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.

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.

The commenter questions the safety and regulatory compliance of the crew rest area in the Bombardier 8000/7500 aircraft. They argue that the current configuration fails to meet Level 1 requirements and express concern that allowing its use under 135 regulations could compromise safety.

The commenter argues that the proposed exemption poses a significant safety risk because the aircraft's rest areas are inadequate for crew recovery during long duty days. They contend that current rest rules should be strengthened rather than relaxed to prevent accidents in increasingly busy airspace.

A crewmember on a Global 7500 argues that the current crew rest areas are inadequate for long-duration flights due to noise and lack of comfort. They oppose the proposed self-attestation for non-fatigue, arguing that mission pressure and financial incentives will lead to dishonest reporting.