FAA Proposal Will Allow Part 135 Operators to Upgrade Nav Databases

The FAA proposes to amend the maintenance regulations by removing from the preventive maintenance category the task of updating databases used in self-contained, front-panel or pedestal-mounted navigation equipment. This change would allow pilots who operate certificated aircraft to update the specified databases and eliminate the requirement for certificated mechanics or repair stations to perform the update. (NPRM)

Paragraph (c)(32) from Part 43, Appendix A, Preventive Maintenance, currently lists "Updating self-contained, front instrument panel-mounted Air Traffic Control navigational software databases (excluding those of automatic flight control systems, transponders and microwave frequency distance measuring equipment) provided no disassembly of the unit is required and pertinent instructions are provided" as a preventive maintenance task.

Section 43.3 (g) allows the holder of a pilot certificate to perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under Part 121, 129 or 135 operations.

Currently a pilot for an aircraft operated under Part 135 cannot perform ATC Nav Database updates.  The proposal will change the regulations by first, removing ATC Nav Databases from the list of authorized preventive tasks apparently making them a maintenance task, and then allowing any pilot to perform this new maintenance task by adding this new paragraph to Section 43.3.

(k) The holder of a pilot certificate issued under Part 61 of this chapter may perform updating of self-contained, front-instrument panel-mounted and pedestal-mounted air traffic control navigational system databases (excluding those of automatic flight control systems, transponders, and microwave frequency distance measuring equipment, and any updates that affect system operating software) provided:

  1. No disassembly of the unit is required.
  2. The pilot has written procedures available to perform and evaluate the accomplishment of the task.
  3. The database is contained in a field-loadable configuration and imaged on a medium, such as a compact disc read-only memory (CD-ROM), synchronous dynamic random-access memory (SDRAM), or other non- volatile memory that contains database files that are non-corruptible upon loading, and where integrity of the load can be assured and verified by the pilot upon completing the loading sequences.
  4. Records of when such database uploads have occurred, the revision number of the software, and who performed the upload must be maintained.
  5. The data to be uploaded must not contain system operating software revisions.


The AEA has been working with the FAA for more than a year on this issue. Based on the recommendations of the AEA Government & Industry Affairs committee, the AEA has been supportive of the FAA's efforts to remove the restriction placed on Part 135 pilots.

Contact Ric Peri, AEA vice president of government and industry affairs, by email at ricp@aea.net or by phone at 202-589-1144.