Petition for Exemption; Summary: NetJets Aviation, Inc.

The NetJets Association of Shared Aircraft Pilots (NJASAP) opposes NetJets Aviation, Inc.'s petition for exemption from flight and duty-time limitations. They argue that the petitioner has failed to demonstrate an equivalent level of safety, specifically citing concerns over the adequacy of onboard rest facilities and the lack of validation for the biomathematical fatigue models used.

The National Business Aviation Association (NBAA) supports NetJets Aviation's petition for a limited exemption from flight duty limitations. They argue that the proposal is narrowly tailored, utilizes modern fatigue science and robust safety mitigations, and maintains an equivalent level of safety while improving operational efficiency.

The International Brotherhood of Teamsters, Local 284, representing NetJets flight attendants, opposes the proposed exemption. They cite safety concerns regarding pilot fatigue and rest opportunities, aligning their position with the labor union representing the pilots.

The Private Aviation Safety Alliance (PASA), a nonprofit consumer advocacy organization, opposes NetJets' petition for an individualized exemption from fatigue-related flight and duty limits. They argue that any changes to these regulations should be made through transparent, generally applicable rulemaking rather than bespoke operator-specific carve-outs, and they urge the FAA to require the disclosure of any safety-enhancing data to benefit the broader industry.

The commenter opposes NetJets Aviation, Inc.'s petition for exemption from flight-deck duty and time-aloft limits, arguing that the requested relief is broader than the aircraft's actual range capabilities. They suggest that if the FAA grants any relief, it should be strictly limited to single, continuous flight segments to ensure crew fatigue protections are maintained for multi-leg operations.

A commercial airline captain expresses concern that extending allowable duty periods for ultra-long-haul flights will increase safety risks due to crew fatigue. The commenter argues that the cumulative effect of extended duty periods leads to a rapid decline in alertness and suggests that any exemption should include safeguards like prohibiting repositioning flights for the same crew.

A NetJets crew member opposes the proposed exemption, arguing that it would be used by the company to allow pilots to fly the aircraft for extended periods (up to 17 hours) without adequate rest. The commenter expresses concerns about pilot fatigue and suggests that the company should instead adjust schedules to accommodate these flights within standard duty time limits.

A flight attendant expresses opposition to the proposed exemption, arguing that it extends duty periods without providing adequate rest or recognition for flight crew. The commenter highlights concerns regarding the lack of dedicated rest areas and the potential for exploitative labor practices by the company.

A NetJets captain who has operated augmented flight crews for many years opposes the proposed exemption, arguing that it lacks an equivalent level of safety. The commenter cites specific concerns regarding crewmember fatigue, inadequate rest facilities, insufficient data on biomathematical models, and the use of duty time extensions for economic reasons rather than safety.