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Castle Bravo
09-19-2017, 10:48 AM
61.159 (c) (3) allows military FEs to count 3 for 1 hours towards their ATP 1500, i.e. if an FE had 1500 flight hrs, he/she can credit 500 of those toward their ATP mins. The FAR doesn't mention navs, so I'm just wondering if anyone has Don Quixote'd this windmill yet with a waiver request, legal finding request, etc. I know all the bomb-droppin' Navs have to maintain Instrument ratings (via IRC) and I think the AMC guys do as well. Saving 500 hours of CFI time would be a HUGE savings towards trying to get to the Regionals. Has anyone had success or failure on this issue yet?


rickair7777
09-19-2017, 03:38 PM
This comes up every now and then.

The answer is No.

Castle Bravo
09-19-2017, 03:43 PM
The question is, has anyone tried to challenge the rule?


Hacker15e
09-19-2017, 04:18 PM
I know all the bomb-droppin' Navs have to maintain Instrument ratings (via IRC)

No. WSOs do not have an Instrument Check Form 8.

Castle Bravo
09-19-2017, 05:49 PM
OK, Instrument "Qual'd." IRC taken annually and for each checkride. All the approach plate reviews, etc. I don't think FEs on AMC jets do that stuff; nice that FEs get the ATP waiver, but why did the WSO community not get the same good deal as the FEs?
I just want to know if someone has tried to slay this dragon or not before I start my letter writin' campaign to the FAA and my local Congressman (who is a retired Nav btw).

rickair7777
09-19-2017, 05:49 PM
The question is, has anyone tried to challenge the rule?


S-3 NFO's have in the distant past logged some SIC and gotten away with it in the eyes of airline employers. But they had flight controls and even then it does not really standup to detailed regulatory scrutiny.

There's really nothing to challenge, the regs are written in a fairly clear manner. I think what you're talking about is a petition to change the regs, not challenge the existing ones. Call your congress-critter?

If you're airline bound, you'll probably get there quicker by building civilian flight time rather than titling at windmills in DC...

Castle Bravo
09-19-2017, 06:27 PM
I had the privilege of getting some S-3 stick time back in 2001 off the TR. The cat shot was brutal, but awesome. I still have my purple holdback.
Guess I'll start the letter campaign...never up, never in.

Otterbox
09-19-2017, 06:40 PM
I had the privilege of getting some S-3 stick time back in 2001 off the TR. The cat shot was brutal, but awesome. I still have my purple holdback.
Guess I'll start the letter campaign...never up, never in.

Even if you get the FAA to help recognize it towards ATP mins, airlines may not recognize NFO/NAV time at all towards hiring mins etc.

Write all you want but don't put flying on the back burner for it. 500hours could be as little as 6-9 months working as a CFI...

Castle Bravo
09-19-2017, 07:02 PM
Even if you get the FAA to help recognize it towards ATP mins, airlines may not recognize NFO/NAV time at all towards hiring mins etc.

I see your point...

navigatro
09-20-2017, 04:32 AM
Never trust a Nav that doesn't wear glasses.

155mm
09-20-2017, 08:06 AM
S-3 NFO's have in the distant past logged some SIC and gotten away with it in the eyes of airline employers. But they had flight controls and even then it does not really standup to detailed regulatory scrutiny.

There's really nothing to challenge, the regs are written in a fairly clear manner. I think what you're talking about is a petition to change the regs, not challenge the existing ones. Call your congress-critter?

If you're airline bound, you'll probably get there quicker by building civilian flight time rather than titling at windmills in DC...

True Statement! I've flown with guys who used it as SIC time. However, they did hold an FAA license while logging it and the civilian operator only required a commercial, instrument multi so the flight time was basically a resume enhancer and not regulatory as are the requirements for the ATP.

If the FAA regs still accept 500 hours of flight engineer time towards the ATP, does military FE time count ie: time in KC10, C-130, etc?? And while we are it, we had a handful of enlisted Private pilot rated helicopter guys that logged SIC time in the Loach helicopter (OH-6) as an Aeroscout Observer. Does that count as total time?

