You may recall my difficulties in changing the M to an F with the FAA (here, here, here, and here), but I am happy to report that I finally buckled and complied and have now been issued an airman’s certificate that has my new name and new sex written on it.

One of the problems with the FAA regarding gender marker changes is that their policy is inconsistent and incoherent, which is kind of unusual for an organization that defines everything. Where I got on the wrong path (and perhaps it was unavoidable) is that the FAA website makes it sound as if gender marker changes are easy, but that the actual FAA regional officers don’t use the website, but rather a field manual called FAA Order 8900.1. You see, on the very first page of the FAA website that deals with pilots, the requirements are pretty plain and make it seem as if all you need is a letter from a psychologist:

Gender change

To obtain a new airman certificate that reflects a gender change, it is necessary that you appear at an FAA Flight Standards District Office (FSDO) for positive identification. One or both of the following documents must be presented to an FAA Inspector:

1. A court order issued by a court of the United States or it's territories stating that the applicant has changed his/her gender, and/or
2. A statement from a physician or clinical psychologist treating the applicant that contains:
* Identification of the applicant by name and address, and
* Verification that the applicant is undergoing treatment that has altered or will alter the gender

However, this information is incorrect, as the field inspectors use an internal document, as I was told at my local field office. This document, they said, requires a surgeon’s letter. However, a visit to the FAA and a search for “8900.1” reveals that there’s a whole website devoted to Flight Standards Information, http://fsims.faa.gov/, and if one searches that site for gender, one finds the current version dealing with exchange of valid pilot certificates, and at 5.317, part D, “Changes to personal data,” we find

D. Change of Gender. For a change of gender on an airman certificate, the original copies of two documents must be provided to the certifying ASI. After examining and verifying these documents, the ASI photocopies the documents and attaches the photocopies to Form 8710-1. In block I, under “Other”, the ASI notes gender change reissue. The file is then forwarded to AFS-760 for processing. The required documents are:
1) A court order, issued by a court of the United States or its territories, stating that the individual has changed his/her gender to ___, or a court order stating that the individual’s gender is ___; or
2) A physician’s statement clearly indicating that the individual is physically the gender noted on the court order.

I do not know where my office gets the “surgeon’s letter required,” but suffice to say that was what I had to do to change the gender marker.

But the point of this blog entry is to highlight inconsistencies, so I wrote the FAA webmaster about the wrong information on their website, and here’s the letter I received in return:

Your are correct:

Our web page at http://www.faa.gov/licenses_certificates/airmen_certification/name_change/ does not specify a physical gender change while FSIMS Volume 5, Chapter 2, Section 5, para. 5-317 does.

We are researching his discrepancy. You may contact the Flight Standards Web Manager, Joel Wilcox, for the status of this research: 202-493-4876.

It’s small, but at least it’s a recognition that there is an inconsistency. What’s frustrating is that this labyrinth of information isn’t easy for the transgender pilot to navigate. A system of information that was user-oriented, one that anticipated that there’s a transgender pilot who wants to change information, would try to answer, unambiguously, that person’s question. Instead, the web gives us false hope, the official regulations (FAR’s) mention nothing about gender, and order 8900.1, which pilots don’t even know exists, is the “ultimate” guide — but even this order seems to have been revised with multiple versions floating around out there.