DRAFT REGULATORY EVALUATION, 

INITIAL REGULATORY FLEXIBILITY DETERMINATION, TRADE 

IMPACT ASSESSMENT, AND UNFUNDED MANDATES 

DETERMINATION 

NOTICE OF PROPOSED 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 photos on all pilot certificates. The FAA 

proposes a 5-year phased implementation schedule. This schedule includes a 

“Trigger-based” approach to issue pilot certificates with photos to people 

interacting with the FAA during the implementation period. The schedule also 

includes a “Non-Trigger-based” approach that requires a pilot certificate with 

photo to exercise pilot privileges after a 3-, 4-, or 5-year period dependent on 

the type of certificate. 

This proposal would modify the application 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 certificates with photos. Consistent with 

the Real ID Act, the FAA proposes an 8-year duration. 

There are currently about 740,000 pilots and 93,000 CFI’s that would be 

covered by this proposal. Given future projected growth in all pilot categories 

and given the requirement to renew every 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 District Office. These portals would incur 

costs of $33.2 million to process this 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 Intelligence Reform and Terrorism Prevention 

Act (IRTPA) by requiring digital photos on all pilot certificates. Congress, 

which represents the will of the American people, has mandated that the FAA 

improve pilot licenses by including a photo on the license. The proposal 

requiring owners to personally appear before authorized persons and to produce 

proof of identity including photo identification would be a significant help in 

the prevention of fraudulent and fictitious registration. 

The proposed rule is not expected to have a significant impact on international 

trade, a significant impact on a substantial number of small firms, or an 

unfunded mandate. 

2
I. Introduction and Background 

This proposal would require digital photos on all pilot certificates. This 

proposal responds to the 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 plastic certificate (exempting temporary 

certificates or student pilot certificates) that meets all of the relevant 

requirements of IRTPA, except for including photos of pilots on their pilot 

certificates. This proposal includes the requirements that the certificate be 

resistant to tampering, alteration, and counterfeiting; includes a photograph of 

the individual to whom the license is issued; and is capable of accommodating 

a digital photograph, a biometric identifier, or any other unique identifier that 

the Administrator considers necessary. In the DEA final rule, the FAA also 

exempted holders of temporary pilot certificates and student pilot certificates 

from the requirement for plastic certificates. 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 paper certificates started issuing plastic 

certificates only. The current rules state that as of March 31, 2010, all pilots, 

except student pilots, must have plastic certificates. The plastic 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, alteration, and counterfeiting. 

II. Proposal 

The FAA proposes to fulfill the requirements of the IRTPA by requiring a 

photo of the pilot on all plastic 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 upgrading 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 accompanies the underlying plastic certificate. 

The FAA proposes a 5-year phased implementation schedule. This schedule 

includes a “Trigger-based” approach to issue pilot certificates with photos to 

people interacting with the FAA during the implementation period. The 

1
schedule also includes a “Non-Trigger-based” approach that requires a pilot 

certificate with photo for a person to exercise pilot privileges after a 3-, 4-, or 

5-year period depending on the type of certificate, as discussed below. This 

proposal would not revoke or otherwise cancel a previously-issued plastic 

certificate. 

This proposal would modify the application 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 airman certificate. 

Although the FAA has statutory authority to charge a fee for issuing a pilot 

certificate, the FAA previously has not exercised 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 portals) to accept and 

verify applications to minimize the inconvenience 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 with the FAA during one of the following 

“triggering” events. Specifically, the FAA is proposing to require all persons to 

provide a photo when the following “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 additional 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. 

2
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 and 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 pilot (ATP) certificate must obtain a pilot 

certificate with photo within 3 years after the final rule becomes effective; 

those holding a commercial pilot certificates must obtain a pilot certificate with 

photo within 4 years; and those holding private, recreational, and sport pilot 

certificates must obtain a pilot certificate with photo within 5 years. 

