Comment from Harry Davies

Harry DaviesSupportIndividual
Summary: A Naval Aviator supports the rulemaking to allow Naval Flight Officers to count a portion of their flight time (Special Crew Time) toward FAA certificates. The commenter argues that the training and responsibilities of these officers are comparable to those of pilots and flight engineers.
I am a Naval Aviator who has flown with Naval Flight Officers in tactical aircraft (F/A-18, EA-18, T-38, F-16) frequently throughout my career. I support this rulemaking to count a portion of their flight time (Special Crew Time) towards FAA Airline Transport Pilot and other certificates. The individuals I have flown with are well-trained and pass evaluations similar to those of pilots. They perform several functions in the aircraft identical to Pilot Monitoring in multi-piloted aircraft--monitoring flight instruments, monitoring engine instruments, working through emergency procedures, and communicating with ATC. I believe this experience is AT LEAST on par with Flight Engineers whose time is already recognized by FAA regulations.

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