Comment from NetJets Association of Shared Aircraft Pilots (NJASAP)
NetJets Association of Shared Aircraft Pilots (NJASAP)OpposeUnion
Summary: 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.
NJASAP respectfully submits these supplemental comments to provide additional information and analysis following its original submission in Docket No. FAA-2026-3840. These comments supplement, and do not replace or supersede, NJASAP’s original filing.