NetJets Aviation, Inc - Exemption/Rulemaking

The Air Line Pilots Association (ALPA), representing over 80,000 pilots, opposes NetJets Aviation's petition to extend maximum pilot work hours. They argue that the petition fails to demonstrate an equivalent level of safety because it lacks necessary fatigue mitigations, data-driven monitoring, and validated rest facility standards.

The NetJets Association of Shared Aircraft Pilots (NJASAP), a labor advocate representing NetJets pilots, opposes the proposed exemption because it establishes a repeatable operational capability that exceeds current Part 135 flight and duty time limits. They argue that the proposal lacks a measurable safety framework, fails to adequately address fatigue risk during disruptions, and should be addressed through formal rulemaking rather than a limited exemption.

A current NetJets pilot with over 34 years of experience supports the proposed action but suggests specific improvements to the implementation. The commenter recommends addressing augmented crew rules, improving crew rest facilities (such as mattresses and earplugs), and better accounting for circadian rhythms and the international dateline.

Bombardier, the aircraft manufacturer, provides a statement in support of NetJets' request for a crew duty time and flight time exemption for the BD-700-2A12 aircraft. They argue that the aircraft was specifically designed and certified for ultra-long-range operations and includes modern fatigue-mitigation features that support such missions.