Skipping a Broken Record—Temporarily, At Least

In August, 2021, the FAA mandated the establishment of an electronic Pilot Records Database (PRD) and implemented statutory requirements to facilitate the sharing of pilot records among air-carriers and other operators in an electronic data system managed by the agency.

The measure requires air-carriers, air tour operators, fractional ownerships, and corporate flight departments to not only enter data on their pilots into the database, but to access the thing for purpose of evaluating the available data pertaining to any pilots they seek to hire.

The database instantiates governmental meddling in matters best left to the judgement and insight of qualified and experienced chief pilots and flight department managers.

The NBAA, however, has successfully petitioned the FAA for limited relief from the requirement to begin reporting pilot records created on or after 10 June to the Pilot Records Database within 30 days of the effective date of the record.

Exemption No. 19176 applies to NBAA member companies conducting Part 135 operations that hold OpSpec A025 for electronic training records and members operating under Part 91(k) that hold MSpec MA025 for electronic training records. The FAA denied NBAA’s petition for relief for Part 125 operators.

The NBAA requested relief because the relevant Notice of Proposed Rule-making (NPRM) forecasted that the FAA would provide two methods of data entry into the PRD: (1) an electronic transmission method using an automated utility and (2) a manual entry method for operators with fewer records or without the technology required to make an electronic transfer. The electronic transmission method is not expected to be ready until late 2022.

The exemption is only from the reporting requirements outlined in 14 CFR § 11.215(a) and expires 10 January 2023.

Qualifying entities must submit a Letter of Intent to the Federal eRulemaking Portal through the comment process, under Docket No. FAA-2022-0795. The letter of intent must state the certificate holder’s or operator’s intention to exercise the relief granted in the exemption and affirm the intention to comply with all of its conditions and limitations.

Records created 10 June through 10 January 2023, must be reported to the Pilot Records Database by 12 June 2023.

Brian Koester, CAM, NBAA’s director of flight operations and regulations states: “NBAA supports the overall philosophy behind the PRD, and we appreciate the FAA’s ongoing progress to develop PRD solutions. However, for large operators, manual submission of these records is unreasonable and defeats the purpose of the database. We will continue to work closely with the FAA and operators to expeditiously implement the electronic transmission method once it becomes available.”

In the meantime, Part 135 operators and 91(K) program managers are advised to continue maintaining records in accordance with their A025 or MA025 requirements.

FMI: www.federalregister.gov/documents/2021/06/10/2021-11424/pilot-records-database