Comment from Netjets Association of Shared Aircraft Pilots (NJASAP)

Summary: 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.