasons, such as a change in address, if the pilot has obtain a the “English Proficient” endor sement, or if the pilot has had to comply with the paper to plastic rule. This rulemaking does not include b) – while there is a requirement for a pilot to notify the FAA of a change in address, a new certificate would only be issued if

the airman wanted to have his/her FAA certif icate to reflect the new address. It is not a requirement of the rule to ha ve a new certificate is sued in case of an address change; thus, any change is vo luntary and can not be charged to this proposal. In addition, as mentioned above, the latter two examples in b) are due to other rulemakings, and so shou ld not counted in the costs of this rulemaking. About two thirds of the re placement certificates or about 70,000, 14


### were for reason a). As can be seen in column (D) of Table A-4, over 20 years, there would be 1.45 million replacement p hoto ID’s issued. In almost cases, pilots would not have to submit a new photograph.

Total Number of Certificates

Over 20 years, the FAA projects 2.95 mill ion pilots registering to get their photo ID’s. Included in this would 1. 26 million pilots renewing their photo ID’s, and all these would be considered to be “non-trigger” events. In addition, there would be 1.45 million replacement ID ’s issued. In total, the FAA would be processing 4.40 m illion photo ID’s fr om 2010 to 2029.

13 This analysis is using the ratio of replacement certificates in 2008, 205,400, to total pilots in Table 29, 613,700, for a ratio of 0.335. This ratio was multiplied by the projections of total pilots

for 2010 to 2029.

12 14 Source: AFS-760, Airman Registration Branch, Civil Aviation Registry.

### Costs

The FAA envisions the airman would pr ovide the FAA a photo using one of the portals (KTC, FSDO, DPE, etc.) by prov iding a hard copy. If the airman provides a hard copy photo and Form 8710-1, the portals would verify the airman's identity, physically sign the 8710-1, and forward the paperwork package to AFS-760. This analysis as sumes that the pilot would provide hard copy photos, which many pharmacies sell for $8.

The material could be forwarde d to AFS-760 in one of two ways: 1) The application would consist of one piece of 8.5 x 11 sheet of paper (8710-1) and one 2x2 photo. Maile d individually, the FAA estimates that it would cost $3 each (delivery co nfirmation, etc.). But given the large number of application packages that each portal would process per week, the FAA will assume a cost of $15 per batch mailing of 20 applications; each batch could be mailed every week or so. 2) The portals could scan a hard copy of the photo for inclusion into the Integrated Airman Certificate and/or Rating A pplication (IACRA). 15


### The portals would also verify the airm an's identity and di gitally sign the 8710-1, and the IACRA package would be uploaded to AFS-760. This analysis is assuming that all applications would be mailed instead of being uploaded via IACRA.

In the future, the FAA anticipates accepti ng a digital photo, which would allow the material to get to the FAA in one of the following ways: 1) Either the airman or the portals could upload a digital photo that the airman brings into IACRA, and, as ab ove, the portals would verify the airman's identity and dig itally sign the 8710-1, and the IACRA package would be uploaded to AFS-760. 2) One of the portals could take a digit al photo of the airman. If the airman has the portal capture the digital pic ture, the portal would electronically attach it to the IACRA-generated 8710-1, verify the airman's identity, and digitally sign the 8710-1. The IACRA package would be automatically uploaded to AFS-760.

Cost of a “Trigger” Event As discussed in the Preamble, a “trigger-base d” event is one in which pilots are already interacting with the FAA duri ng the implementation period. Adding

13 15 It is anticipated that IACRA will be the only pub lic access portal for digital photos. In turn, the IACRA sub-system will feed the digital photos in to the Airmen Registry Branch (AFS-760) main

system.

### the photo is simply one additional st ep in the process. A pilot personally interacts with the Agency when they obta in a new pilot certificate or rating, obtain a new flight instructor certificate, renew a flight instructor certificate, and, in some cases, when they need to get an additional replacement certificate due to changes in vital information (these will be covered in a separate section, below). The pilot is already interacting with the FAA, so the costs, as per this proposal, the cost of the photo ($8) and the time to get the photo and fill out 8710-1 ($21.70) 16 

### for a total of $29.70. (As discussed in the Assumptions section, the $22 application cost is considered a transfer fee and is not considered a cost of this rulemaking. ) This would apply to all non-student pilot “trigger” events which totals to 194,800 pilots. As can be seen in Table A-5 in the Appendix, over 20 years, costs for initial registration equals $4.22 million ($2.46 million, discounted).

Cost of a “Non-Trigger” Event All pilots who woul d not be interacting with the FAA for the aforementioned reasons would need to renew on a 3, 4, or 5 year schedule discussed above. In addition, student pilots would need to be included in these calculations, even though theirs would not be done on a phased-in schedule. The total number of these pilots can be seen in Table A-6 in the Appendix, and this includes 1.54 million for initial registration and 1.26 m illion for renewal, for a total of 2.81

million.