The FAA assumes that applications for the pilot certificate with photo would be 

evenly spread throughout the implementation period. If all pilots wait until 

close to the end of the period to apply for the certificate, there undoubtedly 

would be delays in processing and receipt of the new certificate. The phased 

implementation period balances the FAA’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 pilot’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 expiration 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 this proposal to meet the IRTPA 

requirements. The DEA final rule, which required plastic pilot certificates, did 

not include student pilots. The FAA proposes 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 discontinue use of an Aviation Medical Examiner (AME) 

for the application and issuance of a student pilot certificate. Currently, except 

in the case of glider, balloon, and light sport aircraft, a student pilot’s first 

3
contact with the FAA usually is through an AME because of the medical 

certificate requirement. The AME may issue both a medical certificate and a 

student pilot certificate (often referred to as a combination certificate). Under 

this proposal, a student pilot would obtain a student pilot certificate with photo 

that is issued by AFS-760 prior to conducting solo flights. A person wishing to 

obtain a student pilot certificate would still obtain a medical 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 airmen certification representatives, local 

Flight Standards District Offices (FSDOs), and International Field Offices also 

would be authorized to accept 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 digital photo; the FAA would revise its guidance 

material as technology advances and additional methods are available for photo 

submission. 

III. Cost of Compliance 

In this analysis, the FAA estimated future 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 was 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 time1

 

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 opportunity cost equal to the amount of foregone 

activity. Economic theory postulates that individuals will adjust the amount of time they devote 

to work and leisure such that the value of an additional small increment of either will be valued at 

the wage rate. 
$54.42 – Total cost to the FAA of producing a Certificate 

$22.00 – Proposed fee for issuing a new or replacement pilot certificate with 

photo2

$8.00 – Cost of two hard copy photos 

$0.585 – Cost per mile for an automobile3

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 certificates. 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 payments to the FAA are considered transfer payments; OMB 

Circular A-4 defines transfer payments as “monetary payments from one group to another that do not affect 

total resources available to society.” This $22 fee is a transfer payment from the pilots to the Agency and 

as such does not increase or decrease the cost to society of this rulemaking. Another way of looking at this 

is to realize that if the analysis adds in the $22 fee from the aircraft owners and then subtracts the same $22 

to partially offset the FAA’s processing costs, the result would be that this application fee would, in effect, 

be zeroed out in the calculations and so would not be reflected in the cost of the rule to society. 

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 was raised from $0.505 to $0.585 per mile. 

5

4

 Source: AFS-760, Airmen Certification Branch 
Total Private, Recreational 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 original pilot certificates issued in 2008 

(which includes approximately 4,400 original 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 earn one or more additional ratings, and 

these additional ratings qualify as “trigger” events. In FY 2008, there were 

approximately 38,300 additional 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 “English Proficient” endorsement, or if the 

pilots is complying with the paper to plastic rule. Requests for these 

replacements can be made via written request or on the AFS website. The FAA 

processed about 205,400 replacements in 2008. However, this number was 

inflated that year because of the latter two reasons – the “English Proficient” 

endorsement and the paper to plastic rule. 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 report 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 correlates with an expiration date on the medical 

certificate. 

6

To project the 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 applied 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 Table 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-based” 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 flight instructor certificate. The pilot is 

already there, so for the costs, as will be described below, there would be no 

additional time, transportation, or processing costs. When these pilots renew in 

8 years, however, this renewal would not be considered a “trigger-based” event 

as the pilot would not be interacting 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 declined in 2008, while the number of 

additional ratings has stayed roughly the same since 2003. The decline in the 

number of original ratings in 2008 may 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 data 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 additional 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 would 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 years later. In 2011, there would be an 

additional 700 pilots; these new pilots would be interacting with the FAA in the 

 

7

6

 Source: Table 17 and 18 from 

http://www.faa.gov/data_research/aviation_data_statistics/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 additional 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 would 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 assumes that this would happen uniformly, 

so that 1/3 of these pilots would get their licenses each year. Given the 

projected “non-triggered” 130,200 pilots in 2010 (calculation: 151,200 x 

86.1%), about 43,400 licenses 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 registering 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 “trigger” events, so total “trigger” events 

sum to 18,100 certificates, or 10.7% of total commercial certificates. The 

number of “non-trigger” events would 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 commercial 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 processed (calculation – 168,200 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-trigger” events. In 

2011, there are an additional 800 pilots, and as above, since these pilots would 

be interacting with the FAA, these would 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 would 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 would have a 5-year licensing process. 

In 2008, there were approximately 337,900 private certificates. There were 

about 2,900 recreational and sports certificates in that year as well, for a total of 

340,800. Of these, there were about 20,500 original certificates and 

approximately 13,300 additional 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 total 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 2010 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” events . In 2015, the FAA projects an 

additional 1,300 pilots, and as above, since these pilots would be interacting 

with the FAA, these would be “trigger” events. As can be seen in Table A-3 in 

9
the Appendix, over 20 years, there would be 5976,800 pilots registering to get 

their new photo ID.8

Private, recreational, and sport pilots getting 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 (calculation: 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 registering to get their 

new photo ID and 612,400 renewing their ID. 

