...This is in response to your request for an interpretation regarding adequate sleeping facilities as prescribed by 14 C.F.R. §135.269(b)(5)...The FAA has consistently interpreted the phrase "adequate sleeping facilities on the aircraft" as generally meaning a bunk or berth, but not a reclining seat...Advisory Circular 121-31 (Sept. 30, 1994) contains the current guidance on this subject...
FAA Chief Counsel's Opinion