In May 1996, the FAA classification of the navigational database update process as preventative maintenance occurred with the issuance of a final rule. At that time, the majority of navigational databases required removal of the unit from the instrument panel and, in some cases, disassembly of the unit itself. It was the intent of this final rule to adapt federal regulations to the current state of modern technology. As a result of the 1996 revisions, the FAA classified the update process as preventative maintenance allowing, by way of 14 CFR 43.3(g), pilots in a Part 91 environment to perform the database update process. However, pilots operating aircraft under Part 135 were prohibited from performing these updates.
Today, the navigational database update process, due to technological advances, has changed from a complex procedure occasionally requiring parts removal and/or disassembly to a more user-friendly, plug-and-play type of process. In an attempt to account for the simplicity provided by these modern navigational databases, several of NATA’s Part 135 on-demand charter members have petitioned the FAA for an exemption from 14 CFR 43.3(g) as it relates to 14 CFR 43 Appendix A (c)(32). These petitions are based upon the economic hardship and safety concerns that arise from scheduling aircraft to be at locations where adequate maintenance facilities are available. The primary issue NATA seeks to resolve is the classification of navigational database updates as “preventative maintenance.”
NATA submitted a letter to the FAA’s Flight Standards Service, asking the FAA to review the rule and its exemption process. A copy of this letter may be viewed here.
If you have questions, please contact NATA Manager of Regulatory Affairs Dennis Van de Laar.