I was actually more referring to the "operating certificate holder must supply" part. There is no operating certificate under part 91.
However reading the actual NFRM, it seems that the intent is that a part 91 operator would be his/her own operating certificate holder. Wish they made that explicit in the rule though.
Never mind, I'm incorrect about this. It looks like the removed the "Updating databases" from the list of preventative maintenance in Appendix A as well, so now it's not considered preventative maintenance at all.
Are we sure that this actually applies to part 91?
(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 you're part 91, there is no "holder of operating certificates" for the operation, and thus. Can that part of the requirement be met under part 91?
I think the major applicability of this is that pilots can update GPSs under part 135 and 121, instead of MX.