AN ACR SO CITES EXCESSIVE PAPERWORK AS A SAFETY HAZARD AND DISTR.

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THE AIR FREIGHT OP BASED IN IND IS AN OVERNIGHT DELIVERY HUB AND SPOKE OP BASED ON ANOTHER ACR'S CONCEPT. THE GOV HAS STRINGENT REQUIREMENTS FOR ON-TIME PERFORMANCE; BOTH IN DEPS AND ARRS. HVY FINES ARE IMPOSED ON THE CONTRACT ACRS FOR A WIDE VARIETY OF 'VIOLATIONS;' MANY OF THEM CUMULATIVE PER INCIDENT. THE PRESSURE ON THE FLT AND GND CREWS IS ENORMOUS TO CUT CORNERS; RUSH CHKLISTS; AND DO NONSTANDARD PROCS. THE PAPERWORK REQUIRED AND LOGGING OF DATA FAR EXCESS THAT REQUIRED BY THE SUPPLEMENTAL ACR'S NORMAL OPS. MOST OF THIS DATA IS NOT REQUIRED FOR NORMAL FLT OPS BUT DOES PUT UNDUE BURDEN ON THE FE DURING THE COURSE OF HIS NORMAL DUTIES. (IN OTHER WORDS; THE GOV HAS MADE A SECRETARY OUT OF A FLT CREW MEMBER). THE INTENT OF FAR 121.542 IS STRETCHED ON EVERY DEP AND LNDG (ALMOST 100 TIMES/NIGHT -- 6 DAYS/WK). OUR COMPANY IS NOT GOING TO DO ANYTHING AS LONG AS THERE ARE NOT FAA COMPANY VIOLATIONS; INCIDENTS OR ACCIDENTS. I HATE TO SEE A CREW MEMBER BE VIOLATED BY THE FAA (ESPECIALLY ME) AND DEFINITELY HOPE THERE ARE NO INCIDENTS OR ACCIDENTS RELATED TO THIS UNDUE WORKLOAD BURDEN.