The proposed rule would require owners and/or operators with two or more aircraft that require a type rating and who employ pilots to enter information about their pilots’ currency and backgrounds in the database, for use by air carriers and other entities during the vetting of prospective hires.
The survey was sent to all members of the National Business Aviation Association, and all AOPA members who hold commercial pilot certificates or airline transport pilot certificates, generating 1,219 responses.
The survey data will supplement the associations’ formal comments on the Pilot Records Database plan, which the FAA proposed in March “to facilitate the sharing of pilot records among air carriers and other operators in an electronic data system managed by the FAA.”
On becoming a final rule, the proposal would require “air carriers, specific operators holding out to the public, entities conducting public aircraft operations, air tour operators, fractional ownerships, and corporate flight departments” to enter the mandated data about their pilot employees, making the information electronically accessible. Air carriers and other entities would be required to “evaluate the available data for each pilot candidate prior to making a hiring decision.”
In formal comments filed in June, AOPA concurred with the need for air carriers to have a means to ascertain accurate training records of pilot candidates. But we noted concern that the proposal “expands beyond what is statutorily required, does not accept industry recommendations, and does not provide a clear process for the lifetime of the pilot to have errors on their record corrected.”
The seven-page letter of comments argued for narrowing the range of air service organizations subject to the rule and excluding Part 91 operators—many of whom are sole practitioners with only one or two aircraft—from recordkeeping requirements. AOPA urged the FAA to ensure that all FAA-certificated pilots have free access to their database records, and opined that the agency should consider stakeholders’ comments made “with safety and the future growth of the next generation of pilots and aviation professionals in mind.”
The survey examined data in two pools of respondents, measuring overall pilot sentiment and a group consisting of those with two or more type-rated aircraft.
According to the survey, all respondents were skeptical about the Pilot Records Database plan, noting concerns about added recordkeeping burdens and the possible pitfalls of including comments made by a check pilot on a pilot’s qualification history. Among respondents with two or more type-rated aircraft, 56 percent opposed including check pilot comments in the database; about 20 percent agreed with including the comments.
On recordkeeping changes, respondents estimated that entering data into the electronic database “would add a significant time burden but would not be a significant improvement over the current paper-based reporting system.” Respondents with two or more type-rated aircraft said they expected to spend significantly more time on administrative chores under the plan.
In both groups, few thought the Pilot Records Database would “streamline” the hiring process for pilots and employers. One in three respondents thought the system would improve on the existing paper-based Pilot Records Improvement Act system.
“AOPA strongly believes that the Pilot Records Database must include a clear process for correcting erroneous information, with the FAA responsible for evaluating and correcting inaccuracies if a pilot’s employer is unwilling or unable to do so,” said Murray Huling, AOPA vice president of regulatory affairs. “The need to provide pilots with transparency and convenient access to their records is why we also recommend giving any holder of an FAA-issued pilot certificate the opportunity to inspect their information on file in the database.”
Noting the robust pilot community response to the survey, AOPA and NBAA believe that the research would serve as “an excellent guide to perceptions of flight departments, organizations, and pilots who likely will be required to transition” to the proposed electronic database.