While the FAA’s new electronic pilot record database (PRD) rule expands the applicability of record-keeping mandates for air carrier hiring purposes to corporate flight departments, business and general aviation organizations welcomed changes that exempt most of the sector from “onerous” reporting requirements.
NBAA, which had voiced strong opposition to the notice of proposed rulemaking released more than a year ago, said the hundreds of comments from the business aviation community proved critical to some of the key changes in the rule. In the final rule, the agency said it determined that “in light of the information and data provided by commenters, some requirements of the proposed rule were overly burdensome for certain types of operators” and, as a result, exempted corporate flight departments, air tour operators, and public operators from requirements to upload training, disciplinary, and separation-from-employment records to the PRD unless and until requested by a hiring operator. But certain termination and disciplinary action records must be reported.
NBAA further noted that the rule eliminated a single “corporate flight department” definition out of industry concerns that the precedent-setting definition would not reflect the diversity of the industry. In the rule, the FAA acknowledged those concerns and instead included a footnote stating: “The FAA uses the term corporate flight departments to reference operators of two or more aircraft conducting operations in furtherance of or incidental to a business, solely pursuant to the general operating and flight rules in Part 91 or operating aircraft pursuant to a Letter of Deviation Authority issued under § 125.3.”
“This final rule reflects a more risk-based approach to safety and demonstrates that our community effectively made its voice heard during the rulemaking process,” said NBAA president and CEO Ed Bolen. “The business aviation community stands for safety, and working together, we have determined the best way to address the agency’s aims, without introducing needless reporting requirements that do not have a clear safety benefit.”
Meanwhile, the Aircraft Owners and Pilots Association, which had joined NBAA in expressing strong reservations about the rule, also was encouraged by some of the incorporated changes. "While AOPA continues to review the final rule, we are pleased to see the FAA has addressed some of our concerns to the proposed rule,” said Christopher Cooper, AOPA's senior director of regulatory affairs.
He noted the final rule now establishes a process to resolve errors to a pilot's record and reduces the reporting burden for small and sole-practitioner Part 91 operators, such as air tour and corporate flight operations. “Compared to the proposed rule, both changes provide increased flexibility and transparency, while also ensuring safety and accurate pilot records," Cooper said.
Both associations said they are continuing to review the rule.
This story has been updated to include comments from AOPA.