Comment from Anonymous
Anonymous AnonymousSupportIndividual
Summary: The commenter supports the proposed rule change but argues that the current proposal is overly complicated regarding how credit time is calculated. They advocate for a simplified rule that grants up to 750 hours of credit at a 1:3 ratio for rated Nav/CSO/WSO/EWO personnel who hold a commercial certificate with an instrument rating.
This rule change is long overdue...but, the actual proposal is too complicated with who gets to credit time and how much time based on number of seats, where you sit, and airframe. These factors show the original petitioner is unfamiliar with the duties of Nav/CSO/WSO/EWO in all but their own airframe(s). I went to navigator school and have been a navigator, a CSO, and a WSO...all in the same type of aircraft without a change in seats or duties; just a change in what the USAF called me. I was responsible for navigation, ATC communications, weather avoidance, traffic separation, procedural control of other aircraft, etc...A lot of this I did from outside the cockpit in specialized aircraft. Maybe I should be able to count all this as actual instrument time since that is what I was using. Where I sat outside the cockpit also gave physical control of the aircraft to the navigator seat (course and altitude). It also should not matter when I got my commercial certificate or instrument rating so long as I have them. The experience gained with my military time did not become more valuable because of those certificates and rating. This should be simple. If you are a rated Navigator/Combat Systems Officer/Weapons Systems Officer/Electronic Warfare Officer who holds a commercial pilot certificate with an instrument rating you should be credited with up to 750 hours at a 1:3 ratio. Make it simple. This rule change is long overdue.