Comment from Robert Lacy

As an Air Force Combat Systems Officer (CSO) with nearly 2000 hours of flight time in a variety of aircraft, two of which included flight engineers (FEs) on the crew, I am intimately familiar with the similarities and differences between the two positions. Since the current wording of CFR 61.159, which gave FEs the opportunity to log time toward their ATP Certificate requirements, was adopted, the US military has largely eliminated flight engineers from its aircraft. Legacy aircraft requiring Flight Engineers such as the E-8 JSTARS and all variants of the C-130E and C-130H (C-130H, EC-130H, AC-130U, AC-130W, MC-130H, MC-130P, HC-130P) have been eliminated from the Active Duty force, though the position lives on in niche aircraft such as the E-3 AWACS, E-4B, C-5M, and some remaining C-130H3 units with the Air National Guard. Where those aircraft have been replaced by newer aircraft, such as the C-130J, AC-130J, MC-130J, HC-130J, many of the duties that the FE performed have been eliminated through the adoption of automated digital systems--just as they have been on commercial aircraft for years. For "FE duties" which remain, they are shared by the Pilot and the Pilot Not Flying (PNF), and in aircraft with a CSO on the flight deck, many are passed to the CSO. On the MC-130J and HC-130J for instance, the CSO is responsible for managing checklists for the aircraft during emergency procedures; balancing and managing fuel; monitoring engine start-up; monitoring and troubleshooting aircraft radio, navigation, and electrical systems; and clearing for traffic, just as the FEs were--while still being responsible for visual and instrument navigation, monitoring instrument approaches, interpreting meteorological forecasts and conditions, conducting flight and fuel planning, coordinating with ground and air traffic control, and knowing and adhering to applicable aviation regulations. For aircraft with only a Pilot and a CSO, such as the F-15E, this situation has always been the case, with the CSO sharing many pilot duties--including even operating the primary flight controls. If the adoption of the current language in 14 CFR 61.159 paragraph (d) (2), was intended to credit important and valuable aviation experience gained by highly experienced Air Force flight crewmembers toward earning their ATP certificate, then it would only make sense to extend this to some CSOs and NFOs, many of whom perform aviation duties much closer to those of a pilot than flight engineers ever did. However, the CSO and NFO community is not a monolith, and the comparison to FEs is different in some important ways. Though some CSOs are effectively an additional (or the only) PNF, other CSO positions may perform more limited "aviation" roles, and instead focus on the special missions of their aircraft. CSOs on aircraft such as the B-52, and B-1, perform duties tied to flight operations, but do not sit on the flight deck. On other aircraft, such as the RC-135 and AC-130J, one CSO's crew position sits on the flight deck performing the traditional duties of a navigator/FE, while others remain in the mission compartment performing specialized mission roles largely separate from safely aviating in the relevant airspace. As a result, "CSO hours" logged may vary greatly in their pilot applicability. Regardless of how involved or valuable a CSO may be to aviation operations, unlike a flight engineer, in no case does the aircraft manual prohibit basic flight operation without a CSO onboard. Due to these reasons, some might argue that CSOs and NFOs cannot, or should not be considered in the same category as FE's. This would be to miss the point. For the certain categories of CSOs who perform flight deck duties intensively focused on the safe aviation and operation of the aircraft, I would argue that their experience provides far more useful experience for a future airline pilot than the, now largely anachronistic, duties performed by a flight engineer. The petitioner attempts to unnecessarily complicate this by pre-requiring a commercial pilot certificate before logging time, though that does nothing to alter the value of the aviation experience received--valuable aviation experience will be gained in some CSO positions, and not in others. I would recommend then listing key duties that the FAA believes were the key competencies in which flight engineers were gaining experience, and in recognition of that experience being valuable (agnostic of the title of the aviator), allow CSOs--when in positions that perform that full list of duties--to log 1/3 time, up to 500 hours in exactly the same manner as flight engineers. Alternatively, or additionally, I recommend the intensive aviation coursework and training CSOs receive during their initial qualification be reviewed by the administrator for credit under 14 CFR 61.160.