Comment from Anonymous

I am a pilot at NetJets, where I have flown for nearly two decades. Prior to that, I flew for private companies and taught flight students at a local flight school. I have experience in a variety of jets and regularly fly tours with 4-6 legs per day and 10-11 hours of rest afterward. Until the past couple of years, I was never a person to file ASAP reports, call in fatigued, or grumble about my job. But in the past couple of years I have forced myself to file safety reports and to take the rest time that I need with more frequency. I have always respected the NetJets pilots union (NJASAP) but never involved myself in the politics because I find it more of a hindrance to my desire to do my job and to do it safely. That said, I have to agree with some of the comments left by NJASAP and other pilots on the matter of the duty and rest regulations exemption filed here. Over the past couple of years the workload that NetJets pilots have been asked to endure has grown larger and larger. We are asked to work longer days and to fly more legs than ever before. The attitude of never saying no to our clients has reached the point that pilots are asked not only to fly planes but also to act as babysitter to underage passengers, deal with biting dogs, carry disabled passengers up and down the aircraft stairway, and clean up the feces and vomit left by drunken passengers. When we ask for a couple of extra hours of rest beyond the minimum 10 that the schedulers give us, we are harassed by the schedulers, their bosses, and even the chief pilot and his assistants. We are rarely consulted on changes to company policies, and in all my asking around, I haven't been able to find any pilots who were consulted about the exemption for the Global 8000. I have found a lot of resentment among pilots because of it. Unfortunately, most pilots don't want to stir the waters. They shrug it off as typical company action that we have no control over and add it to their list of complaints that they keep to themselves. Before I could come anywhere near being in favor of the type of change to the rules that Mr. Kennedy is asking for here, I would like to see changes made to problems that already exist. This exemption will lead to problems that I am sure company leaders have not yet imagined. So they need to address the problems that already exist before creating situations that will lead to additional problems. Another issue that see with this exemption is the appearance of favoritism. There already exists at NetJets the idea that, because we are the big and powerful company that we are, the FAA will do whatever we ask of them. We already have the ability to create our own approaches into difficult airports, which is great for us and gets us into places that others can't reach. But having a group of pilot specialists who can work with the FAA to create custom made approaches is not the same as bending the rules or getting an exception to the rules for no other reason than to use a specific type of aircraft that we have already bought. As others have already pointed out, a request for this type of exemption should actually point out a hole in the current regulations or a need for the regulations to be updated. The exemption itself should not be granted. In the world of aviation today, technology allows us to get into and out of places we used to never get into at all. It allows aircraft to fly faster and longer distances. As technology changes, the rules should as well. We should not get into the habit of asking for exemptions, which could set a dangerous precedent. Give it to us this time, and who knows what we will ask for next time, precisely because we are NetJets and expect to get what we ask for. The same goes for other air carriers. This issue should be resolved through the normal rulemaking process. We already own Global 8000s. So why wasn't this process resolved well before we took possession of those aircraft? Is this request for an exemption a last minute attempt to save face and start using the aircraft for those long flights that we can't perform without the exemption? It seems to me that the proper process of changing the duty and rest rules should have gotten started a couple of years ago. It should have been going on at the same time as the negotiations with Bombardier to design the aircraft. At face value, this looks like NetJets leaders ignoring the rules in order to make a buck. Safety of flight at NetJets over the past couple of years has been slipping. Our colleagues at home who go to the monthly safety meetings have been telling us about how much the daily duty period has increased and how much our rest periods have decreased. Why? So NetJets can make a buck. NetJets leaders talk safety all day, but in practice everyone knows that safety comes first only if it doesn’t get in the way of operations. FAA -- do not let safety become a slave to the almighty dollar. That's what will happen if this exemption is approved.