How should I handle the maximum length for given names on the U.S. passport card?

Question

I'm preparing a Form DS-11 passport application for my infant daughter, who never has been issued a prior U.S. passport.

I'm considering applying for both a passport book and a passport card for her, but I saw the note in Section F (page 3) of the DS-11 instructions under "Difference Between U.S. Passport Book and Card" that reads:

The maximum number of letters provided for your given name (first and middle) on the card is 24 characters. If both your given names are more than 24 characters, you must shorten one of your given names you list on item #1 of Application Page 1.

My daughter's full given name is 25 characters—one first name of nine letters, followed by two middle names of nine and 5 letters, respectively (9 (first) + 9 (middle) + 5 (middle) + 2 (spaces) = 25)—so this appears to be unable to fit on the passport card.

I have a few questions about what to do about this:

• Does this length limit also apply to the passport book? (The instructions don't say anything about name length for the book, but I want to confirm.)
• Are there preferred or suggested methods for shortening given names in this scenario? (Since this is an identity document, I want to try to avoid unnecessary confusion or complications down the road.) Possible options I can think of are:
  • omitting one middle name (First Middle Last)
  • using an initial for one middle name (First Middle M Last)
  • omitting the space between two names (First MiddleMiddle Last, since my daughter's name is literally one character too long)
• Is it possible for a person to be issued a passport book and a passport card with different forms of their given name? (For example, could my daughter be issued a passport card with her second middle name omitted for length (i.e., First Middle Last) and separately be issued a passport book with both middle names retained (i.e., First Middle Middle Last)?)
  • If so, would this require two separate Forms DS-11 to be completed and two separate execution fees to be paid?

I tried emailing the National Passport Information Center as noted at the beginning of the form's instructions, but I got an immediate form reply that specifically said it "is the only reply [I] will receive to [my] email."

Answer 1

My middle name has three words, and my full name has 31 characters, including spaces. I don't have a passport card, but I've had my name truncated in several contexts, never with my input, usually to 30 characters. Sometimes they have dropped the last letter of my middle name; sometimes they have removed one of the spaces.

Does this length limit also apply to the passport book? (The instructions don't say anything about name length for the book, but I want to confirm.)

I don't think so. I suspect that the limit is not mentioned because it is implicit in the fact that they provide 16 positions in the form itself.

Are there preferred or suggested methods for shortening given names in this scenario?

I think the reason they ask you to shorten the name is that it doesn't matter how it's done, and they want you to choose the method that you are most comfortable with.

Another possiblity in addition to those you've mentioned is to drop the last letter of the second middle name. This is the approach mandated by the International Civil Aviation Organization when the name shown in the "visual inspection zone" is too long to fit in the "machine readable zone." That's not the case here, of course, but it does nonetheless suggest that this is an acceptable option.

Is it possible for a person to be issued a passport book and a passport card with different forms of their given name?

It must be, at least in cases where a name exceeds the limits of the card but not of the book.

If so, would this require two separate Forms DS-11 to be completed and two separate execution fees to be paid?

If your daughter were over 16, she could use DS-82 to get the card after using DS-11 to get the book. As she is not yet 16, this isn't an option.

One possibility that might appeal is to apply with the name as it should be shown in the book and let the passport office decide how to shorten it for the card. I don't know, however, whether they would do that or just refuse to issue the passport card or even reject the application entirely.

You could also try including a note describing how you want the name shortened for the card, but I would be surprised if the acceptance agent allows it and even more surprised if the passport office followed it.

Another thing you might try is to ask the acceptance agent. They may have seen such a case before, and (perhaps it is too much to hope) their training may even include guidance on this situation.

Depending on how much you travel, and given the expense and shorter validity period of documents issued to children, you might also consider forgoing the passport card entirely. I think I would be inclined to do that unless I were driving into Canada or Mexico several times a month.