The FAA developed two sets of estimates (based on where the pilots live) for the time and mileage necessary for a pilot to fill out the Form 8710-1 paperwork, get a photo, and visit a KTC, DPE, or FSDO to submit the necessary materials to get the photo ID. In this analysis, the FAA assumes that the pilot population in the U.S. is rand omly distributed. Thus, the percentage of pilots living in urban areas to the enti re pilot population is the same as for the U.S. population as a whole, 82%. 17 

### The FAA bases the amount of time necessary to do the above ta sks and drive the n ecessary mileage is a function of whether the pilot lives in an urban setting or a rural setting. Table 3 shows the

FAA’s estimates as to the amount of tim e and mileage for urban and rural areas and the weighted average, rounded to the closest 5 minutes or 5 miles:

16 Airman filing paperwork for an original or a dditional rating would need to fill out the entire 8710-1 package, which should take about 30 minutes. For the CFI rating and for replacement certificates, the airman would only need to fill out part of the form, which should not take more than 15 minutes to complete. As will be explaine d further in the ‘non-trigger” section, the FAA is using 35 minutes as the average time to fill ou t this form and get the photo. Multiplying 0.58 hours (35 minutes) times the personal time of $37.20 equals $21.70.

14 17 https://www.cia.gov/library/publications/the-world-factbook/print/us.htmlTable 3 – Time and Mileage

Urban Rural Weighted Average Time (in minutes) Fill out 8710-1 and get photo 30 45 35 Round trip travel 60 150 75 Time to be processed at KTC, by DPE or at FSDO 20 20 20

Total 110 215 130

Miles 40 100 50 

### Given the value of time and mileag e noted above, 130 minutes equates to $80.60 and 50 miles equates to $29.25. 18 

### As mentioned above, this analysis assumes that each pilot brings hi s or her own photo, at $8.

The FAA bases costs on 70% of these pilo ts getting their license from a KTC, 25% from a DPE, and 5% from a FSDO; these estimates are based on location and availability. Currently there are two major testing companies that are authorized to perform know ledge testing for the FAA at KTC’s. These testing

centers are located to serve a wide geographic range (approximately 800 both nationwide and international locations). 19 

### There are about 1,000 DPE’s in differing parts of each state, 20 

### and 83 FSDO‘s. Appointments are mandatory with DPE’s and at FSDO’s and are optional at KTC’s. At each of these portals, the tasks include verifying the pilot, verifying the documents, accepting the photo, and forwarding the applicable material to the FAA (mailing charges will be computed separately). The charges differ at each:

- The FAA assumes that the KTC w ould charge between $35 and $50 per application. The FAA is using the midpoint, $42.50, to estimate costs. - The FAA assumes that the DPE would charge $25 for a simple application, where the pilot provides the photo, and $50 if the DPE captures the photo. For this analysis, the FAA is assuming the lower charge.

- The FAA assumes no additi onal charge at a FSDO. The weighted average of these charges equals $36. 21 

### Total costs for each “nontrigger” event sum to about $153. 22 

### As can be seen in Tables A-6 and A-7 in

18 Value of time = $37.20/hr x 1hr/60 minutes x 130 minutes = $80.60 and mileage = $0.585/mile x 50 miles = $29.25.

19 The number of KTC’s varies over the course of a year, so the FAA is using 800 as the average

number of KTC’s.

20 The number of active DPE’s fluctuates over the c ourse of a year, so the FAA is using 1,000 as the average number of DPE’s.

21 $42.50 x .7 + $25 x .25 + $0 x .05 = $36.

22 Calculation: $80.60 + $29.25 + $8 + $36.

15

### the Appendix, over 20 years, costs fo r initial registration equals $237.336 million ($151.92 million, discounted) an d for renewal equals $194.59 million ($76.39 million, discounted), respect ively, for a total of $431.91 million ($228.31 million, discounted).

Cost of a Replacement Event

As discussed above, about 70,000 replacement certificates wo uld be covered by this rulemaking – thos e that are needed to replace certificates that have been lost or destroyed. These can be handle d through the mail or via the Web. The costs would be the time to make a written request to AFS-760 ($6.20), 23 

### and mailing charges ($0.44), 24 

### totaling $26.64. There is not be a need to supply a new photo. As shown in Table A-8, 20 year costs sum to $9.66 million ($5.04 million, discounted).

Table A-9 in the Appendix shows the 20 y ear costs to the pi lots, which sum to $445.79 million ($235.80 mill ion, discounted). This is obtained by adding the resultant columns of Tables A-5, A-6, A-7, and A-8.

Foreign Pilots As shown in Appendix B, there are abo ut 162,400 pilots tha t are either foreign based or have foreign addresses. In this analysis, the FAA assumes that these airmen would not make a separate trip to the U.S. or to a KTC or DPE in a foreign country simply to get photo ID. Those pilots who are obtaining a new certificate or rating, i.e., a “trigger” ev ent would be able to submit a photo and get their photo ID as an incidental extr a; that would not be the focus of their trip. Accordingly, this analysis will not take into account the any additional travel costs. All other pilot s would not have a need to fly in the U.S. based on their certificate or license until they act ually come to the U.S. At that point, they would need a photo ID to fly, the y then would go to a KTC, DPE, or FSDO to obtain that ID. Again, getting th e photo ID would no t the purpose of their trip.

