AOPA petition for rulemaking to amend Sections 61.3(a) and 61.3(l) of the FARs

February 21, 2002

The Honorable Jane Garvey
Administrator
Federal Aviation Administration
800 Independence Ave SW
AOA-1 Room 1010
Washington, DC 20591

Dear Administrator Garvey,

As we discussed by phone, the enclosed Petition for Rulemaking is being sent to you on behalf of the 380,000 members of the Aircraft Owners and Pilots Association (AOPA), representing almost 60 percent of all licensed pilots. With a simple rule change, the FAA can address the growing government and industry consensus for the need to add a picture identification for pilots. No lengthy implementation process, no enormous investment for the agency to handle this task, and no financial or time impact on the pilots required to obtain such through whatever mechanism the agency were to establish. The petition requests the Federal Aviation Administration (FAA) issue a direct final rule requiring pilots to carry valid photo identification.

We believe the photo identification in most instances would be a current state-issued driver's license, although it could also be a government ID card, passport, and other form of identification acceptable to the FAA for security purposes. Based on our research, each state has a photo on the driver's license and offers a non-driver's license photo identification. As you know, the FAA already requires all applicants for pilot certificates to produce positive identification at the time of application for a certificate to a designated examiner or FAA inspector. Our petition takes this a step further by having pilots carry picture identification, in addition to their pilot and medical certificates, with them when flying.

Clearly, AOPA has been proactive in working with the agency in the aftermath of the events of September 11th. This petition covers an important area and shows Congress and the American public the government can take immediate, positive steps that make sense to enhance aviation security.

As always, the AOPA staff and I will be available to you or any of your people to answer any questions about this proposal and, upon enactment of the rulemaking, establish rapid communication to all pilots of the compliance date. As FAA administrator, no one knows more than you how these difficult times have required often complex solutions—hopefully, you will view this as one of those solutions that is so simple; let's get on with it.

Sincerely,

Phil Boyer

February 21, 2002