X-Virus-Scanned: clean according to Sophos on Logan.com Return-Path: Sender: To: lml@lancaironline.net Date: Wed, 05 Jan 2011 12:34:49 -0500 Message-ID: X-Original-Return-Path: Received: from imr-mb01.mx.aol.com ([64.12.207.164] verified) by logan.com (CommuniGate Pro SMTP 5.3.11) with ESMTP id 4664856 for lml@lancaironline.net; Wed, 05 Jan 2011 11:47:05 -0500 Received-SPF: pass receiver=logan.com; client-ip=64.12.207.164; envelope-from=VTAILJEFF@aol.com Received: from imo-da03.mx.aol.com (imo-da03.mx.aol.com [205.188.169.201]) by imr-mb01.mx.aol.com (8.14.1/8.14.1) with ESMTP id p05GkKlY023685 for ; Wed, 5 Jan 2011 11:46:20 -0500 Received: from VTAILJEFF@aol.com by imo-da03.mx.aol.com (mail_out_v42.9.) id q.e7d.459acda (55485) for ; Wed, 5 Jan 2011 11:46:16 -0500 (EST) Received: from smtprly-ma03.mx.aol.com (smtprly-ma03.mx.aol.com [64.12.207.142]) by cia-md01.mx.aol.com (v129.7) with ESMTP id MAILCIAMD011-5c534d24a053c3; Wed, 05 Jan 2011 11:46:15 -0500 Received: from webmail-d073 (webmail-d073.sim.aol.com [205.188.167.107]) by smtprly-ma03.mx.aol.com (v129.5) with ESMTP id MAILSMTPRLYMA031-5c534d24a053c3; Wed, 05 Jan 2011 11:46:11 -0500 References: <1104183409281.1103262434267.482.1.1811000C@scheduler> X-Original-To: lml@lancaironline.net Subject: Fwd: NPRM Could Cost Instructors (And pilots) $210 Biennially X-Original-Date: Wed, 05 Jan 2011 11:46:10 -0500 X-AOL-IP: 75.63.172.235 In-Reply-To: <1104183409281.1103262434267.482.1.1811000C@scheduler> X-MB-Message-Source: WebUI MIME-Version: 1.0 From: vtailjeff@aol.com X-MB-Message-Type: User Content-Type: multipart/alternative; boundary="--------MB_8CD7B0F310B81E4_3E0_237BA_webmail-d073.sysops.aol.com" X-Mailer: AOL Webmail 33069-STANDARD Received: from 75.63.172.235 by webmail-d073.sysops.aol.com (205.188.167.107) with HTTP (WebMailUI); Wed, 05 Jan 2011 11:46:10 -0500 X-Original-Message-Id: <8CD7B0F3088960D-3E0-DF9F@webmail-d073.sysops.aol.com> X-Spam-Flag:NO X-AOL-SENDER: VTAILJEFF@aol.com ----------MB_8CD7B0F310B81E4_3E0_237BA_webmail-d073.sysops.aol.com Content-Transfer-Encoding: quoted-printable Content-Type: text/plain; charset="utf-8" I have responded to this NPRM and written to my congresman. If you like ne= w "user fees" then do nothing. Otherwise, I would recommend everyone on th= is list to write your congressman and also respond to the NPRM.=20 Jeff Edwards -----Original Message----- From: Society of Aviation and Flight Educators To: vtailjeff@aol.com Sent: Wed, Jan 5, 2011 10:00 am Subject: NPRM Could Cost Instructors $210 Biennially =20 FAA Photo Certificates Could Cost Instructors $210 Biennially from Robert Hadow, concerned SAFE member, flight school owner, instructor: On November 19, 2010, the FAA issued a Notice of Proposed Rulemaking (NPRM= ), Docket No. FAA-2010-1127, Notice No. 2010-16, entitled Photo Requiremen= ts for Pilot Certificates. Key elements in this NPRM and in additional doc= uments include: A proposal of $50 per new certificate and $25 per replacement. A requirement that student pilots wait 6-8 weeks to get a certificate befo= re solo. A claim that the new certificate fee represents no net cost to society. An assertion that the proposed photo procedure is "in the interest of redu= cing burdens on the certificate holder..." A claim that foreign pilots holding U.S. certificates would incur no addit= ional travel expense as a result of having to visit a testing center, FSDO= , or DPE. An assertion that there is "no additional expense to CFIs" as a result of= the initiative because we also hold Commercial Certificates or ATP certif= icates; the NPRM, however, describes CFI certificates separately. If the= NPRM language remains, CFIs will have to pay $210 for a new CFI certifica= te every two years when they renew. An FAA estimated total cost of $718.7 million to implement photo certifica= tes. Here is the list of costs estimated by the FAA per new certificate: FAA charge $50.00 Photo at CVS $8.00 Testing Center $42.50 Pilot Time $80.60 (130 minutes at $37.20 per hour) Travel $29.25 (50 miles) Total $210.35 The Intelligence Reform and Terrorism Prevention Act (IRTPA) requires the= FAA to issue pilot's licenses with photographs. Now the FAA has a legal= reason to replace the certificate system a second time in six years, and= sees an opportunity to increase fees and staffing. What we need to do is= point out the errors in logic and try to get something that works, rather= than a regression to a paper-based 8710 system with silver prints requiri= ng a physical visit to a FSDO or testing center. We can urge Congress to change the IRTPA, or we can urge the FAA to adopt= an implementation that is less costly and burdensome than the current pro= posal. If we don't respond, we're likely to get a system that costs $210= every time a pilot certificate or flight instructor certificate (new or= renewal) needs to be issued! General comments are due at the Department of Transportation on or before= February 17, 2011; however, comments related to data collection and cost= need to be submitted no later than January 18th. SAFE is preparing an off= icial response to the NPRM, and we are soliciting input from members. You= are urged to weigh in on this issue by January 14th by submitting the NPR= M comment form posted on the SAFE website. View the text of the NPRM: http://www.regulations.gov/#!documentDetail;D=3DFAA-2010-1127-0001 View other comments posted on regulations.gov: http://www.regulations.gov/#!searchResults;rpp=3D10;so=3DDESC;sb=3DpostedD= ate;po=3D0;s=3DFAA-2010-1127 =20 This email was sent to vtailjeff@aol.com by safe@safepilots.org. Update Profile/Email Address | Instant removal with SafeUnsubscribe=E2=84= =A2 | Privacy Policy. Email Marketing by =20 Society of Aviation and Flight Educators | c/o Virtual Accounting Svcs |= 80 Valley Grove Cove | Cordova | TN | 38018 =20 ----------MB_8CD7B0F310B81E4_3E0_237BA_webmail-d073.sysops.aol.com Content-Transfer-Encoding: quoted-printable Content-Type: text/html; charset="utf-8"
I have responded to this NPRM and written to my congresman. If you li= ke new "user fees" then do nothing. Otherwise, I would recommend everyone= on this list to write your congressman and also respond to the NPRM.
 