Number of Student Pilot Certificates

All student certificates would be “trigger” 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 certification 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 following percentages, 70%, 25%, and 5%, 

respectively.10 Under current FAA rules, a student 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 for a student pilot certificate and in this 

analysis, the FAA assumes that no student renews their photo ID – in the 8 

years before they would have to renew their photo ID, they would acquire 

another certification. 

In 2008, there were 81,300 student certificates and 1,500 additional certificates, 

where student pilots got an additional 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-810 
Table 2 – Student pilot certificates – 2008 

Designated Examiner 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 year (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, there were approximately 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 process 42,100 student certificates. In 

future years, the FAA would process both new original student certificates and 

additional certificates. This 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, there is no separate requirement to have 

a separate CFI certificate. Hence, there would be no additional costs to those 

pilots who obtain original 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 certificate 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” endorsement, 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 certificate to reflect the new address. It 

is not a requirement of the rule to have a new certificate issued in case of an 

address change; thus, any change is voluntary 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 should not counted in the costs of this 

rulemaking. About two thirds of the replacement 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 photo 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 million 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 million photo ID’s from 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 provide the FAA a photo using one of the 

portals (KTC, FSDO, DPE, etc.) by providing 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 assumes that the pilot would provide hard 

copy photos, which many pharmacies sell for $8. 

The material could be forwarded 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. Mailed individually, the FAA estimates 

that it would cost $3 each (delivery confirmation, 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 Application (IACRA).15 

The portals would also verify the airman's identity and digitally 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 accepting 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 above, the portals would verify the 

airman's identity and digitally sign the 8710-1, and the IACRA package 

would be uploaded to AFS-760. 

2) One of the portals could take a digital photo of the airman. If the airman 

has the portal capture the digital picture, 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-based” event is one in which pilots are 

already interacting with the FAA during the implementation period. Adding 

 

13

15 It is anticipated that IACRA will be the only public access portal for digital photos. In turn, the 

IACRA sub-system will feed the digital photos into the Airmen Registry Branch (AFS-760) main 

system. 
the photo is simply one additional step in the process. A pilot personally 

interacts with the Agency when they obtain 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 would 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 million 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 randomly distributed. Thus, the percentage 

of pilots living in urban areas to the entire 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 tasks and drive the necessary 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 time 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 additional 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 explained further in the ‘non-trigger” section, the FAA 

is using 35 minutes as the average time to fill out 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.html 
Table 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 mileage 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 his or her own photo, at $8. 

The FAA bases costs on 70% of these pilots 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 knowledge 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 would 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 additional 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 course 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 for initial registration equals $237.336 

million ($151.92 million, discounted) and for renewal equals $194.59 million 

($76.39 million, discounted), respectively, for a total of $431.91 million 

($228.31 million, discounted). 

Cost of a Replacement Event

As discussed above, about 70,000 replacement certificates would be covered by 

this rulemaking – those that are needed to replace certificates that have been 

lost or destroyed. These can be handled 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 year costs to the pilots, which sum to 

$445.79 million ($235.80 million, 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 about 162,400 pilots that 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” event would be able to submit a photo and 

get their photo ID as an incidental extra; that would not be the focus of their 

trip. Accordingly, this analysis will not take into account the any additional 

travel costs. All other pilots would not have a need to fly in the U.S. based on 

their certificate or license until they actually come to the U.S. At that point, 

they would need a photo ID to fly, they then would go to a KTC, DPE, or 

FSDO to obtain that ID. Again, getting the photo ID would not 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 minutes) times $37.20 per hour equals $6.20. 

16

24 To be conservative and so as to not underestimate 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 FAA 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 costs would sum to $239.67 million, ($126.55 

million, discounted). 

The FAA would need to amend FAA Form 8500-8, the application for a 

medical certificate, as there are several references to "student pilots" on this 

form. The FAA would have to get rid of all those references since this proposal 

would be removing the AME’s authority to issue the combination student 

pilot/third class medical certificate. The cost to reprint and distribute the new 

form would be about $135,400 ($126,600, discounted). 

Portals

The “trigger” pilots, would be interacting with either 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 mailing 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 hour, and the intake 

person at a FSDO would be an Aviation Safety Technician, paid at a FG-9 

level.27 Applying the fringe benefit factors28 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 costs 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 process 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 charge $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 analysis 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 would 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 million ($1.02 million, discounted). 

