Question: Can someone who holds a student pilot certificate legally update the database of the GPS installed in their own airplane? Or does updating the database fall under “preventative maintenance,” which you can’t do on an aircraft you own or operate until you are at least a private pilot?
Answer: Per 14 CFR Part 43 subpart (k): Updates of databases in installed avionics meeting the conditions of this paragraph are not considered maintenance and may be performed by pilots provided:
(1) The database upload is:
(i) Initiated from the flight deck;
(ii) Performed without disassembling the avionics unit; and
(iii) Performed without the use of tools and/or special equipment.
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(2) The pilot must comply with the certificate holder’s procedures or the manufacturer’s instructions.
(3) The holder of operating certificates must make available written procedures consistent with manufacturer’s instructions to the pilot that describe how to:
(i) Perform the database update; and
(ii) Determine the status of the data upload.
As far as what is considered preventative maintenance, you can find that information under FAR 43.3, specifically, under Appendix A of Part 43.
Most of the items listed are simple replacements. Pilots/owners are allowed to perform tire changes, service shock struts, lubricate wheel bearings, and replace hydraulic fluid, side windows, lights, batteries, and tray-mounted avionics with the exception of transponders, DMEs, and autopilots.
If they have the skill and the proper tools, then they can also replace, clean, gap, or rotate spark plugs, replace prefabricated fuel lines and nonhydraulic hose connections, and clean or replace fuel and oil strainers and filters.
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