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February 21, 2002
AOPA today petitioned the FAA to change the rules to allow for a simple, inexpensive pilot photo ID that could be put into place almost immediately. AOPA said that the FAA should simply require that pilots carry a valid, government-issued photo ID along with their pilot certificates when in command of an aircraft. That photo ID could be a driver's license, passport, state ID card, or government agency photo ID card.
"Since September 11, the need for a picture identification for pilots has been an important element in many security discussions," said AOPA President Phil Boyer. "With a simple stroke of the pen, and with minimal cost to taxpayers, the FAA could satisfy that security concern."
In a letter to FAA Administrator Garvey, Boyer said that with AOPA's proposal, the FAA could address the growing public cry for picture identification of pilots with "no lengthy implementation process, no enormous FAA investment, and no financial or time costs to pilots."
AOPA asked the FAA to implement the change by "direct final rule," which bypasses the normal rulemaking process and would permit the photo ID requirement to go into effect within 30 days.
"This may be too simple for the government, but it sure makes good sense," Boyer said. "And make no mistake. Sooner rather than later, the government is going to require photo IDs for pilots. We're giving them a solution pilots can live with."
In December, AOPA and other industry groups recommended pilot photo IDs to the FAA and Transportation Security Administration. There hasn't been any progress. In fact, the FAA has been under a mandate to develop photo pilot IDs since 1988.
"But the government infrastructure to issue photo IDs already exists in all 50 states, the District of Columbia, and other branches of the federal government," said Boyer. "We can do this now, not five years from now."
Boyer reiterated that if the responsible pilots of America acting collectively as AOPA members didn't take proactive measures now, the government would.
"Already South Dakota has passed legislation that requires state-issued pilot identification, and they're going to charge pilots for it. And don't forget Senator Kohl's comment about GA being a 'ticking time bomb.' He's frustrated that the government hasn't acted. This is action that just makes good sense and can be supported by all pilots."
In fact, the FAA already requires driver's licenses for security identification. Airline passengers must present a driver's license or similar photo ID to pass through airport security. The FAA requires prospective pilots to show a driver's license before taking an FAA written exam or flight test.
General aviation pilots would likely support AOPA's driver's license proposal, according to informal surveys of AOPA members across the nation.
"After all, you need a license to drive to the airport," Boyer said.
AOPA noted that the states have agreed to upgrade driver's license security features and have asked Congress for additional funds to create high-tech licenses.
Other appropriate photo IDs could include state photo identification cards (which all states will issue in lieu of a driver's license), U.S. government-issued passports, U.S. military IDs, and federal and state government identification cards.
"The FAA is still considering its own photo ID system," said Boyer. "But it could take up to five years for the FAA to implement such a system, and it would cost millions of dollars to get it started. It would cost the FAA an additional $2 million a year just to run the system."
There are currently some 630,000 active pilots (with current medical certificates) in the United States, plus an additional 530,000 people holding non-pilot airman certificates (mechanics, flight engineers, ground instructors, etc.) Since 1950, the FAA has issued more than three million pilot certificates alone. That means the FAA could be facing a demand to issue millions of photo IDs if it were to try to do it itself.
Boyer also expressed concern that an FAA-run system could be inconvenient and costly for pilots. For example, the Transportation Security Administration recently estimated that it would cost $50 to $75 per person to issue photo IDs to railroad workers. And FAA photo ID locations might not be convenient for all pilots.
"You already have to stand in line and deal with the motor vehicle administration in your state to get a driver's license," Boyer said. "Would you want to have to do that again at an FAA facility?"
AOPA's petition for rulemaking asks that the FAA amend Sections 61.3 (a) and 61.3 (1) of Title 14 of the Code of Federal Regulations (commonly called the federal aviation regulations) to read that a person may not act as a pilot of a civil aircraft of U.S. registry unless that person has a "form of photographic identification acceptable to the [FAA] Administrator," and that each person required to have this ID "must present it for inspection upon request from the Administrator or any federal, state, or local law enforcement officer."
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