For the pilots analyzed under the “non-trigger” scenario, including student 

pilots, using the assumed frequency of pilots going 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 million, discounted). The last two columns of Table 

A-12 show the total 20-year intake costs at these portals at $33.14 million 

($17.61 million, discounted). 

Equipment and Software

The FAA anticipates that in the future, each portal (FSDO’s and designees) 

would need to have specific equipment 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 equipment 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 fringe 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 analysis 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 application 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 Student Pilots $4,221,982 $2,457,850

 "Non-Trigger" Events plus Student Pilots 

 - Initial Applications $237,325,281 $151,921,169

 - Renewals $194,585,343 $76,385,012

 Replacement Certificates $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 Student Pilots $1,752,887 $1,020,452

 "Non-Trigger" Events plus Student 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 4022 of IRTPA, Congress required the FAA 

to promulgate regulations for the issuance of improved pilot licenses. This 

rulemaking is within the scope of that authority because it prescribes the 

inclusion of a photo of the pilot on the pilot certificate in accordance with the 

IRTPA mandate. 

As noted in 49 U.S.C § 44703(g)(1) of IRTPA, the proposal would also help to 

ensure safety in air commerce by ensuring verifiable identification of 

individuals applying for airman certificates. This would also make the system 

more efficient in serving the needs of those enforcing laws related to combating 

acts of terrorism. 

The proposal requires owners to personally appear before authorized persons 

and to include photo identification, which would help in the prevention of 

fraudulent and fictitious registration. The new registration requirements would 

allow the FAA to build and maintain an up-to-date database of pilots. 

 
APPENDIX A – Tables 

20
21

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 30,033 130,206 310,135 
22

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

342,201
23

Table A-3 – Private, Recreational, 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 76,471 314,906 612,438
24

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 1,454,037 
Table 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

25
26

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 $28,626,278 0.9346 $26,754,119

2011 143,928 186,504 $28,693,664 0.8734 $25,061,046

2012 143,928 186,943 $28,761,204 0.8163 $23,477,771

2013 100,526 143,979 $22,151,193 0.7629 $16,899,145

2014 62,981 106,990 $16,460,435 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 $151,921,169
Table 7 – “Non-Trigger” – Renewed Applications and Total Costs 

Total - 

"NonTrigger" -

Renewed 

Undiscounted 

Cost 

Discount 

Factor 

Discounted 

Cost Total Cost 

Discount 

Factor 

Disco

Co

2010 0 $0 0.9346 $0 $28,626,278 0.9346 $26,72011 0 $0 0.8734 $0 $28,693,664 0.8734 $25,02012 0 $0 0.8163 $0 $28,761,204 0.8163 $23,42013 0 $0 0.7629 $0 $22,151,193 0.7629 $16,82014 0 $0 0.7130 $0 $16,460,435 0.7130 $11,72015 0 $0 0.6663 $0 $6,856,171 0.6663 $4,52016 0 $0 0.6227 $0 $6,946,174 0.6227 $4,32017 0 $0 0.5820 $0 $7,036,176 0.5820 $4,02018 162,369 $24,980,471 0.5439 $13,586,878 $32,106,649

0.5439 $17,4

2019 156,972 $24,150,166 0.5083 $12,275,529 $31,366,192

0.5083 $15,9

2020 153,423 $23,604,152 0.4751 $11,214,333 $30,914,796

0.4751 $14,6

2021 105,546 $16,238,214 0.4440 $7,209,767 $23,643,168 0.4440 $10,42022 70,461 $10,840,425 0.4150 $4,498,776 $18,339,997 0.4150 $7,62023 4,141 $637,093 0.3878 $247,065 $8,231,129 0.3878 $3,12024 4,772 $734,172 0.3624 $266,064 $8,427,134 0.3624 $3,02025 5,202 $800,328 0.3387 $271,071 $8,592,215 0.3387 $2,92026 168,052 $25,854,800 0.3166 $8,185,630 $33,745,767 0.3166 $10,62027 162,731 $25,036,188 0.2959 $7,408,208 $33,026,080 0.2959 $9,72028 159,443 $24,530,329 0.2765 $6,782,636 $32,619,300 0.2765 $9,02029 111,661 $17,179,006 0.2584 $4,439,055 $25,366,903 0.2584 $6,5

