For anybody who wants a possible better answer and who wants to spend $.35/minute they can call the National Passport Information Center at 1-90 and get an automated service or spend $1.05/minute for their operator service. Hair color is after all subjective and these clerks are looking at 2'x2' photos in which you can not tell black from brown, etc.' This information was from Chris Shearon at the Passport Now organization. The passport agency is most concerned with the integrity of the citizenship documents and birth records and less focused on application information.

I would also say that this does not solely apply to females as men gray as they age and there are also people like Dennis Rodman (what color is it today?) The color in the picture should be the color on the application. Thus the hair color should be consistent with the hair color on the application. If the picture is to be a 'true likeness' I would assume it would be of the current hair color. I would advise that the statement you sign claims that the picture is a 'true likeness'. PDF417 is capable of encoding all 256 values (bytes). This is what they sent back 'The State Department Regulations are silent on hair color. State Driver’s License Formats State License Format Alabama 1-7Numeric Alaska 1-7Numeric Arizona 1Alpha+1-8Numeric or 2Alpha+2-5Numeric or 9Numeric Arkansas 4-9Numeric California 1Alpha+7Numeric Colorado 9Numeric or 1Alpha+3-6Numeric or 2Alpha.

Following Ronald's advice, I sent a message to Passport Now [ After all with all this todo we should end up with an official answer.

Hair and eye color abbreviations