Old 09-26-2017, 06:15 AM
  #18  
Hacker15e
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Joined APC: Oct 2006
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Originally Posted by Cavepilot View Post
Castle,
I am all about getting the ball rolling. I am willing to roll up my sleeves. Makes no sense that an FE can apply hours and the NAV can't. The airlines don't have to accept it but if I show up with an ATP, what else will they say. With the hiring boom, I don't think they really have the luxury to be particular when there isn't any real justification.
Can you lay out the argument you'll make to the FAA for this?

Does your proposal hinge on simply asserting equivalency with FEs (or rather, equivalency with pilots in the same way that FEs are in the CFR)? If that's the angle, then is your goal the 500-hours-credit-for ATP rule?

If not, then how do you justify the training, skills, and experience of such a widely variant career field as NFOs/CSOs as, by default, equivalent with pilot flight time? Some aircraft have access to flight controls for NFOs/CSOs and some do not. Some aircraft and regulations have airborne decisionmaking authority for NFOs/CSOs and some do not. Credit for all, or credit for some? Split it out by aircraft type or by crew position designation according to the flight control access and/or the decisionmaking authority?

Are you going to argue for straight military NFO/CSO hours to be considered for this, or that if an NFO/CSO holds appropriate ratings in Category/Class/Type they can log the Part-61 "sole manipulator of controls" definition flight time? If the latter, then does that time count straight time, or does it count 3-to-1 ratio like the FE military time? Is the credit only toward the ATP, or other ratings too?

By contrast, consider the training and experience that 18x (rated UAV operators) receive, and their lack of pilot-equivalent credit with the FAA. Consider that rated pilots don't even get to credit their UAV flight time toward flying time requirements, even though that job requires a very similar type of airmanship/decisionmaking to manned flight time (and is arguably more relevant than NFO/CSO time). How do you argue that their time is not valid, but NFO/CSO time should be?

Not trying to hate here...just curious what arguments you're going to bring and what logic you're planning on using to defend it.
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