AOPA raised concerns over the FAA’s proposal of an electronic database intended to replace the longstanding Pilot Records Improvement Act (PRIA) for air carriers and to verify certification, training, and currency of pilots. AOPA and other aviation organizations believe that the Pilot Records Database (PRD) described in a notice of proposed rulemaking will place an undue burden on many individual pilots.
Though pilot record databases like PRIA have been around since the 1990s, it was the tragic Colgan Air Crash in 2009 that prompted the FAA to make changes in its training requirements and pilot records. After more than a decade in the works, the PRD was published for comment in March, giving AOPA and industry stakeholders 90 days to respond.
Chief among AOPA’s complaints is that the PRD NPRM expands beyond what is statutorily required, does not accept industry recommendations, and does not provide a clear process for pilots to have errors on their record corrected.
Additionally, thousands of small, sole-practitioner operations under Part 91 (e.g., small corporate and air tour operators) would be subjected to costly and burdensome regulations, setting a bad precedent for interpreting the PRD to apply to a broader group of small operations. According to AOPA’s comments, “The result would [be] unnecessary self-reporting to the PRD. Similarly, having PRD reporting for other part 91 operations, such as aerial advertising and photographers, pipeline patrol, glider operations, banner towers, agriculture operations, and acrobatic teams should not be included due to their size and type of operation and not being mandated by the PRD Act.”
“While AOPA supports the need for a transparent process to ensure accurate pilot records, this proposal unfortunately attempts to mandate a costly process to smaller Part 91 operations that we strongly believe were not intended to comply,” said AOPA Director of Regulatory Affairs Chris Cooper. “Again, the FAA proposal places unnecessary requirements on Part 91 operators that would do nothing to enhance safety.”
Along with AOPA, several other aviation organizations and pilots have spoken out against the proposed rulemaking.