23 The FAA is assuming that making a written request or filling out the information over the Web would take 10 minutes. 0.17 hours (10 mi nutes) times $37.20 per hour equals $6.20.

16 24 To be conservative and so as to not under estimate costs, the FAA assumes that all these requests would be mailed.

### Provider’s Costs

FAA’s Costs As shown in Appendix C, it costs the F AA about $54 to process each certificate application, whether the FAA collects the application from a FSDO or the application is forwarded from a KTC or DPE. FAA staff would need to review the paperwork, and the photo, as well as process, scan, and print the plastic

certificate. The FAA estimates would take about 70 minutes to do all that. 25 

### As shown in Table A-10, given a total of 4.40 million “trigger” and “non-trigger” events over 20 years, processing cost s would sum to $239.67 million, ($126.55 million, discounted).

The FAA would need to amend FAA Fo rm 8500-8, the application for a medical certificate, as there are severa l references to "stu dent pilots" on this form. The FAA would have to get rid of all those references since this proposal would be removing the AME’s author ity to issue the combination student pilot/third class medical certificate. Th e cost to reprint and distribute the new form would be about $135,4 00 ($126,600, discounted).

Portals The “trigger” pilots, woul d be interacting with eith er with a KTC or a DPE in the process of obtaining a new pilot certificate or rating, obtaining a new flight instructor certificate, or renewing a flight instructor certificate. Those getting replacement certificates would be maili ng their requests directly to AFS-760

and would not involve a FSDO. As discussed above, the FAA assumes that both the pilots getting their ID under a “non-trigger” scenario and student pilots would go to KTC’s, DPE’s, and FSDO’ s in the proportions of 70%, 25%, and 5%, respectively.

Each portal would have intake costs, to account for the employees who process the pilot. A DPE’s hourly costs are estimated at $75. 26 

### The FAA assumes that the intake person at a KTC would be paid $12.50 per h our, and the intake person at a FSDO would be an Aviation Safety Technician, paid at a FG-9

level. 27 

### Applying the fringe benefit factors 28 

### yields loaded hourly salaries of

25 The bulk of these costs would come from 7 different categories of FAA employees. In addition, there would be some contracting co sts and the production of producing the card.

26 DPE’s are private individuals who may or may not have other full/part-time employment. The FAA is using the fee they would charge to pro cess the photo ID application as the equivalent of an hourly rate. As this analysis assumes that it takes a DPE 20 minutes to fully process a pilot who brings a photo, and that that DPE would char ge $25 for this service, the FAA is using $75 as the per hour rate for a DPE.

17 27 In 2008, the base salary for a FG-9, step 5 was $54,534.

### $15.43 and $34.73, respectively. This an alysis assumes that each intake person would need 20 minutes to process and mail the materials. The costs for the intake person yields a per pilot cost, to the portal, of $25.00, $5.14, and $11.58, respectively.

Certain applications woul d only go through a FSDO – these include pilots analyzed under the “trigger” scenario . The FSDO’s cost per pilot would be $11.58, plus mailing charges. 29 

### Table A-1` in the Appendix shows the 20-year costs at the FSDO’s at $1.75 mill ion ($1.02 million, discounted).

For the pilots analyzed under the “ non-trigger” scenario, including student pilots, using the assumed frequency of pilots goi ng to KTC’s, DPE’s, and FSDO’s yields a weighted average of $10.43 per pilot, 30 

### plus mailing charges. Table A-12 in the Appendix shows the 20 -year costs at these portals summing to $31.39 million ($16.59 mill ion, discounted). The last two columns of Table A-12 show the total 20-year intake cost s at these portals at $33.14 million ($17.61 million, discounted).

Equipment and Software

The FAA anticipates that in the futu re, each portal (FSDO’s and designees) would need to have specific equipme nt and software to comply with these proposals if the FAA decides to require digital capture of photos in the final rule. Appendix D will explain the eq uipment and software that would be

needed in such an event.

Total costs sum to $718.72 million ($380. 09 million, discounted), as shown in

Table 4.

28 All hourly wage rates for government employees are increased by 32.45% and for nongovernment employees by 23.45% to account for all fr inge benefits. This fringe benefits factor was derived from Table 4-5, page 4-22, of the Economic Values for Evaluation of Federal Aviation Administration Investments and Regulatory Programs (Values), DOT; this Draft Final Report, dated December 31, 2004. Since DPE’s are self-employed, the FAA is not factoring in a fringe benefit add-on. Accordingly, this an alysis will multiply the KTC and FSDO’s intake person’s salary by 1.2345 and 1.3245, respectively.

