AOPA, in a joint letter with the National Business Aviation Association, wrote to FAA Administrator Steve Dickson regarding the Pilot Records Database (PRD) proposal and the negative impact it would have on general aviation pilots.
AOPA President Mark Baker and NBAA President and CEO Ed Bolen emphasized support for the “high-level goal” of the PRD rulemaking to “help better inform air carrier pilot hiring decisions” and to improve aviation safety by allowing commercial air carriers to access a pilot’s records and other pertinent information prior to making a hiring decision. However, the associations stopped short of fully supporting the proposed rule with language that is currently drafted because it would place “burdensome and costly requirements on general aviation, with little to no safety benefit,” the leaders wrote.
The database is intended to facilitate sharing records surrounding a pilot’s qualifications before an air carrier decides to hire that pilot. The catalog includes information about medical certificates, employment history, flying records, and types of aircraft pilots are qualified to fly.
However, the PRD rule would open the door to FAA reporting on Part 91 commercial and airline transport pilots, and that is “not reflective” of the safety-minded GA stakeholders participating in the Aviation Rulemaking Committee process, Baker and Bolen pointed out.
The leaders emphasized that the “high cost of compliance with these new requirements will turn operators away from general aviation at a time [when] our industry is already facing significant economic and operational challenges due to the COVID-19 pandemic.” They cited new language that redefines a “corporate flight department” and could place significant compliance challenges on many small aviation businesses.
Of particular concern are requirements “for operators to report a pilot's aeronautical experience, flight time, and flight maneuvers performed to maintain privileges of their certificate.”
“Compliance with this requirement would likely require Part 91 operators to log every flight hour, instrument approach, and landing in the PRD after every flight,” they wrote. The effort to keep information up to date could consume “hours of data entry to duplicate” without a safety benefit; and could also increase the risk of pilot record errors.
To comply with the proposal, small GA 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,” the letter added. “All of this would impose significant additional costs” without “providing useful insights for air carrier hiring decisions” because recruiters “already review a pilot's logbook to verify currency prior to employment.”
Baker and Bolen explained to the administrator that there are already opportunities within existing FAA regulations that could accomplish the same reporting goals.
During the NBAA Virtual Business Aviation Town Hall on August 4, Bolen asked Dickson to explain what problem the FAA was trying to solve with the proposed rule on pilot records.
Dickson said, “the primary focus here has been on the air carrier qualifications and the ability to be able to share either employment or training data that’s germane to identifying performance issues during the hiring process.”
Dickson said that the FAA is adjudicating comments on the rule now and will “have to look at the burden on different operators.” He added that he would “certainly commit to you that we will take all that perspective into consideration as we work toward having a final rule out there.”
The letter to the FAA noted that NBAA surveyed a group of members to find out how often corporate flight departments were tasked with providing Pilot Records Improvement Act requests. He said operators meeting the newly defined corporate flight department language received “less than one PRIA request every two and a half years.”
AOPA and NBAA determined that the burdensome proposal was not cost-effective and that it would not produce meaningful information during the air carrier hiring process. In addition, the two groups said that the existing process meets current needs.
“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,” the groups noted.
AOPA and NBAA are planning to conduct a joint membership survey seeking information on the PRD’s potential impact to the GA community.