AOPA has urged the FAA to go beyond a proposal to allow pilots operating under Parts 121 and 135 of the regulations to update certain navigation and terrain-awareness databases by freeing all pilots—including those operating under Part 91—of a record-keeping burden associated with maintaining the databases.
The association also urged clarifying the proposal to ensure that its provisions include terrain and obstacle database updates.
The proposed rule would allow pilots “to update databases used in self-contained, front-panel or pedestal mounted navigation equipment installed on aircraft operated under Parts 121 and 135 of the regulations.” Under current rules, pilots of aircraft operating under Part 91 may perform the updates, while under Parts 121 and 135 the update must be performed by a certificated mechanic or repair station.
“Currently, Part 91 pilots can update the databases, but they must keep a record of the update,” said Rob Hackman, AOPA vice president of regulatory affairs. “We think the FAA should go beyond its proposal and eliminate this, and drop a new recording requirement for the Part 135 and 121 operators as well.”
AOPA agreed in comments submitted Dec. 19 that the rule change would increase safety by allowing pilots better access to the most current and accurate navigational data. However ,the association recommended dropping the proposed language requiring maintenance entries for updates because the record-keeping would have “no positive effect” on safety, while imposing costs on operators.
AOPA expressed concern “that the proposed language creates a second record-keeping requirement and that the return to service maintenance entry required by [FAR 43.7] may no longer be made by the pilot; instead the return to service will need to be completed by ‘qualified personnel.’ The requirement for database updates and subsequent return to service to be performed by a mechanic or repair station is exactly what the FAA was attempting to change through this rulemaking,” Hackman wrote. “These maintenance record issues appear to be unintended consequences and contrary to the proposed change.”
“As noted earlier, AOPA does not believe any record is necessary. We see no reason for two records,” he wrote.