29 As discussed above, this analysis assumes 20 app lication packages would be sent together for a cost of $15.

18 30 Calculation: 0.7 x $5.14 + 0.25 x $25.00 + 0.05 x $11.58 = $10.43.19 Table 4 – Total Costs

Undiscounted
Costs Discounted
Costs

Pilot Costs "Trigger" Events minus St udent Pilots $4,221,982 $2,457,850 "Non-Trigger" Events plus Student Pilots - Initial Appl ications $237,325,281 $151,921,169

- Renewal s $194,585,343 $76,385,012 Replacement Certif icates $9,654,807 $5,036,623 FAA's Costs to produce photo ID's $239,655,257 $126,547,081

AAM Costs $135,436 $126,576

Portal Costs "Trigger" Events minus St udent Pilots $1,752,887 $1,020,452 "Non-Trigger" Events plus St udent Pilots $31, 386,349 $16,590,691

TOTAL $718,717,341 $380,085,455



### IV. Discussion of Benefits

The requirement to include a photo on the pilot certificate is mandated by Congressional statute. In Section 40 22 of IRTPA, Congress required the FAA to promulgate regulations for the issuan ce 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.

As noted in 49 U.S.C § 44703(g)(1) of IR TPA, the proposal would also help to ensure safety in air commerce by ensu ring 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 owne rs to personally appear be fore authorized persons and to include photo identification, w hich 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.

### APPENDIX A – Tables

2021 Table A-1 – Air Transport Pilots

ATP -

Total ATP –

New ATP - "Trigger" - Registered ATP -

"NonTrigger" - Registered ATP - –

Renewed

2010 151,220 7,005 43,402

2011 151,933 713 7,718 43,402

2012 152,544 611 7,616 43,402

2013 153,156 612 612

2014 153,716 560 560

2015 154,226 510 510

2016 154,684 458 458

2017 155,143 459 459

2018 155,601 458 458 50,407

2019 156,060 459 459 51,120

2020 156,518 458 458 51,018

2021 156,977 459 459 612

2022 157,385 408 408 560

2023 157,792 407 407 510

2024 158,200 408 408 458

2025 158,607 407 407 459

2026 159,015 408 408 50,865

2027 159,423 408 408 51,579

2028 159,830 407 407 51,476

2029 160,238 408 408 1,071

TOTAL 9,018 30,033 130,206 310,13522 Table A-2 – Commercial Pilots

Commercial

Pilot - Total Commercial – Change from

Previous Year Commercial

Pilot - "Trigger" - Registered Commercial

Pilot - "NonTrigger" - Registered Commercial

Pilot -

Renewed

2010 168,240 4,515 37,545

2011 169,051 811 5,326 37,545

2012 166,415 -2,636 1,879 37,545

2013 162,224 -4,191 346 37,545

2014 158,574 -3,650 0

2015 160,940 2,366 2,366

2016 163,306 2,366 2,366

2017 165,671 2,365 2,365

2018 168,240 2,569 2,569 42,060

2019 170,808 2,568 2,568 42,871

2020 173,512 2,704 2,704 39,424

2021 176,283 2,771 2,771 37,891

2022 179,055 2,772 2,772 0

2023 181,826 2,771 2,771 2,366

2024 184,665 2,839 2,839 2,366

2025 187,504 2,839 2,839 2,365

2026 190,343 2,839 2,839 44,629

2027 193,182 2,839 2,839 45,439

2028 196,021 2,839 2,839 42,128

2029 198,860 2,839 2,839 40,662

TOTAL 59,157 150,180 342,20123 Table A-3 – Private, Recr eational, and Sport Pilots

Private, Recreational,

and Sport -

Total Private, Recreational, and Sport – Change from

Previous Year Private, Recreational,

and Sport - "Trigger" - Registered Private, Recreational,

and Sport - "Non-Trigger" - Registered Private, Recreational,

and Sport - "Non-Trigger" -

Renewed

2010 349,510 6,921 62,981

2011 341,590 -7,920 0 62,981

2012 333,973 -7,617 0 62,981

2013 331,114 -2,859 4,062 62,981

2014 331,113 -1 6,920 62,981

2015 332,378 1,265 1,265

2016 334,326 1,948 1,948

2017 336,704 2,378 2,378

2018 339,360 2,656 2,656 69,902

2019 342,092 2,732 2,732 62,981

2020 344,950 2,858 2,858 62,981

2021 347,835 2,885 2,885 67,043

2022 350,845 3,010 3,010 69,901

2023 353,906 3,061 3,061 1,265

2024 357,042 3,136 3,136 1,948

2025 360,231 3,189 3,189 2,378

2026 363,418 3,187 3,187 72,558

2027 366,605 3,187 3,187 65,713

2028 369,792 3,187 3,187 65,839

2029 372,980 3,188 3,188 69,928

TOTAL 76,471 314,906 612,43824 Table A-4 – Student Pilots and Replacement Certificates

Student

Pilots – Original

Issuances Student

Pilots -

Additional

Issuance Student

Pilots - "Trigger" Replacement
Certificates (A) (B) (C) (D)

