Comment from Anonymous

I am writing to comment on the petition by NetJets Aviation, Inc. for exemption from 14 CFR 135.269(b)(2), 135.269(b)(3), and 135.269(b)(4) for BD-700-2A12 operations. I oppose the petition as written, and I urge the FAA to deny it unless any grant is expressly conditioned on the relief applying only to a single, continuous flight segment (leg). The petition's entire justification rests on the aircraft's range - its ability to complete missions "up to the maximum endurance of the aircraft of between 16 and 17 hours." Range is, by definition, a single-leg capability: it describes how far an aircraft can fly without stopping to refuel, and it is the one thing an ultra-long-range aircraft can do that a shorter-range aircraft cannot. A multi-leg mission totaling the same 16 to 17 hours requires no exceptional range at all. It can be flown today by aircraft with a fraction of the BD-700-2A12's endurance simply by refueling between legs, using the three- and four-pilot crew complements that the existing rule already permits (up to 20 duty hours and 16 hours aloft for a four-pilot crew). As written, however, the requested relief is not tied to a single leg. It would raise the flight-deck-duty, duty-hour, and time-aloft ceilings for any qualifying operation with four pilots assigned - including duty periods made up of multiple shorter legs that have nothing to do with the aircraft's range. That is a mismatch between the justification offered and the relief requested. The FAA should not grant relief broader than the rationale that supports it. The distinction matters for safety, not merely for logic. The augmented-crew premise - assigning a third and fourth pilot so crewmembers can rotate into onboard rest - depends on the flight actually containing long, low-workload cruise periods during which off-duty pilots can obtain meaningful in-flight rest. A single ultra-long-range leg provides exactly that. A duty period broken into multiple legs does not. Each leg concentrates the most demanding and fatiguing phases of flight (taxi, takeoff, departure, approach, and landing), inserts non-restful ground time for turnarounds, and shrinks the continuous cruise windows in which relief pilots can actually sleep. The same total hours, distributed across several legs, impose materially greater crew fatigue than a single continuous leg. Extending the limits of 135.269(b) to multi-leg operations would therefore authorize a level of fatigue exposure that the petition never addresses and that the FAA has not evaluated. Accordingly, if the FAA is inclined to grant any relief, I respectfully request that the grant be conditioned on the following limitation: "The relief granted from 14 CFR 135.269(b)(2), 135.269(b)(3), and 135.269(b)(4) applies only to a duty period consisting of a single, continuous flight segment. Any duty period that includes more than one flight segment remains subject to the unmodified limits of 14 CFR 135.269(b)(2), 135.269(b)(3), and 135.269(b)(4)." This condition would align the exemption precisely with the capability and the rationale the petitioner has put forward. It would preserve the existing fatigue protections for every other operation, and it would prevent a range-based justification from being used to obtain extended duty and flight-time limits for multi-leg flying that has no connection to the aircraft's endurance. Thank you for the opportunity to comment.