The National Business Aviation Association (NBAA) and Aircraft Owners and Pilots Association (AOPA) recently conducted a survey to generate input from their member pilots in response to an FAA notice of proposed rulemaking (NPRM) introducing a new electronic Pilot Records Database (PRD) that would involve certain Part 91 operators. Based on the comments received, the survey results indicate pilots have significant concerns over the potential burden of the FAA’s proposed rule change.
The proposed rule would require owners and/or operators with two or more aircraft that require a type rating and who employ pilots to enter information about their pilots’ currency and backgrounds in the database, for use by air carriers and other entities during the vetting of prospective hires. The intent of the proposed change is to improve safety by improving the hiring process for certain aircraft operators, most of which are not currently subject to reporting requirements outlined in the NPRM.
The survey targeted pilots holding an air transport pilot certificate to gauge the industry’s perception of the PRD, and more than 1,200 pilots from NBAA and AOPA 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 percent of respondents believe the comments should be included in the PRD,” NBAA said.
“The survey results are clear—our members do not believe the proposed electronic Pilot Records Database will significantly 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.” NBAA added that since the vast majority of pilots responding to the survey said they would be required to log activity that may be required in the FAA PRD up to several times per day, some pilots estimated it could take “over 18 hours per month” to maintain records that may be required by the new PRD.
Dan Hubbard, NBAA’s senior vice president, communications, added that NBAA supports modernizing the PRIA process. “However, we are concerned that the FAA’s proposed rule creates new, burdensome recordkeeping and reporting requirements without improving safety for Part 91 operators. The survey results indicate that the industry shares our concerns,” he said.
In a seven-page letter of comments filed in June, AOPA concurred with the need for air carriers to have the means to ascertain accurate training records of pilot candidates, but were concerned that the proposal “expands beyond what is statutorily required, does not accept industry recommendations, and does not provide a clear process for the lifetime of the pilot to have errors on their record corrected.”
“AOPA strongly believes that the Pilot Records Database must include a clear process for correcting erroneous information, with the FAA responsible for evaluating and correcting inaccuracies if a pilot’s employer is unwilling or unable to do so,” said Murray Huling, AOPA vice president of regulatory affairs. “The need to provide pilots with transparency and convenient access to their records is why we also recommend allowing any holder of an FAA-issued pilot certificate to inspect their information on file in the database.”
Both associations signed on to a letter sent to FAA Administrator Steve Dickson in August, noting that 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. “All of this would impose significant additional costs for many small general aviation businesses without providing useful insights for air carrier hiring decisions, as carriers already review a pilot’s logbook to verify currency prior to employment,” the joint letter stated.
