Comment from Russ Klawitter

I concur for the rule change to 61.159 as mentioned. Another reason to add to some of the comments: USAF and USN WSOs and NFOs are required to keep a currency on emergency procedures, Instrument and qualification procedures. This is similar to a biennial flight review required by the FAA on most ratings. This military regulation, specific to aircraft (11-2F15E) requires aircrew (Pilots and WSOs) to keep the same 11-202 volume 3 (VFR regulations) and 11-217 (IFR regulations) written currency (testing) and practical exams as pilots for the safety of the airplane and coordination of the aircrew. This level of testing and check ride preparation and execution is intense and similar to FAA check rides and biennial flight review requirements. The air sense, CRM and flying practical application for WSOs and NFOs is invaluable and will add to any flight deck crew under Part 91, 135 or 121 flying. WSOs and NFOs also complete preflight planning, inflight execution of departures, replanning these procedures in the case of need for an alternate, transition between IFR and VFR flight plans, and also back up the pilot on any instrument and visual approach for landing. Conclusion: The WSO and NFO aircrew are held to the same testing standards as pilots for knowledge and practical application of the important FAR and AIM regulations as FAA pilots. References for military currency: https://static.e-publishing.af.mil/production/1/af_a3/publication/afman11-2f-15v2/afman11-2f-15v2.pdf https://www.columbus.af.mil/Portals/39/afman11-217.pdf https://static.e-publishing.af.mil/production/1/af_a3/publication/afman11-202v3/afman11-202v3.pdf