Oct. 6, 2020
NBAA and the Aircraft Operators and Pilots Association (AOPA) have partnered on a survey soliciting feedback on the FAA’s proposal for a Pilot Records Database (PRD).
The FAA published a notice of proposed rulemaking (NPRM), introducing new mandates for certain Part 91 operators and others through the use of an electronic PRD. This NPRM would have a substantial impact on a large portion of the business aviation community, much of which is not currently subject to reporting requirements.
In June, NBAA submitted detailed comments outlining the association’s concerns regarding the proposal. The most significant concerns related to business aviation are:
- 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
“NBAA and other aviation industry groups participated in an Aviation Rulemaking Committee on the Pilot Records Database several years ago,” explained Brian Koester, CAM, NBAA’s director of flight operations and regulations. “However, the FAA diverged from many of the industry consensus recommendations outlined in the ARC’s final report, including a recommendation to exclude check airman and instructor comments from the PRD.”
NBAA and other industry representatives fear inclusion of instructor and check airman comments in a permanent database will discourage instructors and check airmen from providing important critical feedback that could enhance a pilot’s performance and therefore improve overall safety.
NBAA and AOPA are seeking industry feedback regarding the PRD and related recordkeeping requirements in order to quantify the true impact of the proposed rule.