Comment from Clinton Kelley

I propose allowing WSOs and NFOs who qualify to be able to apply their time in the cockpit towards acquiring an R-ATP after leaving service. Often due to deployments and time demands of being an officer it is difficult to earn FAA instrument and commercial ratings while still being in the military. The experience of being a flight officer in military aircraft is still just as valuable however and should be counted towards the time required to earn an R-ATP even if the WSO or NFO earns their commercial rating after leaving service. This will also help ensure that the person can meet the appropriate standards at the time when they are transitioning out of the military and into civilian commercial flying. This proposal is long overdue, especially for 2-place cockpits. Initial training is heavily focused on navigation, instrument flying, and communications with the student handling all ATC communications and directing the pilot what headings and altitudes to fly, directing level-offs, calculating decent points, and directing instrument approaches and go around/missed approaches. Checklists, emergency procedures, and unusual attitudes are also directed by the student with the pilot instructor following their instructions. In addition, heavy focus is placed on low-level VFR navigation and radar navigation. In the fighter community, after initial training being a fully qualified member of the crew is demanded. The WSO shares all duties with the pilot besides manipulating the controls, acting as the pilot monitoring. They will learn all the maneuvers and be able to talk through the correct positioning of the stick, throttle, and rudder during highly dynamic air-to-air and air-to-ground maneuvering often directing the pilot where they should place the controls. They also must be acutely aware of the positioning and energy state of the aircraft particularity during basic fighter maneuvering (dog fighting), low-level flight (300ft AGL) and dive weapons deliveries. Often in command of the mission and the overall safety of flight of multiple aircraft in the flight, they must be aware of the positioning and status of all aircraft supporting the mission. WSOs are equally responsible alongside the pilots for all aspects of safety of flight from pre-flight preparation and briefing all the way until the debriefing. Military flight crews are also trained in all aspects of CRM and required to have recurrent annual training. Throughout a WSO’s flying career they are equally responsible for checklist and emergency procedures and often must be keenly aware of the actions of the pilot because they are not side-by-side and cannot directly observe the pilot’s motions, relying on timing, the status of the aircraft, and verbal cues. WSO’s are also responsible for all communications outside of the flight with ATC and all external agencies. On top of all these duties the WSO is also responsible for the operation of the radar and weapons systems. Bottom line, in a 2-place cockpit the back seat officer performs all the functions of a second in command in a civilian commercial cockpit and more. I recommend a crew member of a fighter aircraft should be able to use their special crew time as a one for one in logging hours towards earing R-ATP eligibility and remove the restriction that a commercial rating has to be obtained before being eligible to acquire qualifying special crew time.