Nov. 17, 2020
New survey results released by NBAA and the Aircraft Owners and Pilots Association (AOPA) indicate pilots have significant concerns over the potential burden of the FAA’s proposed Pilot Records Database (PRD).
The FAA published a notice of proposed rulemaking (NPRM) earlier this year introducing an electronic PRD with new mandates for certain Part 91 operators with the intent to improve safety by improving the hiring process for certain aircraft operators. Much of the business aviation industry is not currently subject to reporting requirements outlined in the NPRM, resulting in many new mandates for these operators.
The survey targeted pilots holding a commercial air transport pilot certificate to gauge the industry’s perception of the PRD, and more than 1,200 pilots responded. All survey respondents expressed skepticism about the proposed PRD, particularly in terms of time necessary to comply and burdens of new requirements. For example, more than half of the respondents with two or more type-rated aircraft are against including check airman comments in the PRD. Only 20% of respondents believe the comments should be included in PRD.
A key concern of respondents is that time spent entering data into the PRD to comply with these requirements would create a significant burden without a corresponding improvement over the current system.
The vast majority of responding pilots said they would be required to log activity that may be required in the FAA PRD, such as night landings or instrument approaches, at a minimum of once or twice a month and up to several times per day, with some estimates over 18 hours per month to maintain records that may be required by the new PRD.
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
“The survey results are clear – our members do not believe the proposed electronic Pilot Records Database will significant improve hiring processes or safety,” said Brian Koester, CAM, NBAA’s director of flight operations and regulations. “NBAA and AOPA appreciate the robust response to this survey and will use the survey results to guide discussions with regulators.”