Comment from Anonymous

I’m a Captain on the Global 7500/8000 fleet. With respect to the proposed exemption to extend allowable duty periods, I have some concerns. The main concern most crews who conduct these flights share is the extended duty period after an ultra-long-haul segment. While an additional hour of flight time may appear insignificant when viewed in isolation, the cumulative effect of an already extended duty period is the primary safety concern. Crew rest during these types of operations rarely results in continuous, restorative sleep. In practice, most crewmembers are fortunate to obtain only a limited period of quality rest. After completing one of these segments, the heightened concentration required during the approach and landing phase is often followed by a rapid decline in alertness as fatigue becomes more pronounced. It is very common for these operations to be followed by a repositioning flight with the same crew (due to parking restrictions s etc). In my opinion this represents an unnecessary increase in operational risk, particularly when the entire crew may have obtained only a few hours of fragmented sleep over the preceding 24-hour period. If this exemption is granted, I strongly encourage that appropriate safeguards accompany it. At a minimum, consideration should be given to prohibiting repositioning flights by the same flight crew following an extended-duty operation. Such a safeguard would help mitigate fatigue-related risks while preserving the intended operational flexibility of the exemption. The primary objective should remain maintaining an acceptable margin of safety rather than simply increasing operational capability.