The comment period closes on 17 Feb. That is tomorrow. You can go to www.regulations.govand search for docket# FAA-2010-1127. It wilol show some 300+ comments. Click on rule to submit directly. Here is my comment:
There is no need to redo the pilot certificate to include a photograph. FAR § 61.3 already requires a pilot to carry an acceptable picture ID when exercising his pilot privileges.
Isn’t there a government directive that says that we should not add to the government’s paperwork and expenses without serious justification? Beyond satisfying a member of Congress, what justification is there for this rule?
When I worked as a FAA aviation safety inspector, I checked pilot certificates when I inspected airline operations. While I didn’t check a photo-ID, the point is that the pilot’s certificate was only looked at when doing an inspection. I venture to guess that more than 95% of all airline operations are flown without the pilot ever being asked to show his pilot certificate. Probably more than 99% of all aircraft are being flown without anyone having to show a photo ID. Airline crews have company and airport ID’s with photos. TSA has forced most FAR Part 139 airports to impose an ID card requirement with a photo. How many forms of photo ID should a pilot carry?
Yes, at the direction of our Congress, the FAA can make this a new requirement. However, what it does is create a requirement for additional FAA Certification staff and more bookkeeping. It will increase the cost of flying just to satisfy an order demanding a photo ID. And then we can expect a requirement to update the photos after that. All of this sounds like an old Army cliché about digging a hole and then going back and filling it. When we’re done, we’ve put in a lot of work and accomplished nothing.
The NPRM is saying that we need the photo, then it says that it incurs costs to handle that, and then we end up with an expanded bureaucracy. And for what?