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Are pilots allowed to perform FMS database updates under part 135? If so, do they need formal training entered in their pilot records before they are allowed to do it?

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Updating a navigation database used to be considered preventative maintenance and was required to be performed by a mechanic under Part 135. However, the regulations were changed at the end of 2012 (here is the final rule) and it no longer falls under this category so pilots are allowed to update "aeronautical databases" (a new term) if it is "easy" to do (see the regulation quoted below for the exact requirements). There is no training requirement specified by the regulations, however there may be company specific procedures which require it.

14 CFR 43.3 was updated, and now says (in part):

(k) Updates of databases in installed avionics meeting the conditions of this paragraph are not considered maintenance and may be performed by pilots provided:

(1) The database upload is:

(i) Initiated from the flight deck;

(ii) Performed without disassembling the avionics unit; and

(iii) Performed without the use of tools and/or special equipment.

(2) The pilot must comply with the certificate holder's procedures or the manufacturer's instructions.

(3) The holder of operating certificates must make available written procedures consistent with manufacturer's instructions to the pilot that describe how to:

(i) Perform the database update; and

(ii) Determine the status of the data upload.

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  • $\begingroup$ There is a difference in language that various parts of the FAA use. What is described here as updating the database, is elsewhere (AC20-153A) described as loading the database. $\endgroup$ – DeltaLima Jan 24 '14 at 13:33
  • $\begingroup$ @DeltaLima Ummmm, okay....? (Does that change something?) That AC is for people processing aeronautical data (ie creating databases). It was also written in 2010 before the change to the regulations. $\endgroup$ – Lnafziger Jan 24 '14 at 13:44
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I assume that by updating you mean loading a pre-compiled database into the FMS, replacing the old one.

The RNAV database inside the FMS should be updated according to the 28 day Aeronautical Information Regulation and Control (AIRAC) cycle. Typically this is a maintenance task and the pilot has no play in this. Of course if the pilot also holds the required maintenance certificates, then he can update the database in the appropriate way. However, he is not acting in his capacity of pilot in that case, but wearing his maintenance hat.

In some cases the database update is not considered maintenance and can be performed by the pilot. 14 CFR Part 43 covers Maintenance, preventive maintenance, rebuilding and alteration. It contains an interesting section regarding databases; 14 CFR § 43.3(k) specifically addresses database updates.

(k) Updates of databases in installed avionics meeting the conditions of this paragraph are not considered maintenance and may be performed by pilots provided:

(1) The database upload is:

(i) Initiated from the flight deck;

(ii) Performed without disassembling the avionics unit; and

(iii) Performed without the use of tools and/or special equipment.

(2) The pilot must comply with the certificate holder's procedures or the manufacturer's instructions.

(3) The holder of operating certificates must make available written procedures consistent with manufacturer's instructions to the pilot that describe how to:

(i) Perform the database update; and

(ii) Determine the status of the data upload.

If these conditions are not met, then there is a final escape door which might apply to Part 135 rotorcraft pilots:

14 CFR § 43.3(h) states:

(h) Notwithstanding the provisions of paragraph (g) of this section, the Administrator may approve a certificate holder under Part 135 of this chapter, operating rotorcraft in a remote area, to allow a pilot to perform specific preventive maintenance items provided—

(1) The items of preventive maintenance are a result of a known or suspected mechanical difficulty or malfunction that occurred en route to or in a remote area;

(2) The pilot has satisfactorily completed an approved training program and is authorized in writing by the certificate holder for each item of preventive maintenance that the pilot is authorized to perform;

(3) There is no certificated mechanic available to perform preventive maintenance;

(4) The certificate holder has procedures to evaluate the accomplishment of a preventive maintenance item that requires a decision concerning the airworthiness of the rotorcraft; and

(5) The items of preventive maintenance authorized by this section are those listed in paragraph (c) of appendix A of this part.


Summary

When the database update meets the conditions stated in paragraph (k) of 14 CFR § 43.3 it is not considered maintenance and may be performed by the pilot.

When CFR § 43.3 (k) conditions are not met the pilot cannot perform the update unless the Administrator approves it under 14 CFR § 43.3(h).

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