Comment on DOS-2026-0496-0001

As a frequent traveler, I use the 50-page passport book and benefit from it greatly. I would be unduly burdened by the removal of this option, and there are other ways in which the Department can address any inefficiencies arising from the maintenance of 2 passport size options. The Federal Register notice mentions that a planned enhancement to extend online passport renewal to overseas applicants may mitigate the burden of removing the 50-page book option. However, this overlooks the fact that one of the criteria for online renewal eligibility is that your current passport must be within a year of expiry. If one needs to renew due to running out of stamp/visa pages, it's because they ran out of stamp/visa pages significantly before the passport expired (because if it was close to expiry then you'd have to renew regardless of whether or not you have free pages left). As an example, my current (50-page) passport was issued mid-2023, and I'm already up to page 31 with stamps. Only pages 8 and up of our current passports are usable for visas & stamps, so there are 43 usable pages of which I've used 24. At this rate, I'd expect to run out of space and have to renew sometime in 2029. But if instead my passport had 38 pages (with 31 usable), then I'd expect to run out of space and need to renew in the first half of 2027. And I wouldn't be eligible to use the online renewal because my passport doesn't expire until 2033. Hence, any extension of online passport renewal to overseas applicants wouldn't alleviate the burden imposed by a lack of the 50-page book, because those needing to renew due to running out of pages couldn't do so online due to the requirement to be within 1 year of your current passport's expiry. Just like we have done for decades, many other countries also recognize that there are citizens who have a need for larger passport books and offer this option. For instance, The Netherlands issues a 34-page passport by default but will issue a 66-page passport upon request for no additional charge. Japan offers 2 sizes of passports, a 38-page passport with a 5-year expiration and a 54-page passport with a 10-year expiration. And Belgium ordinarily issues 32-page passports but will issue a 64-page passport for an additional charge. Notably, Belgian passports issued to adults expire after 7 years. In a contemporary Belgian passport of either size, pages 5 and up can be used for visas & stamps. Therefore, a 66-page Belgian passport would have 62 pages usable for stamps & visas, and therefore affords its bearer an average of almost 9 pages per year. By contrast, American passports issued to adults are generally valid for 10 years, and if it were limited to 38 pages, there would only be 31 pages usable for stamps and the bearer would thus be afforded an average of just over 3 pages per year, which is only a third of what Belgium's large book offers and is quite restrictive for frequent travellers, especially those who travel to places for which a visa (which typically takes up an entire page) is required. While not providing specifics, the Federal Register notice states that moving to a single size book will increase efficiencies and reduce waste at the GPO and within the Department. The Department has successfully offered 2 sizes of passports for decades, but if it is now cumbersome for the Department to offer 2 different sizes, then the Department could just have all books be 50-page by default. Then the Department would no longer need to manage 2 different sizes without burdening any existing passport holders. Another option would be to charge a higher fee for the larger book, which I would be happy to pay if the Department felt it necessary. For example, Japan and Belgium do this, charging 11000JPY/16000JPY and 65EUR/245EUR respectively for their smaller/larger books. Another thing to consider is that if the 50-page book is eliminated, then the people who used this option will renew more frequently, creating additional work and backlog for the Department. Also, our passports have an excessive amount of informational pages, spanning pages 4-7. Most of this information could instead be included in a leaflet or QR code provided with the passport, such as the links to the Department's travel information, CBP's website, and the agriculture rules. And some of the information — such as telling you that when you're in a foreign country you're subject to its laws — is so obvious that it really doesn't need to be mentioned at all. Removing this excess of information from the passport itself would free up more pages for visas & stamps. Even countries with only a single size of passport have more usable pages than 31 — Switzerland, for instance, has 36. I urge the Department to consider other alternatives and to keep the 50-page book.