Comment from Corey Smith
Corey SmithOpposeIndividual
Summary: The commenter argues that the proposed exemption poses a significant safety risk because the aircraft's rest areas are inadequate for crew recovery during long duty days. They contend that current rest rules should be strengthened rather than relaxed to prevent accidents in increasingly busy airspace.
Crews are already overwhelmed and tired; transiting multiple time zones, inadequate rest areas, complex airspace, commercial travel, long duty days, minimum rest. This is a recipe for disaster. The rest areas on these airplanes (globals) are inadequate at best, its noisy, uncomfortable, and inadequate… Crews are not resting when in rest; they’re simply isolated, and not from the noise. Operators knew the capabilities of this plane prior to purchasing. It is not a large wide body plane with adequate crew rest areas, these planes are built for passenger convenience and comfort, not crew. It is an accident waiting to happen; currently rules are inadequate, and need to be bolstered, not relaxed. Do not approve this request. If allowed, then what will stop other operators for requesting exemptions from Part 135 rest rules; which many operators blatantly violate, by doing rolling rest and allow reposition under part 91. Airspaces are getting busier, crews are working harder, and longer; mistakes and incidents are up… What is the FAA waiting on to act.