2010 40,797 1,341 42,138 70,149

2011 41,221 1,355 42,576 69,879

2012 41,646 1,369 43,015 69,281

2013 42,070 1,383 43,453 68,894

2014 42,609 1,400 44,009 68,783

2015 43,146 1,418 44,564 69,271

2016 43,713 1,436 45,149 69,813

2017 44,279 1,455 45,734 70,397

2018 44,845 1,474 46,319 71,026

2019 45,411 1,492 46,903 71,667

2020 46,006 1,512 47,518 72,337

2021 46,600 1,531 48,131 73,016

2022 47,195 1,551 48,746 73,703

2023 47,790 1,570 49,360 74,398

2024 48,412 1,591 50,003 75,110

2025 49,035 1,611 50,646 75,827

2026 49,658 1,632 51,290 76,545

2027 50,281 1,652 51,933 77,263

2028 50,904 1,673 52,577 77,981

2029 51,527 1,693 53,220 78,699

TOTAL 947,284 1,454,037Table A-5 – Total Cost of “Trigger” Events

Total "Trigger" - Registered Total "Trigger" - Registered

minus
Student

Pilots Total

Undiscounted
Cost Discount

Rate Discounted
Cost

2010 60,579 18,441 $547,693 0.9346 $511,874

2011 55,620 13,044 $387,407 0.8734 $338,361

2012 52,510 9,495 $282,002 0.8163 $230,198

2013 48,473 5,020 $149,082 0.7629 $113,735

2014 51,489 7,480 $222,151 0.7130 $158,394

2015 48,705 4,141 $122,988 0.6663 $81,947

2016 49,921 4,772 $141,728 0.6227 $88,254

2017 50,936 5,202 $154,499 0.5820 $89,919

2018 52,002 5,683 $168,785 0.5439 $91,802

2019 52,662 5,759 $171,042 0.5083 $86,941

2020 53,538 6,020 $178,794 0.4751 $84,945

2021 54,246 6,115 $181,616 0.4440 $80,637

2022 54,936 6,190 $183,843 0.4150 $76,295

2023 55,599 6,239 $185,298 0.3878 $71,859

2024 56,386 6,383 $189,575 0.3624 $68,702

2025 57,081 6,435 $191,120 0.3387 $64,732

2026 57,724 6,434 $191,090 0.3166 $60,499

2027 58,367 6,434 $191,090 0.2959 $56,543

2028 59,010 6,433 $191,060 0.2765 $52,828

2029 59,655 6,435 $191,120 0.2584 $49,385

1,089,438 142,154 $4,221,982 $2,457,850

2526 Table 6 – “Non Trigger” – Initial Applications

Total "NonTrigger" - Registered Total "NonTrigger" - Registered plus Student

Pilots Undiscounted
Cost Discount

Factor Discounted
Cost

2010 143,928 186,066 $28,626,27 8 0.9346 $26,754,119

2011 143,928 186,504 $28,693,66 4 0.8734 $25,061,046

2012 143,928 186,943 $28,761,20 4 0.8163 $23,477,771

2013 100,526 143,979 $22,151,19 3 0.7629 $16,899,145

2014 62,981 106,990 $16,460,43 5 0.7130 $11,736,290

2015 0 44,564 $6,856,171 0.6663 $4,568,267

2016 0 45,149 $6,946,174 0.6227 $4,325,382

2017 0 45,734 $7,036,176 0.5820 $4,095,054

2018 0 46,319 $7,126,178 0.5439 $3,875,928

2019 0 46,903 $7,216,027 0.5083 $3,667,906

2020 0 47,518 $7,310,644 0.4751 $3,473,287

2021 0 48,131 $7,404,954 0.4440 $3,287,800

2022 0 48,746 $7,499,572 0.4150 $3,112,322

2023 0 49,360 $7,594,036 0.3878 $2,944,967

2024 0 50,003 $7,692,962 0.3624 $2,787,929

2025 0 50,646 $7,791,887 0.3387 $2,639,112

2026 0 51,290 $7,890,967 0.3166 $2,498,280

2027 0 51,933 $7,989,892 0.2959 $2,364,209

2028 0 52,577 $8,088,971 0.2765 $2,236,601

2029 0 53,220 $8,187,897 0.2584 $2,115,753

595,292 1,542,576 $237,325,281 $151,921,169Table 7 – “Non-Trigger” – Renewed Applications and Total CostsTotal -"NonTrigger" -RenewedUndiscountedCostDiscountFactorDiscountedCostTotal CostDiscountFactorDiscountedCost20100$00.9346$0$28,626,2780.9346$26,754,11920110$00.8734$0$28,693,6640.8734$25,061,04620120$00.8163$0$28,761,2040.8163$23,477,77120130$00.7629$0$22,151,1930.7629$16,899,14520140$00.7130$0$16,460,4350.7130$11,736,29020150$00.6663$0$6,856,1710.6663$4,568,26720160$00.6227$0$6,946,1740.6227$4,325,38220170$00.5820$0$7,036,1760.5820$4,095,0542018162,369$24,980,4710.5439$13,586,878$32,106,6490.5439$17,462,8062019156,972$24,150,1660.5083$12,275,529$31,366,1920.5083$15,943,4362020153,423$23,604,1520.4751$11,214,333$30,914,7960.4751$14,687,6202021105,546$16,238,2140.4440$7,209,767$23,643,1680.4440$10,497,567202270,461$10,840,4250.4150$4,498,776$18,339,9970.4150$7,611,09920234,141$637,0930.3878$247,065$8,231,1290.3878$3,192,03220244,772$734,1720.3624$266,064$8,427,1340.3624$3,053,99320255,202$800,3280.3387$271,071$8,592,2150.3387$2,910,1832026168,052$25,854,8000.3166$8,185,630$33,745,7670.3166$10,683,9102027162,731$25,036,1880.2959$7,408,208$33,026,0800.2959$9,772,4172028159,443$24,530,3290.2765$6,782,636$32,619,3000.2765$9,019,2372029111,661$17,179,0060.2584$4,439,055$25,366,9030.2584$6,554,8081,264,773$194,585,343$76,385,012$431,910,624$228,306,18127Table A-8 – Replacement Certificate Costs

