Comment from Aaron Law
Aaron LawSupportIndividual
Summary: A former military weapons system officer and current airline pilot supports the proposed rule to allow fighter aircraft flight time to count toward the 1,500-hour ATP requirement. The commenter argues that the duties of weapons system officers are of equal or greater difficulty than those of airline pilots and provides specific examples of how the reduction should be calculated.
As a former F/A-18 Weapons System Officer (WSO) and a current Part 121 airline pilot, I can say with confidence that the duties performed by WSOs are of equal or greater difficulty than those performed by the Pilot Monitoring (PM) in an airliner.
This rule would allow the airline industry and the world of professional flying writ large to tap into a wealth of aviation knowledge from experienced aviators whose flight hours have been lumped into the murky category of “special crew time.”
For fighter-qualified aircrew specifically, the ATP hour requirements should be lowered based on flight time accrued in a fighter aircraft. Provided the ATP candidate meets all the other elements of §61.159, their total flight time requirement would be reduced from 1,500 hours by the number of hours they accrued in fighter aircraft, not to exceed 750 hours.
For example:
1) LCDR Smith, an F/A-18F WSO, has logged 3,000 hours of special crew time with 2,850 of those hours in F/A-18s. LCDR Smith’s new ATP total flight time requirement would be 750 hours: 1,500 hours less 750 hours of allowed special crew time.
2) 1st Lt Doe, an F-15E WSO, has logged 600 hours of special crew time with 450 hours in F-15s. Lt Doe’s new ATP flight time requirement would be 1,050 hours: 1,500 hours less the 450 hours logged in a fighter aircraft.
ATP candidates with prior fighter experience would still be required to pass FAA written and practical exams for all certificates and ratings leading up to the ATP as well as meet the aeronautical requirements of §61.159.