The National Business Aviation Association (NBAA) called\nupon the Federal Aviation Administration (FAA) to rethink its questionable\ndecision to deny requests from NBAA and others in the industry for additional\ntime to comment on new, onerous pilot-reporting requirements.<\/p>\n\n\n\n
The FAA\u2019s new data-gathering criteria, outlined in a\n200-page Notice of Proposed Rulemaking (NPRM), introduce sweeping new mandates\nfor certain Part 91 operators and others to submit a raft of additional pilot\ndata to the agency, through the use of an electronic Pilot Records Database\n(PRD). Although the FAA\u2019s new rule was issued March 30, the agency has elected\nto disallow additional time for pilots and other affected parties to offer\nfirst-hand perspectives on the proposal\u2019s most-troubling elements. <\/p>\n\n\n\n
\u201cMake no mistake: this plan raises serious privacy,\nadministrative and other concerns in an era of big-data gathering, sharing and\nuse,\u201d said Brian Koester, NBAA\u2019s director of flight operations and regulations.\n\u201cCertainly, the proposal has the potential to create efficiencies for air\ncarriers under current data-reporting laws. That said, the rules would not\nenhance safety for everyone, they propose substantial new regulatory burdens\nfor a large segment of the Part 91 community, and for many NBAA members, the\nplan could create more problems than it solves.\u201d<\/p>\n\n\n\n
Koester noted that the new FAA rules would expand the\ndata-collection requirement provisions outlined in the Pilot Records\nImprovement Act (PRIA). That legislation, enacted in 1997, was intended simply\nto establish requirements for airlines to conduct pilot-background checks \u2013\nincluding aviation experience and history, drug and alcohol testing results and\ndriver-registration records \u2013 as part of the hiring process.<\/p>\n\n\n\n
As a result of congressional updates to PRIA in 2010, the\nFAA\u2019s newly proposed rule would widely broaden this mandate, in the process\nlayering on a new administrative burden for Part 91 operators, which often count\nonly a handful of employees in their ranks.<\/p>\n\n\n\n
The flaws in the FAA\u2019s new mandates are all the more\ntroubling, given the nearly decade-long effort on pilot-reporting requirements,\nin which NBAA has been a supportive partner to government. In 2011, the FAA\nchartered a government-industry Aviation Rulemaking Committee to explore\nreporting criteria, partly in response to the fatal 2009 Colgan Air accident in\nBuffalo, NY.<\/p>\n\n\n\n
Over the ensuing nine years, a concerted effort was\nundertaken to examine options for increasing the efficacy of the information in\nthe database, while mitigating concerns raised by NBAA and others.\nNevertheless, the resulting rule from the FAA looked past many of those\nconcerns, and only 90 days have been provided for stakeholders to comment on\nthe plan, including its exhaustive list of more than 20 additional technical\nquestions for affected stakeholders.<\/p>\n\n\n\n
\u201cIt is exasperating that the FAA has given industry just 90\ndays to unpack a complicated plan amassed over nine years, and released as the\naviation community fights for its survival during COVID-19,\u201d said Koester. \u201cIt\nwould not seem unreasonable to allow another 30 days for discussion, so we are\npursuing other means to encourage the FAA to provide for this minimal,\nreasonable accommodation.<\/p>\n\n\n\n
\u201cFurther, given the FAA\u2019s request for industry input on over\n20 technical questions, it seems this rulemaking process would have benefitted\nfrom an Advanced NPRM to allow the FAA to receive preliminary industry\nfeedback, and include those perspectives in a more thorough and polished\nproposal.\u201d<\/p>\n\n\n\n
With that in mind, Koester pointed to a new NBAA resource\nassociation members can use to digest the massive proposal and develop their\nindividual responses for the FAA to help ensure industry\u2019s voice is heard.<\/p>\n\n\n\n
The NBAA Regulatory Alert provides operating members with an\noverview of the proposed rule, highlights concerning provisions, and includes\ninstructions for submitting comments to the FAA. Link to NBAA\u2019s Regulatory\nAlert and make your voice heard.<\/p>\n\n\n\n
\u201cThe public comment period for the NPRM ends June 29, 2020,\nso we need everyone to make their voices heard today,\u201d Koester concluded.<\/p>\n","protected":false},"excerpt":{"rendered":"
The National Business Aviation Association (NBAA) called upon the Federal Aviation Administration (FAA) to rethink its questionable decision to deny requests from NBAA and others in the industry for additional time to comment on new, onerous pilot-reporting requirements. The FAA\u2019s new data-gathering criteria, outlined in a 200-page Notice of Proposed Rulemaking (NPRM), introduce sweeping new […]<\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[115],"tags":[],"class_list":["post-15790","post","type-post","status-publish","format-standard","hentry","category-national-news"],"jetpack_featured_media_url":"","jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/posts\/15790","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/comments?post=15790"}],"version-history":[{"count":1,"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/posts\/15790\/revisions"}],"predecessor-version":[{"id":15791,"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/posts\/15790\/revisions\/15791"}],"wp:attachment":[{"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/media?parent=15790"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/categories?post=15790"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/tags?post=15790"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}