Replacement

Certificates Total

Undiscounted
Cost Discount

Rate Discounted
Cost

2010 70,149 $465,790 0.9346 $435,327

2011 69,879 $463,997 0.8734 $405,255

2012 69,281 $460,025 0.8163 $375,519

2013 68,894 $457,453 0.7629 $348,991

2014 68,783 $456,719 0.7130 $325,641

2015 69,271 $459,957 0.6663 $306,470

2016 69,813 $463,558 0.6227 $288,658

2017 70,397 $467,439 0.5820 $272,050

2018 71,026 $471,615 0.5439 $256,511

2019 71,667 $475,867 0.5083 $241,883

2020 72,337 $480,315 0.4751 $228,198

2021 73,016 $484,824 0.4440 $215,262

2022 73,703 $489,386 0.4150 $203,095

2023 74,398 $494,000 0.3878 $191,573

2024 75,110 $498,728 0.3624 $180,739

2025 75,827 $503,494 0.3387 $170,534

2026 76,545 $508,260 0.3166 $160,915

2027 77,263 $513,026 0.2959 $151,805

2028 77,981 $517,792 0.2765 $143,170

2029 78,699 $522,558 0.2584 $135,029

TOTAL 1,454,037 $9, 654,807 $5,036,623

28Table A-9 – Total Pilot Costs“Trigger”“Non-Trigger”– InitialApplications“Non-Trigger”– RenewalsReplacementTotal PilotCostsDiscountedCosts2010$547,693$28,626,278$0$465,790$29,639,761$27,701,3202011$387,407$28,693,664$0$463,997$29,545,068$25,804,6622012$282,002$28,761,204$0$460,025$29,503,231$24,083,4872013$149,082$22,151,193$0$457,453$22,757,728$17,361,8712014$222,151$16,460,435$0$456,719$17,139,306$12,220,3252015$122,988$6,856,171$0$459,957$7,439,116$4,956,6832016$141,728$6,946,174$0$463,558$7,551,460$4,702,2942017$154,499$7,036,176$0$467,439$7,658,114$4,457,0232018$168,785$7,126,178$24,980,471$471,615$32,747,049$17,811,1202019$171,042$7,216,027$24,150,166$475,867$32,013,101$16,272,2592020$178,794$7,310,644$23,604,152$480,315$31,573,905$15,000,7622021$181,616$7,404,954$16,238,214$484,824$24,309,607$10,793,4662022$183,843$7,499,572$10,840,425$489,386$19,013,225$7,890,4892023$185,298$7,594,036$637,093$494,000$8,910,427$3,455,4642024$189,575$7,692,962$734,172$498,728$9,115,437$3,303,4342025$191,120$7,791,887$800,328$503,494$9,286,829$3,145,4492026$191,090$7,890,967$25,854,800$508,260$34,445,117$10,905,3242027$191,090$7,989,892$25,036,188$513,026$33,730,196$9,980,7652028$191,060$8,088,971$24,530,329$517,792$33,328,153$9,215,2342029$191,120$8,187,897$17,179,006$522,558$26,080,581$6,739,222TOTAL$4,221,982$237,325,281$194,585,343$9,654,807$445,787,413$235,800,65429Table A-10 – FAA Processing Costs

