NBAA Shares Industry’s Pilot Record Database Concerns with OMB, Other Agencies

Dec. 8, 2020

NBAA recently met with representatives from several federal agencies to share the business aviation industry’s continuing concerns regarding the proposed electronic Pilot Records Database (PRD) rule.

The PRD, outlined earlier this year in a notice of proposed rulemaking (NPRM) from the FAA, would require certain Part 91 operators to submit training and other employment records to a national database. NBAA believes inclusion of these Part 91 operators exceeds the original intent of Congress.

Three key issues impacting business aviation were highlighted in the meeting:

• Definition of “corporate flight department”
• Inclusion of check pilot comments from training and checking events
• Inclusion of aeronautical experience requirements

NBAA shared these concerns with representatives from the Department of Transportation’s Office of the Secretary, the FAA’s Office of Rulemaking and the Office of Information and Regulatory Affairs, as well as OIRA’s parent agency, the Office of Management and Budget.

“NBAA wants to ensure we’ve communicated concerns with every office involved in this rulemaking initiative,” said NBAA Director of Flight Operations and Regulations Brian Koester, CAM. “The meeting was successful in raising new concerns brought to light since the NPRM was published.”

“Survey results indicated this rule will cost operators approximately $9,100 per aircraft per year,” said Koester. “The PRD requirements will offset PRIA [Pilot Records Information Act] mandates; however, surveys indicate most operators receive only one PRIA request every two and a half years. This demonstrates the fact business aviation is simply not a common gateway to the airlines. Applying PRD mandates to certain Part 91 will not be effective in improving airline safety.”

NBAA recommended the final rule establish a voluntary procedure for Part 91 operators to participate in the PRD due to the burdensome costs and lack of demonstrated safety benefits resulting from mandatory participation.