1,264,773 $194,585,343 $76,385,012 $431,910,624 $228,3

27
Table 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 

28
Table A-9 – Total Pilot Costs 

“Trigger” “Non-Trigger” 

– Initial 

Applications 

“Non-Trigger” 

– Renewals 

Replacement 

Total Pilot 

Costs 

Disco

Co

2010 $547,693 $28,626,278 $0 $465,790 $29,639,761 $272011 $387,407 $28,693,664 $0 $463,997 $29,545,068 $252012 $282,002 $28,761,204 $0 $460,025 $29,503,231 $242013 $149,082 $22,151,193 $0 $457,453 $22,757,728 $172014 $222,151 $16,460,435 $0 $456,719 $17,139,306 $122015 $122,988 $6,856,171 $0 $459,957 $7,439,116 $42016 $141,728 $6,946,174 $0 $463,558 $7,551,460 $42017 $154,499 $7,036,176 $0 $467,439 $7,658,114 $42018 $168,785 $7,126,178 $24,980,471 $471,615 $32,747,049 $172019 $171,042 $7,216,027 $24,150,166 $475,867 $32,013,101 $162020 $178,794 $7,310,644 $23,604,152 $480,315 $31,573,905 $152021 $181,616 $7,404,954 $16,238,214 $484,824 $24,309,607 $102022 $183,843 $7,499,572 $10,840,425 $489,386 $19,013,225 $72023 $185,298 $7,594,036 $637,093 $494,000 $8,910,427 $32024 $189,575 $7,692,962 $734,172 $498,728 $9,115,437 $32025 $191,120 $7,791,887 $800,328 $503,494 $9,286,829 $32026 $191,090 $7,890,967 $25,854,800 $508,260 $34,445,117 $102027 $191,090 $7,989,892 $25,036,188 $513,026 $33,730,196 $92028 $191,060 $8,088,971 $24,530,329 $517,792 $33,328,153 $92029 $191,120 $8,187,897 $17,179,006 $522,558 $26,080,581 $6

TOTAL $4,221,982 $237,325,281 $194,585,343 $9,654,807 $445,787,413 $235

29
Table 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 

30
Table A-11 – FSDO’s Processing Costs 

"Trigger" Pilots 

minus Student 

Pilots 

Intake Costs 

at FSDO 

Mailing 

Costs 

Total FSDO 

Costs 

Discount 

Factor 

Discounted 

Costs 

2010 18,441 $213,545 $13,845 $227,390 0.9346 $212,5192011 13,044 $151,050 $9,795 $160,845 0.8734 $140,4822012 9,495 $109,952 $7,125 $117,077 0.8163 $95,5702013 5,020 $58,127 $3,765 $61,892 0.7629 $47,2172014 7,480 $86,617 $5,610 $92,227 0.7130 $65,7582015 4,141 $47,953 $3,120 $51,073 0.6663 $34,0302016 4,772 $55,260 $3,585 $58,845 0.6227 $36,6432017 5,202 $60,239 $3,915 $64,154 0.5820 $37,3382018 5,683 $65,809 $4,275 $70,084 0.5439 $38,1192019 5,759 $66,689 $4,320 $71,009 0.5083 $36,0942020 6,020 $69,712 $4,515 $74,227 0.4751 $35,2652021 6,115 $70,812 $4,590 $75,402 0.4440 $33,4782022 6,190 $71,680 $4,650 $76,330 0.4150 $31,6772023 6,239 $72,248 $4,680 $76,928 0.3878 $29,8332024 6,383 $73,915 $4,800 $78,715 0.3624 $28,5262025 6,435 $74,517 $4,830 $79,347 0.3387 $26,8752026 6,434 $74,506 $4,830 $79,336 0.3166 $25,1182027 6,434 $74,506 $4,830 $79,336 0.2959 $23,4752028 6,433 $74,494 $4,830 $79,324 0.2765 $21,9332029 6,435 $74,517 $4,830 $79,347 0.2584 $20,503

TOTAL 142,154 $1,646,147 $106,740 $1,752,887 $1,020,452

31
32

Table A-12 – “Non-Trigger” Portal’s Processing Costs and Total Processing Co

"Non-Trigger" 