Total Pilots

Serviced FAA Cost Discount

Factor Discounted
Cost

2010 274,656 $14,947,695 0.9346 $13,970,116

2011 269,427 $14,663,123 0.8734 $12,806,771

2012 265,719 $14,461,313 0.8163 $11,804,770

2013 217,892 $11,858,422 0.7629 $9,046,790

2014 183,253 $9,973,238 0.7130 $7,110,919

2015 117,976 $6,420,627 0.6663 $4,278,064

2016 119,734 $6,516,321 0.6227 $4,057,713

2017 121,333 $6,603,369 0.5820 $3,843,161

2018 285,397 $15,532,271 0.5439 $8,448,002

2019 281,301 $15,309,323 0.5083 $7,781,729

2020 279,298 $15,200,309 0.4751 $7,221,667

2021 232,807 $12,670,149 0.4440 $5,625,546

2022 199,100 $10,835,662 0.4150 $4,496,800

2023 134,138 $7,300,214 0.3878 $2,831,023

2024 136,268 $7,416,140 0.3624 $2,687,609

2025 138,110 $7,516,429 0.3387 $2,545,815

2026 302,321 $16,453,324 0.3166 $5,209,122

2027 298,361 $16,237,803 0.2959 $4,804,766

2028 296,434 $16,132,917 0.2765 $4,460,752

2029 250,014 $13,606,607 0.2584 $3,515,947

TOTAL 4,403,540 $239, 655,257 $126,547,081

30Table A-11 – FSDO’s Processing Costs"Trigger" Pilotsminus StudentPilotsIntake Costsat FSDOMailingCostsTotal FSDOCostsDiscountFactorDiscountedCosts201018,441$213,545$13,845$227,3900.9346$212,519201113,044$151,050$9,795$160,8450.8734$140,48220129,495$109,952$7,125$117,0770.8163$95,57020135,020$58,127$3,765$61,8920.7629$47,21720147,480$86,617$5,610$92,2270.7130$65,75820154,141$47,953$3,120$51,0730.6663$34,03020164,772$55,260$3,585$58,8450.6227$36,64320175,202$60,239$3,915$64,1540.5820$37,33820185,683$65,809$4,275$70,0840.5439$38,11920195,759$66,689$4,320$71,0090.5083$36,09420206,020$69,712$4,515$74,2270.4751$35,26520216,115$70,812$4,590$75,4020.4440$33,47820226,190$71,680$4,650$76,3300.4150$31,67720236,239$72,248$4,680$76,9280.3878$29,83320246,383$73,915$4,800$78,7150.3624$28,52620256,435$74,517$4,830$79,3470.3387$26,87520266,434$74,506$4,830$79,3360.3166$25,11820276,434$74,506$4,830$79,3360.2959$23,47520286,433$74,494$4,830$79,3240.2765$21,93320296,435$74,517$4,830$79,3470.2584$20,503TOTAL142,154$1,646,147$106,740$1,752,887$1,020,4523132Table A-12 – “Non-Trigger” Portal’s Processing Costs and Total Processing Costs"Non-Trigger"Pilots plusStudent PilotsIntake Costsat PortalsMailingCostsTotal PortalsCostsDiscountFactorDiscountedCostsTotal PortalIntake CostsTotal PortalDiscountedCosts2010186,066$1,940,670$139,560$2,080,2300.9346$1,944,183$2,307,620$2,156,7022011186,504$1,945,238$139,890$2,085,1280.8734$1,821,151$2,245,973$1,961,6332012186,943$1,949,817$140,220$2,090,0370.8163$1,706,097$2,207,114$1,801,6672013143,979$1,501,703$107,985$1,609,6880.7629$1,228,031$1,671,579$1,275,2482014106,990$1,115,907$80,250$1,196,1570.7130$852,860$1,288,384$918,618201544,564$464,803$33,435$498,2380.6663$331,976$549,310$366,005201645,149$470,904$33,870$504,7740.6227$314,323$563,619$350,965201745,734$477,006$34,305$511,3110.5820$297,583$575,465$334,9212018208,688$2,176,616$156,525$2,333,1410.5439$1,268,995$2,403,225$1,307,1142019203,875$2,126,418$152,910$2,279,3280.5083$1,158,582$2,350,337$1,194,6762020200,941$2,095,816$150,720$2,246,5360.4751$1,067,329$2,320,763$1,102,5942021153,677$1,602,849$115,260$1,718,1090.4440$762,840$1,793,510$796,3192022119,207$1,243,329$89,415$1,332,7440.4150$553,089$1,409,074$584,766202353,501$558,015$40,140$598,1550.3878$231,965$675,083$261,797202454,775$571,303$41,085$612,3880.3624$221,930$691,103$250,456202555,848$582,495$41,895$624,3900.3387$211,481$703,737$238,3562026219,342$2,287,737$164,520$2,452,2570.3166$776,385$2,531,593$801,5022027214,664$2,238,947$161,010$2,399,9570.2959$710,147$2,479,293$733,6232028212,020$2,211,370$159,030$2,370,4000.2765$655,416$2,449,724$677,3492029164,881$1,719,706$123,675$1,843,3810.2584$476,330$1,922,729$496,833TOTAL2,807,349$29,280,649$2,105,700$31,386,349$16,590,691$33,139,235$17,611,144

### APPENDIX B – Foreign Pilots

3334 

### Foreign pilots are not inc luded in the FAA annual forecast, but for costing purposes of this proposal, the FAA needs to include them. Table 1in the main text shows that about 127, 000 pilots that are foreign based – approximately 29,200 commercial and 97,900 private. Th ese pilots have re stricted licenses; because they have a foreign li cense, their U.S. license is only valid as long as the foreign license also remains valid. Of these 127,000, 26,800 have domestic addresses – about 6,300 commercial and 20,500 private. On occasion, when foreign pilots are in the U.S., they apply for a domestic license, and often, their license is recorded with a domestic address. Of the remaining 100,200 pilots (calculation: 127,000 minus 26,800), th ey are recorded as having foreign addresses – getting their license from a Knowledge Testing Center (KTC) or DPE located in a foreign country.

