Comment from Timothy Tendall

Timothy TendallSupportIndividual
Summary: Matthew T. Keefe, a retired military Weapons Systems Officer (WSO), argues that flight time served as a WSO should count toward ATP requirements. He contends that the rigorous training and responsibilities of a WSO provide skills equivalent to or better than civilian flight schools and suggests adapting Part 61.159 Flight Engineer time rules to include WSOs.
I am a retired F-15E Weapons Systems Officer. I flew the Strike Eagle for 20 years. I am now working toward my ATP with 1196 of the 1500 hours required. Time flown as an F15E WSO should definitely count toward an ATP or at least qualify a WSO for a Restricted ATP. The rigors of military flight school and the nature of flying in the F-15E prepares WSOs as well as or better than an approved civilian flight school where I can obtain a restricted ATP. WSOs are required to pass checkrides every 18 months and must know all of the emergency procedures that the pilot does. Additionally, WSOs perform the "pilot not flying" duties that are required during an ATP. As an Instructor WSO, I was the instructor in the airplane. New F-15E pilots would fly with an IWSO with as little as 15 hours in the airplane. Its the IWSO's job to monitor the pilot at all times and provide instruction in the jet. All of this training prepares WSOs for the cockpit environment for an ATP plus it imbues situational awareness, crew resource management and air sense well beyond what is achieved in a civilian flight school. I do not think that a WSO needs to have an FAA instrument rating or commercial pilot license to gain the benefits of pilot monitoring that makes using flight time a good thing. WSOs receive instrument training in undergraduate flight school, even though we are not given an instrument rating. Furthermore, getting the required flight time to get a private pilot licenses, instrument rating and commercial license is prohibitively difficult when coupled with the rigors of day to day military duties. In my case, I earned my private pilot license while in my first assignment but my next two assignments were overseas. When I returned to the US, I was an IWSO and had a wing level job as the Wing Flight safety officer. I got very little flight time with my day to day schedule. Not to mention multiple deployments! I did not get any more ratings until after I left the military. Additionally, I did not decide to pursue a civilian pilot career until I was at retirement. Therefore, I would have missed out on the flight hours. I recommend that part 61.159 Flight Engineer time should be adapted for WSOs with cockpit duties, such as F-15E and F/A-18. It would allow for 1/3 of flight time be counted upto 500 hours toward an ATP. I wholeheartedly agree that the flight time obtained while flying the F-15E as a WSO should be applied toward ATP minimums.

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