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!