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For those of us flying in business aviation, it has become clear that rest and flight time limitations and the growing pressure of increasingly demanding rosters, are becoming more and more problematic. Pilots routinely face long duty days, extended rotations, minimal rest, and numerous last-minute changes. Often our schedules are already planned close to the limits of the existing regulations. 

Several years ago, EASA made a proposal – known as NPA 2017-17 – which aimed to improve the framework by introducing more protective and harmonised rules across Europe. While far from perfect, it addressed key fatigue-related issues and showed potential for being further developed into a new robust FTL framework. However, that proposal is now off the table and has been replaced by a new one: NPA 2024-106(B).


This latest proposal was tabled last autumn for a ‘focused’ stakeholder consultation, held without any (!) pilot representation. Instead, it was significantly influenced by business aviation operators, resulting in a worrying lack of safety mitigations.


The revised proposal also removes some critical safety mitigations which had been proposed back in 2017, while it heavily prioritises operational flexibility, often at the expense of crew wellbeing and – crucially – aviation safety.


Some of the most unsettling changes include:

  • Removal of the limit of 110 duty hours in 14 days, proposed in NPA 2017-17 to help manage long ON/OFF rotations.
  • Increase of the current limit of 60 duty hours in 7 days to 70 hours, if up to 10 of those hours are used for positioning – potentially after an exhausting 14-hour duty across multiple time zones, you might be schedule to proceed home, and maybe even in economy class.
  • On-ground breaks while remaining on board could soon be counted as rest.
  • Augmented flight operations still do not account for cabin crew rest, meaning that if the operator assigns rest to non-certified flight attendants, pilots may lose their own rest period, as most business jets have only one sleeping position.
  • In-flight rest while augmented, previously mandated at minimum 3 hours, may now shrink to only half: 1 hour 30 minutes.
  • Quite surprisingly, the earlier requirement – proposed back in 2017 – for three local nights of rest following extended or heavy duty has been scrapped entirely! 


Perhaps, most concerning, under the new proposal, pilots could legally operate four sectors with an extended duty of up to 14 hours, with an additional 2 hours under Captain's Discretion?


That means, realistically, business aviation pilots could face 16-hour duties without augmented crew support. And all this in *Business Aviation*, where unforeseen circumstances are not uncommon, so this scenario may quickly become more than just theoretical.


Many business aviation pilots are already flying 600 to 700 hours a year, often with long positioning duties added on top. Unlike scheduled operations, Business Aviation frequently involves even more unpredictable delays, last-minute changes, and operational challenges that significantly affect rest and recovery.


We can only question the rationale behind those changes: is it operational flexibility, is it commercial convenience or is it safety-driven? This is not a call to protest. It's a call to be informed.


Being informed is even more important, because EASA had decided to limit its ‘focused’ consultation to recognised stakeholder organisations only, instead of making it a public consultation. That means that individual Business Aviation pilots did not get the opportunity to study the new rules and to submit comments based on their daily operational experience and safety perspective. 


Thankfully, the European Cockpit Association, representing airline and business aviation pilots, has submitted detailed critiques highlighting significant safety shortcomings, procedural flaws, and the troubling reduction of previously proposed safety mitigations – while at the same time offering substantial flexibilities to the operators. It now falls on EASA, as a responsible safety authority, to reassess this proposal urgently.