Anonymous

Document ID: FAA-2011-0763-0003
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: October 19 2011, at 12:00 AM Eastern Daylight Time
Date Posted: October 20 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: October 19 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: December 19 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80f5631d
View Document:

This is comment on Proposed Rule

Pilot Loading of Navigation and Terrain Awareness Database Updates

View Comment

Although I feel this is a good rule the implementation is incorrect. So we have removed (c) 32 from part 43 from preventive maintenance but created a new sub-type of maintenance? The proposed rule 43.3 (k) is under the chapter Persons authorized to perform maintenance, preventive maintenance ,rebuilding and alterations. What is the FAA considering loading databases? A better spot to place this activity would be in the applicable parts (ie 121,125,133, 135) under the approved pilot training program. This would allow pilots to be training in this preflight duty and the GOM would state how this is to be recorded. Placing this under 43 is confusing since this activity is not now considered not to be maintenance, preventive maintenance ,rebuilding and alterations.