Nov. 19, 2020
Two airport leaders are among those who recently shared their concerns for small businesses and organizations mandated to comply with the FAA’s proposed electronic Pilot Records Database (PRD) in letters to the agency and Congress.
Michael Hall, director of Ithaca Tompkins Regional Airport (ITH), and Mark Heefner, commissioner of aviation at the Greater Binghamton Airport (BGM), separately wrote to the agency to express their significant concerns regarding the PRD, proposed by the FAA earlier this year. The letters were also sent to the chairmen and ranking members of the U.S. House of Representative Transportation Committee and Aviation Subcommittee, and the Senate Committee on Commerce, Science and Transportation and Aviation and Space Subcommittee.
The PRD proposal includes a number of new reporting mandates for certain Part 91 operators and codifies the term “corporate flight department.”
The directors’ concerns echo those previously relayed by NBAA and other aviation groups to the FAA and Congress, calling the PRD “an enormous administrative burden” and questioning how these changes would enhance safety, adding the PRD requirements would be “repetitive, duplicative and place an enormous cost and administrative burden on businesses with no demonstrable safety benefit.” One estimate suggests small businesses and organizations will face nearly $10,000 annually in new administrative costs.
The letters highlighted the importance of general aviation in the United States, including the industry’s economic impact of $247 billion per year and support of more than 1.1 million jobs, often while providing emergency services, medical care and disaster relief. However, the COVID-19 pandemic has severely affecting general aviation, with operations down approximately 30% compared to this time last year.
“The directors’ comments clearly show that the effects of this rule stretch beyond pilots and could inhibit the general aviation industry’s further growth at a time when the industry is already suffering the impacts of COVID-19,” said Brian Koester, CAM, NBAA’s director of flight operations and regulations. “Not only are the PRD requirements overly burdensome and overreaching, there is no clear safety justification for implementing these new mandates.”
The final rule has progressed to review from the Office of Management and Budget. NBAA will continue to work with the federal agencies and Congress to mitigate the overall impact of this rule on businesses.
In comments to the FAA submitted earlier this year, NBAA expressed many of these concerns, highlighting three key concerns for business aviation:
- Codification of the term “corporate flight department”
- Overly burdensome recordkeeping requirements with no clear safety benefit
- Inclusion in the PRD of check airman and instructor comments