Pilots plus 

Student Pilots 

Intake Costs 

at Portals 

Mailing 

Costs 

Total Portals 

Costs 

Discount 

Factor 

Discounted 

Costs 

T

Int

2010 186,066 $1,940,670 $139,560 $2,080,230 0.9346 $1,944,183 2011 186,504 $1,945,238 $139,890 $2,085,128 0.8734 $1,821,151 2012 186,943 $1,949,817 $140,220 $2,090,037 0.8163 $1,706,097 2013 143,979 $1,501,703 $107,985 $1,609,688 0.7629 $1,228,031 2014 106,990 $1,115,907 $80,250 $1,196,157 0.7130 $852,860 2015 44,564 $464,803 $33,435 $498,238 0.6663 $331,976 2016 45,149 $470,904 $33,870 $504,774 0.6227 $314,323 2017 45,734 $477,006 $34,305 $511,311 0.5820 $297,583 2018 208,688 $2,176,616 $156,525 $2,333,141 0.5439 $1,268,995 2019 203,875 $2,126,418 $152,910 $2,279,328 0.5083 $1,158,582 2020 200,941 $2,095,816 $150,720 $2,246,536 0.4751 $1,067,329 2021 153,677 $1,602,849 $115,260 $1,718,109 0.4440 $762,840 2022 119,207 $1,243,329 $89,415 $1,332,744 0.4150 $553,089 2023 53,501 $558,015 $40,140 $598,155 0.3878 $231,965 2024 54,775 $571,303 $41,085 $612,388 0.3624 $221,930 2025 55,848 $582,495 $41,895 $624,390 0.3387 $211,481 2026 219,342 $2,287,737 $164,520 $2,452,257 0.3166 $776,385 2027 214,664 $2,238,947 $161,010 $2,399,957 0.2959 $710,147 2028 212,020 $2,211,370 $159,030 $2,370,400 0.2765 $655,416 2029 164,881 $1,719,706 $123,675 $1,843,381 0.2584 $476,330 

TOTAL 2,807,349 $29,280,649 $2,105,700 $31,386,349 $16,590,691 $
APPENDIX B – Foreign Pilots 

33
34

Foreign pilots are not included 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. These pilots have restricted licenses; 

because they have a foreign license, 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), they 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 discussed in the previous paragraph. Table 

B-1 shows the distribution of pilots 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 with foreign addresses. The bulk of the 

ATP’s in Table B-1 are foreign pilots that fly intercontinental routes, thus 

needing multiple licenses. The domestically based Commercial and Private pilots 

in Table B-1 would encompass those pilots with unrestricted licenses, i.e., not 

being dependent on their having a foreign license. 

In total, there are about 162,400 pilots that are either foreign based or have 

foreign addresses. This is derived by adding the 127,000 foreign 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 pilots to avoid double counting. 
APPENDIX C – Costs for Photo ID 

35
Table C-1 – COSTS FOR PHOTO ID 

OTHER DIRECT COSTS: 

CONTRACT SERVICES: 

SCANNING, INDEXING, STORING RECORDS 

QUALITY CONTROL 

Added following information for Certificate Costs for NPRM on Photo certificates TITLE GRADE/STEP NO.M.H HR. COMPLIANCE SPECIALIST / QA GS-11/5 0.0510 $COMPLIANCE SPECIALIST / CORR NOT GS-12/5 0.0780 $LEGAL INSTRU SUPERVISOR GS-13/5 0.1550 $LEGAL INSTRU EXAMINER GS-10/5 0.6650 $TECHNICAL SUPERVISOR GS-14/5 0.1020 $SYSTEMS MANAGER GS-14/5 0.0510 $PROGRAM ANALYST GS-13/5 0.0510 $

36
37

CERTIFICATE PRINTING FOR PHOTO CERTS ONLY Number of Certificates Produced Production Costs all with photo $Holograms $Card Stock $Card Carriers $Envelopes $Postal Reports FedEx Charges Cost per year for certificates Cost per certificate 
APPENDIX D - Anticipated Equipment and Software 

38
The FAA anticipates that in the future, each portal (FSDO’s and designees) 

would need to have specific equipment 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 would ask the portals to take their photo. 

The portals would need to acquire this equipment. The FSDO’s already have 

the photo equipment on hand to take photos for inspector credentials. 

3) A scanner, which is a high quality document 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 portals 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 electronic delivery system of choice. It 

is an electronic 8710-1 system that would eventually be capable of accepting a 

digital photo taken by the airman or taken 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 8710-1 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 paper 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 costs of this proposal since the FAA is 

not requiring the digital capture of photos and 8710-1 applications. 

 

31 Adobe Photoshop used as proxy. 

39
40

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