The National Business Aviation Association (NBAA) and the Aircraft Owners and Pilots Association (AOPA) have sent a letter to FAA administrator Steve Dickson expressing their “serious concerns” with the agency's proposed rulemaking regarding the Pilots Records Database (PRD).
NBAA president and CEO Ed Bolen and AOPA president Mark Baker emphasised their support for the PRD's high-level intent to improve aviation safety by allowing commercial air carriers to access a pilot's records and other pertinent FAA information prior to making a hiring decision. However, the agency's notice of proposed rulemaking (NPRM) would also place “burdensome and costly requirements on general aviation, with little to no safety benefit,” the leaders wrote. “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.”
A recent survey of NBAA members meeting the NPRM's definition of a “corporate flight department” found those operators received less than one Pilot Record Improvement Act (PRIA) request every two-and-a-half years. However, to comply with the proposal's mandates would require many Part 91 non-commercial operators to invest in new systems and hire more staff to record their pilots' flight information in the PRD after every flight.
For example, NBAA calculated a small business aviation flight department would spend approximately $9,100 annually per aircraft in administrative costs to populate the database under the current NPRM, when that money could be better invested in technologies like performance-based safety innovations.
“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 letter read.
Bolen and Baker further noted the proposed rulemaking incorporates few of the many recommendations provided by GA stakeholders who participated in the PRD Aviation Rulemaking Committee to inform the agency's rulemaking process. Their letter also pointed to the hundreds of AOPA and NBAA members who have detailed their concerns about the NPRM.
“In reviewing the legislative intent behind the PRD and the feedback provided by the general aviation community, we believe our recommendations can improve the NPRM without compromising safety,” they wrote. “We look forward to staying in communication with you and your team as we receive additional information on potential impacts to our members.”
During a 4 August NBAA Virtual Business Aviation Town Hall discussion, Dickson expressed his willingness to work with industry stakeholders to address concerns about the NPRM and its seeming overreach.
“I certainly understand that it's not a one size fits all here,” he said. “We have to take a look at the burden on different operators… I will certainly commit to you that we will take all [comments] into consideration as we work toward having a final rule out there.”