There are a total of 135,600 pilots with foreign addresses, the bulk of which are pilots that are foreign based and were dis cussed in the previous paragraph. Table B-1 shows the distribution of pi lots with foreign addresses. Table B-1 – Pilots with Foreign Addresses Airline Transport Pilot 7,649
Commercial Domestic Based 12,689 Commercial Foreign Based 22,849

Private Domestic Based 9,371 Private Foreign Based 77,378 Recreational and Sport 6

Student Pilots 5,610

TOTAL 135,552 

### In addition, there were 2,100 CFI’s w ith foreign addresses. The bulk of the ATP’s in Table B-1 are foreign pilots tha t fly intercontinental routes, thus needing multiple licenses. The domesti cally based Commercial and Private pilots in Table B-1 would encompas s those pilots with unrest ricted licenses, i.e., not being dependent on their having a foreign license.

In total, there are about 162,400 pilots that are eith er foreign based or have foreign addresses. This is derived by ad ding the 127,000 fore ign based pilots in

Table 1in the main text with the all of the pilots in Table B-1 except for the commercial and private foreign based pi lots to avoid doub le counting.

### APPENDIX C – Costs for Photo ID

35Table C-1 – COSTS FOR PHOTO IDOTHER DIRECT COSTS:COSTSCONTRACTSERVICES:SCANNING, INDEXING, STORING RECORDS$0.78QUALITYCONTROL$0.43$1.21Added following information for CertificateCosts for NPRM on Photo certificatesTITLEGRADE/STEPNO.M.HHR. RATEUNIT COSTCOMPLIANCE SPECIALIST / QAGS-11/50.0510$39.19$2.00$2.00COMPLIANCE SPECIALIST / CORRNOTGS-12/50.0780$46.98$3.66$3.66LEGAL INSTRU SUPERVISORGS-13/50.1550$55.86$8.66$8.66LEGAL INSTRU EXAMINERGS-10/50.6650$35.67$23.72$23.72TECHNICAL SUPERVISORGS-14/50.1020$66.02$6.73$6.73SYSTEMS MANAGERGS-14/50.0510$66.02$3.37$3.37PROGRAM ANALYSTGS-13/50.0510$55.86$2.85$2.853637CERTIFICATE PRINTING FOR PHOTO CERTS ONLYNumber of Certificates Produced117,920Production Costsall with photo$1.802$212,491.84Holograms$0.050$5,896.00Card Stock$0.285$33,607.20Card Carriers$0.038$4,480.96Envelopes$0.029$3,419.68Postal Reports$1,250.00FedEx Charges$601.68Cost per year for certificates$261,747.36Cost per certificate$2.22$2.22TOTAL$54.42

### APPENDIX D - Anticipated Equipment and Software

38

### The FAA anticipates that in the futu re, each portal (FSDO’s and designees) would need to have specific equipme nt and software to comply with these proposals if the FAA decides to require digital capture of photos in the final

rule.

Equipment 1) A computer with high speed connection – All FSDO and KTC portals already have this, and almost all DPE portals have this in order to access

IACRA. There should be little or no acquisition costs here. 2) A digital camera with a stand & light colored back drop (the estimated acquisition cost for each portal would be $500) – The FAA anticipates that, at some point in the future, some airmen w ould ask the portals to take their photo. The portals would need to acquire this eq uipment. The FSDO’s already have the photo equipment on hand to take photos for inspector credentials. 3) A scanner, which is a high quality do cument feed (the estimated acquisition cost for each portal would be $500) – In the future, the FAA anticipates that it may be more desirable to have the porta ls scan in the airman-submitted paper photo and application, and submit that package electronically to AFS-760 as opposed to mailing the hard copies.

Software Systems 1) Camera and scanner software– Camera and scanners normally come with the necessary software. 2) IACRA – IACRA is considered the elec tronic delivery system of choice. It is an electronic 8710-1 system that wo uld eventually be cap able of accepting a digital photo taken by the airman or ta ken by the verifying portal. Once the IACRA record/file has been digitally signed, it would be transmitted to AFS760. 3) A system for the electronic delivery of a scanned paper 87 10-1 and photo to AFS-760 (estimated acquisition cost for each portal would be $100). 31 

### The FAA anticipates each portal needing a separate software delivery system for the scanned paper 8710-1 and pa per photo in the event that the portals scan those documents versus mailing them to AFS-760.

As shown in Table A-13, given 800 KTC’ s, 1,000 DPE’s, and 83 FSDO’s, total anticipated costs sum to $2.03 million ($ 1.90 million, discounted). However,

these costs will not be included in the co sts of this proposal since the FAA is not requiring the digital capture of photos and 8710-1 applications.

31 Adobe Photoshop used as proxy.

3940 Table A-13 – Equipment and Software Costs

FSDO KTC DPE

Number 83 800 1,000 Cost for Portal per Item

Camera $0 $500 $500

Scanner $500 $500 $500

Electronic delivery system for a scanned paper 8710-1 and photo to
AFS-760 $100 $100 $100 Total Cost per Portal $4,600 $5,100 $5,100

Total for all Portals $49,800 $880,000 $1,100,000