Jeff Edwards
 


 


-----Original Message-----
From: Society of Aviation and Flight Educators <safe@safepilots.org>=
To: vtailjeff@aol.com
Sent: Wed, Jan 5, 2011 10:00 am
Subject: NPRM Could Cost Instructors $210 Biennially

 
3DSAFE_Banner_Log=

FAA Photo Certificates Could Cost Instructors $210 Biennially
from Robert Hadow, concerned SAFE memb= er, flight school owner, instructor:

On November 19, 2010, the FAA issued a Notice of= Proposed Rulemaking (NPRM), Docket No. FAA-2010-1127, Notice No. 2010-16,= entitled Photo Requirements for Pilot Certificates. Key elements= in this NPRM and in additional documents include:
  • A proposal of $50 per new certificate and $25 per rep= lacement.
  • A requirement that student pilots wait 6-8 weeks to= get a certificate before solo.
  • A claim that the new certificate fee represents no ne= t cost to society.
  • An assertion that the proposed photo procedure is "in= the interest of reducing burdens on the certificate holder..."
  • A claim that foreign pilots holding U.S. certificates= would incur no additional travel expense as a result of having to visit= a testing center, FSDO, or DPE.
  • An assertion that there is "no additional expense to= CFIs" as a result of the initiative because we also hold Commercial Certi= ficates or ATP certificates; the NPRM, however, describes CFI certificates= separately.  If the NPRM= language remains, CFIs will have to pay $210 for a new CFI certificate ev= ery two years when they renew.
  • An FAA estimated total cost of $718.7 million to impl= ement photo certificates.
Here is the list= of costs estimated by the FAA per new certificate:
F= AA charge      $50.00
Photo at CVS   = ;  $8.00

Testing Center $42.50
Pilot Time  &n= bsp;     $80.60  (130 minutes at $37.20 per hour)=

Travel        &= nbsp;       $29.25 (50 miles)

Total  = ;            &= nbsp; $210.35


The Intelligence Reform and Terrorism Prevention Act (IRTPA) requires the= FAA to issue pilot's licenses with photographs. Now the FAA has a legal= reason to replace the certificate system a second time in six years, and= sees an opportunity to increase fees and staffing. What we need to do is= point out the errors in logic and try to get something that works, rather= than a regression to a paper-based 8710 system with silver prints requiri= ng a physical visit to a FSDO or testing center.

We can urge Congress to change the IRTPA, or we can urge the FAA to adopt= an implementation that is less costly and burdensome than the current pro= posal. If we don't respond, we're likely to get a system that costs $210= every time a pilot cert= ificate or flight instructor certificate (new or renewal) needs to be issu= ed!

Ge= neral comments are due at the Department of Transportation on or before Fe= bruary 17, 2011; however, comments related to data collection and cost nee= d to be submitted no later than January 18th. SAFE is preparing an official response to the NPRM, and we are solicitin= g input from members. You are urged to weigh in on this issue by January 14th by submitting the NPRM comment form pos= ted on the SAFE website.

View the text of the NPRM:
http://www.regulations.gov/#!documentDetail= ;D=3DFAA-2010-1127-0001

View other comments posted on regulations.gov:
http://www.regulations.gov/#!searchResults;rpp=3D10;so=3DDESC;sb= =3DpostedDate;po=3D0;s=3DFAA-2010-1127
3D"Safe=20
This email was sent to vtailjeff= @aol.com by safe@safepilots.org.
Update Profile/Email Address | Instant removal= with SafeUnsubscribe=E2=84=A2 | Privacy Policy.
= Email Marketing by
Society of= Aviation and Flight Educators | c/o Virtual Accounting Svcs | 80 Valley= Grove Cove | Cordova | TN | 38018
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