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The NBAA says that the FAA's consideration of public feedback, including hundreds of comments submitted by the business aviation community, has been critical to key improvements in the agency's final rule on its electronic Pilot Records Database (PRD).
First introduced in 2020, and mandated by Congress, the PRD Notice of Proposed Rulemaking suggested new mandates for certain Part 91 operators, with the intent to improve safety by changing the hiring process for air carriers.
During a targeted advocacy effort, NBAA and its members expressed concerns over how elements of the proposed PRD would apply to business aviation, including the agency's focus on establishing a single and possibly precedent-setting definition for the term ‘corporate flight department’ in all uses across the agency's regulatory guidance. That move would side-step the reality that business aviation is a diverse industry, made up of a variety of operational types, possibly ushering in a host of unintended consequences for the sector.
The final rule, published 26 May, takes industry's concerns into account. It eliminates the single corporate flight department definition; returns consistency to the term ‘aeronautical experience’; and now exempts a significant portion of the business aviation community from most other onerous reporting requirements.
NBAA president and CEO Ed Bolen says: “This final rule reflects a more risk-based approach to safety and demonstrates that our community effectively made its voice heard during the rulemaking process. We appreciate the FAA's careful review of the hundreds of comments submitted by NBAA members. The business aviation community stands for safety, and working together we have determined the best way to address the agency's aims, without introducing needless reporting requirements that do not have a clear safety benefit.”
Bolen noted that NBAA is conducting a detailed analysis of the final rule and will soon provide additional resources to its members.