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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.

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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.

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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.

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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.
Sincerely,
Steve Brown
Chief Operating Officer

Agree. Good luck!