Haven't you heard? They have pilots on furlough, non umion pilots flying their trips, and times are tough. Only ~4 Billion in profit last year. Besides if this went through they would have to mod their 767's to the tune of some 20 million. They would probably go out of business overnight.

You decide, here are some of their comments from the nprm:

"UPS’s typical cargo often includes critically needed medical supplies and pharmaceuticals, and so timely delivery often is, quite literally, a matter of life and death."

"A key attribute and result of this business model is that pilots in the scheduled cargo express industry fly significantly fewer hours per month than their passenger airline peers—a material fact that the FAA has ignored in its proposal. They work fewer hours pursuant to carefully developed work rules and thus are better rested than their peers in the passenger segment."

"As a result of this flexible legal framework, UPS need not base its pilots in foreign cities, a circumstance that would require a reassessment if the proposed rules are adopted."

"Indeed, UPS has already adopted most of the components of the FRMP in the absence of a federal mandate and made enormous investments in sleep facilities at UPS’s regional hubs without any legal requirement to do so."

"Likewise, many of UPS’s long haul aircraft are equipped with high quality lie-flat bunks or substantially reclined rest facilities."

"The proposed regulations failed to account for the substantial costs of increasing pilot reserve staffing to deal with unintended trip drops as crewmembers “time out.” Large increases in the necessary reserve pool will be required due to the inability to reschedule crews, three- consecutive night limit, and the mandatory 14-hour requirement before a reserve pilot may be given another assignment.The increased weekly time off—from 24 hours off in every seven days to either 30 hours or 36 hours off (depending on the theater of operation)—will drive additional staffing. There is also significant expense transporting “deadheading” crews utilizing commercial travel on passenger carriers and paying for hotels and per diem amounts."

"In making this proposal, the FAA is seemingly oblivious to UPS’s existing fatigue-mitigation strategies memorialized in its labor agreements and would effectively penalize UPS for its good-faith efforts."

"the FAA has overstepped its bounds and moved from safety regulation into the realm of labor arbitration."

"Moreover, the rule permits cumulative duty extensions only if crewmembers scheduled to “deadhead” do so in first class, yet another example of the FAA solving a labor management conflict and not a safety problem."

"As proposed, “rest” in Section 117.25 does not start until a crewmember arrives at the hotel or sleep facility, even though his or her arrival time is completely out of the certificate holder’s control in the best of cases and is subject to crew manipulation in the worst of them."

"Treating reserve as if it were flight duty makes no sense. Consider a crew whose members have been sitting at home for five days straight observing a 14-hour on-call period each day. On the sixth day, the company would like to schedule the crew for a two-day trip requiring only 10 hours of total duty with flying entirely during the daytime. That assignment would violate the proposed regulation."

"UPS does not carry paying passengers. The risk of human loss in a fatal accident is thus orders of magnitude lower than the risk inherent in a passenger carrying airline."

"UPS has gone to extraordinary lengths to protect its pilots and other employees."

"Costs associated with increasing the company’s overall block hours to meet the stringent scheduling requirement are extremely high and effectively punitive in nature."

"The 14-hour mandatory rest rule for a reserve has no basis in science, and is simply another example of
rule making driven by collective bargaining influences versus regulating from the use of science."

"The FAA has failed to consider that, as with most collective bargaining agreements, pilot pay at UPS is based on the greater of scheduled or actual flight times. The schedule reliability provision of this new regulation will force UPS to pad its schedules—increasing block time for exactly the same trips. This will add significant costs to the airline’s payroll with absolutely no increase in flying or fatigue mitigation and no public benefit. UPS conservatively estimates the cost of this requirement alone to be approximately $435 million over ten years."