General aviation leaders continue to press the FAA to rework its electronic Pilot Records Database (PRD) proposal, saying the current notice of proposed rulemaking would create burdensome and costly requirements with little safety benefit. Aircraft Owners and Pilots Association president and CEO Mark Baker joined NBAA president and CEO Ed Bolen in a letter last week to FAA Administrator Steve Dickson expressing “serious concerns” about the rulemaking. Their letter followed opposition voiced during the comment period, as well as from Bolen to Dickson during an NBAA virtual town hall meeting last week.
“Our industry continuously demonstrates its commitment to proactive and performance-based safety innovations, but in our opinion, the proposed PRD requirements for general aviation will not improve safety,” said the association leaders, objecting to the inclusion of Part 91 corporate operators in the requirements to submit pilot records in the electronic database.
“The high cost of compliance with these new requirements will turn operators away from general aviation at a time our industry is already facing significant economic and operational challenges due to the Covid-19 pandemic,” they warned.
They noted that a PRD aviation rulemaking committee had discussed the unique challenges of general aviation participation and opted against recommending, including private operators. They cited as an example the PRD proposed requirement to report aeronautical experience, flight time, and flight maneuvers.
“Compliance with this requirement would likely require Part 91 operators to log every flight hour, instrument approach, and landing in the PRD after every flight…To comply with this proposed reporting requirement, small general aviation operators would need to invest in new systems, potentially hire additional staff, and reduce their focus on flight operations to accomplish hours of data entry and tracking,” Bolen and Baker said. “All of this would impose significant additional costs for many small general aviation businesses without providing useful insights for air carrier hiring decisions.”
They also questioned the introduction of a definition of a corporate flight department as one that operates two or more aircraft requiring a type rating in furtherance of business.
“These entities would be required to submit records to the PRD; however, the new definition does not consider the significant compliance challenges for these operators, many of which are small businesses,” they said. “We believe there are opportunities within existing FAA regulations to define better which operators should be subject to the PRD, without creating a new definition that will be difficult to apply to the general aviation community.“
NBAA members have indicated they receive very few requests for pilot records from air carriers, they noted. “Due to the extremely low volume of requests, it is not cost-effective for these operators to submit data to the PRD, as the existing process meets current needs,” they added.