NBAA Pushes Back On FAA Pilot Records Proposal


The NBAA has called on the FAA to abandon trying to define “gateway operators” in a way that would include many Part 91 operations in an expanded electronic records-keeping program. In rebutting the FAA Notice of Proposed Rulemaking (whose comments closed yesterday), NBAA says that “The FAA’s proposed PRD [Pilot Records Database] would create substantial new pilot data recordkeeping and reporting requirements for a large portion of the business aviation community that is not currently subject to similar reporting obligations. The proposed rules would expand data-collection mandates outlined in the Pilot Records Improvement Act (PRIA), which was enacted in 1997 to establish requirements for air carriers to conduct pilot background checks during the hiring process.” NBAA believes that the FAA’s attempt to define “corporate flight departments” as “gateway operators,” whose pilots are likely to move on to airline jobs, is incorrect and “lacks any Congressional direction.” (Read the full response here.)

“NBAA is concerned that the safety and public interests analysis conducted in support of this proposal do not suggest a need to expand these reporting requirements to Part 91 operations,” said NBAA Chief Operating Officer Steve Brown. “Further, the arbitrary need to define a ‘corporate flight department’ and the lack of any clear safety benefits of this proposal attributable to Part 91 operations suggest that Agency should consider a less burdensome approach.”

NBAA is also concerned that “instructor and check airman notes regarding a pilot’s training” need to be included in the PRD and that could lead impinge safety. “Including these subjective notes turns training and checking into punitive events that could discourage pilots from seeking additional training and therefore negatively impact safety,” the association said. It regards the expansion as “regulatory creep” on the FAA’s part.

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  1. The term “gateway operators” is frankly offensive to me and no doubt to most of my former corporate pilot colleagues. Very few of us in my circles ever aimed for the airlines. To say that we were proud to be safe, successful self-regulating professionals in what is a relatively unregulated discipline is an understatement. Conceited might better describe some colleagues’ attitudes with respect to the corporate pilot discipline over that of the average winged bus driver. The FAA would do well to not fix what ain’t broke and attend to that which is – their own agency for starters.

    • Agreed John K. There are many like myself who fulfill important roles in aviation commerce that do not see a path to the “big iron”. We, daily, perform safe and efficient operations to our various clients whether it be part 91 or corporate. We enjoy this safe flying-style and in no way see ourselves as “gateway operators”. The term, in this context is almost pejorative as if we are a step to a “real world” of aviation. At least that is how I interpreted the NPRM.

  2. I totally agree with both commenters. The aircraft management company I fly for wants pilots who will stick around, not be a stepping stone for those looking for airline jobs. And what about other Pt91 “work” operations? Do drop zones, pipeline patrol, photography, traffic report, even independent pt61 flight instruction have to comply with this crazy proposed rule? Another worthless bureaucratic rule made up by bureaucrats in the FAA with nothing better to do than come up with more ways to justify their jobs! I also agree with NBAA on instructor and check airman comments. When a check airman does a check ride, the candidate either meets the standard or does not, there is no in between. Making comments public serves no purpose and exposes that check airman or company to more liability in the event of an accident.

  3. Simple Conclusion; Mind boggling.

    Extended Conclusion; NBAA PRD NPRM Comments

    NBAA recognizes the PRD has the potential to streamline and enhance the current PRIA
    process. However, the current proposed rule exemplifies regulatory overreach, going far
    beyond the intent of the legislative mandate with no identifiable safety benefits for Part 91
    operators. The NPRM lacks a robust analysis of the effects on Part 91 operations and ignores
    many consensus recommendations from the 2011 PRD ARC, resulting in a significant burden on
    numerous small entities with no clear nexus to Part 121 carrier hiring. Many of the
    shortcomings in the NPRM can be rectified by removing requirements for Part 91 operators to
    contribute information to the database.
    In light of these comments and the other several hundred public comments submitted to the
    docket, NBAA encourages the FAA to consider this proposal as an Advanced NPRM and publish
    a Supplemental NPRM with all public comments carefully weighed.
    NBAA appreciates the FAA’s consideration of these comments. We look forward to continuing
    to work with the FAA towards our shared goal of enhancing safety.
    Steve Brown
    Chief Operating Officer

    Agree. Good luck!