Review NBAA\u2019s full comments to the FAA. <\/a><\/p>\n\n\n\nThe FAA\u2019s proposed PRD would create substantial new pilot\ndata recordkeeping and reporting requirements for a large portion of the\nbusiness aviation community that is not currently subject to similar reporting\nobligations. The proposed rules would expand data-collection mandates outlined\nin the Pilot Records Improvement Act (PRIA), which was enacted in 1997 to\nestablish requirements for air carriers to conduct pilot background checks\nduring the hiring process.<\/p>\n\n\n\n
The NPRM includes certain Part 91 operators, which appears\nto exceed the scope of the legislation that originally drove the proposal. It\nalso includes concepts that could negatively impact safety that are clear,\nobvious examples of \u201cregulatory creep.\u201d<\/p>\n\n\n\n
For example, the proposed rule includes requirements to\nsubmit instructor and check airman notes regarding a pilot\u2019s training.\nIncluding these subjective notes turns training and checking into punitive\nevents that could discourage pilots from seeking additional training and\ntherefore negatively impact safety.<\/p>\n\n\n\n
NBAA also strongly opposes the codification of \u201ccorporate\nflight department,\u201d a term currently undefined in the Code of Federal\nRegulations.<\/p>\n\n\n\n
Although the FAA\u2019s new rule was issued March 30, the agency\nelected to disallow additional time for pilots and other affected parties to\noffer first-hand perspectives on the proposal\u2019s most-troubling elements. <\/p>\n\n\n\n
\u201cNBAA is concerned that the safety and public interests\nanalysis conducted in support of this proposal do not suggest a need to expand\nthese reporting requirements to Part 91 operations,\u201d said NBAA Chief Operating\nOfficer Steve Brown. \u201cFurther, the arbitrary need to define a \u2018corporate flight\ndepartment\u2019 and the lack of any clear safety benefits of this proposal\nattributable to Part 91 operations suggest that Agency should consider a less\nburdensome approach.\u201d<\/p>\n\n\n\n
NBAA actively engaged with the FAA on this topic over a\ndecade ago, participating in the Aviation Rulemaking Committee (ARC)\ncommissioned to reach industry consensus on several key topics related to the\nPRD. NBAA is disappointed that the FAA failed to include many of the ARC\u2019s\nrecommendations in this NPRM, which took the FAA nine years to draft.<\/p>\n\n\n\n
Additionally, NBAA highlighted and responded to more than 20\ntechnical questions or requests for information from the FAA, which suggests\nthat the agency itself was uncertain of the true impact of the proposed rules.<\/p>\n\n\n\n
\u201cThe NPRM lacks a robust analysis of the effects of this\nproposal on Part 91 operations and ignores many consensus recommendations from\nthe 2011 PRD ARC, resulting in a significant burden on numerous small entities\nwith no clear nexus to Part 121 air carrier hiring,\u201d said Brown.<\/p>\n\n\n\n
Among other recommendations, NBAA is urging the FAA to issue\na Supplemental NPRM reflecting the hundreds of comments already received in the\npublic docket prior to finalizing any elements of this proposal.<\/p>\n","protected":false},"excerpt":{"rendered":"
The National Business Aviation Association (NBAA) today voiced significant concerns about the Federal Aviation Administration\u2019s (FAA\u2019s) recent Pilot Records Database (PRD) Notice of Proposed Rulemaking (NPRM), outlining numerous specific challenges with the proposal, and offering recommendations for more appropriately implementing the PRD. NBAA\u2019s comments, submitted to the public docket, join submissions by hundreds of individuals […]<\/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-15860","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\/15860","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=15860"}],"version-history":[{"count":2,"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/posts\/15860\/revisions"}],"predecessor-version":[{"id":15863,"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/posts\/15860\/revisions\/15863"}],"wp:attachment":[{"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/media?parent=15860"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/categories?post=15860"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/stateaviationjournal.com\/index.php\/wp-json\/wp\/v2\/tags?post=15860"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}