April 2, 2020

NBAA is studying a new notice of proposed rulemaking (NPRM) detailing the implementation of a new electronic Pilot Records Database (PRD), and welcomes the opportunity to comment on the ramifications of this complex proposal for business aviation.

Mandated by Congress to improve safety at commercial airlines, the PRD is being created to replace a pilot records system that currently relies on the FAA and operators maintaining separate records. Under the FAA’s new plan, the PRD will combine these two records systems into a centralized database that would be managed by the agency and accessed by aircraft operators with the consent of an individual pilot.

“The Pilot Records Database will facilitate the sharing of records relevant to a pilot’s qualifications before an air carrier decides to hire that pilot. The database includes information on medical conditions, employment history, flying records, and types of aircraft pilots are qualified to fly,” said the U.S. Department of Transportation in a press release.

The press release also indicated that “[the] new database will provide potential employers with rapid access to information about a pilot’s performance and employment records. This advancement will cut the amount of time for potential employers to review this information from 30 days to less than an hour.”

Business aircraft operators do not currently report or maintain pilot records for the FAA, but those operating with two or more aircraft will be required to submit data for the agency’s new electronic database, according to the NPRM.

“The FAA believes that corporate flight departments typically operate airplanes that provide both entry-level pilots and experienced pilots access to many type-rated airplanes that offer similarities to those operated by air carriers,” the agency says in the NPRM. “As a result, the FAA believes that the records maintained by corporate flight departments would be useful for air carriers to review prior to making a hiring decision on a pilot.”

According to the NPRM, air tour operators and fractional owners will also be asked to expand the amount of data they report because their pilots are likely to be recruited by Part 121 air carriers. This new data will include training, qualification and proficiency reports, disciplinary actions and separation from employment information.

The FAA also plans to expand its database on pilots working at air tour operators and fractional operations beyond airmen and medical certificate data to include any failed attempt to pass a practical test needed to obtain a certificate or type rating, all accident and incident information, and summaries of violations.

“NBAA supports the development of an electronic database to improve the safety of our nation’s airspace,” said Brian Koester, CAM, NBAA director of flight operations and regulations. “We recognize that this is a precedent-setting rulemaking that for the first time defines a business flight department in the Federal Aviation Regulations and expands the reporting standards for air tour operations and fractional owners. We are working diligently to evaluate how this will affect business aviation and look forward to issuing our comments soon.”