ExAF
09-20-2017, 09:51 AM
Never trust a Nav that doesn't wear glasses.A very wise WSO (that wore glasses) one told me....."Never fly with a WSO that doesn't wear glasses." Why? I asked. "Because then you don't know what's wrong with them!"

rickair7777
09-20-2017, 09:01 PM
True Statement! I've flown with guys who used it as SIC time. However, they did hold an FAA license while logging it and the civilian operator only required a commercial, instrument multi so the flight time was basically a resume enhancer and not regulatory as are the requirements for the ATP.

It never held regulatory water towards the ATP (due to lack of type rating or mil pilot rating, there's no regulatory basis for SIC time), although I think a few DPE's let it slide. Some employers would go for it as well, from a practical perspective it's not unreasonable. But that was then, this is now.

UPSet
09-21-2017, 06:49 AM
s-3 nfo's have in the distant past logged some sic and gotten away with it in the eyes of airline employers. but they had flight controls and even then it does not really standup to detailed regulatory scrutiny.

There's really nothing to challenge, the regs are written in a fairly clear manner. I think what you're talking about is a petition to change the regs, not challenge the existing ones. Call your congress-critter?

If you're airline bound, you'll probably get there quicker by building civilian flight time rather than titling at windmills in dc...

aka....... Cotac.

UPSet
09-21-2017, 06:52 AM
A very wise WSO (that wore glasses) one told me....."Never fly with a WSO that doesn't wear glasses." Why? I asked. "Because then you don't know what's wrong with them!"

+1!!!!!!!!

Cavepilot
09-25-2017, 06:49 PM
OK, Instrument "Qual'd." IRC taken annually and for each checkride. All the approach plate reviews, etc. I don't think FEs on AMC jets do that stuff; nice that FEs get the ATP waiver, but why did the WSO community not get the same good deal as the FEs?
I just want to know if someone has tried to slay this dragon or not before I start my letter writin' campaign to the FAA and my local Congressman (who is a retired Nav btw).
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.

Klondike Bear
09-26-2017, 03:35 AM
I think part of it comes from most of these planes need a FE as part of the crew every time you fly but the Nav only for tac flights. Take the C-130 for instance. It needs a Nav for airdrop missions, but if you are just going out to do touch and gos you don't need a Nav. You need a FE all the time. I could be wrong and I wish you luck accomplishing your goal.

Hacker15e
09-26-2017, 06:15 AM
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.

Cavepilot
09-26-2017, 05:13 PM
I think part of it comes from most of these planes need a FE as part of the crew every time you fly but the Nav only for tac flights. Take the C-130 for instance. It needs a Nav for airdrop missions, but if you are just going out to do touch and gos you don't need a Nav. You need a FE all the time. I could be wrong and I wish you luck accomplishing your goal.

You need a NAV for crossing the pond. You need a NAV for MNPS airspace. I don't think needing an FE for all flights is an FAA criteria. I could be wrong but we need to look into this.

Cavepilot
09-26-2017, 05:29 PM
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.

Hacker,
Your questions rightly fleshes out the intricacies of this issue. My strategy would be to get a written explanation from the FAA on how FE time is justified. That is; their thought process in granting FE's this exception. I believe that is essential to any effective argument in the case for NAV/CSO/NFO. Invariably, CSO's, ECMO's, EWO's and TACMO's may not get lumped under the same umbrella. I don't have the answer to that just yet.
I actually got this going a while back but got sidetracked by other things. Getting one or two more people will make the task more manageable.

Again, this is my idea on how to tackle this. Others may have a better approach. I am open and eager to join heads.

navigatro
09-26-2017, 05:31 PM
You need a NAV for crossing the pond. You need a NAV for MNPS airspace. I don't think needing an FE for all flights is an FAA criteria. I could be wrong but we need to look into this.

F/E's are required crewmembers.

your NAV hours will count towards an FAA Nav rating. They do not and should not count towards a pilot ATP. I am a former nav, so I have some understanding, but you are fighting a losing battle.

rickair7777
09-27-2017, 06:43 AM
FEs are a known quantity and have an established (if largely historical) place in 121 ops. Nav, wso, rio, abm, mpra taco, etc, etc are not consistent experience. It would have to be airframe. Just not enough interest.

155mm
09-27-2017, 10:37 AM
FEs are a known quantity and have an established (if largely historical) place in 121 ops. Nav, wso, rio, abm, mpra taco, etc, etc are not consistent experience. It would have to be airframe. Just not enough interest.

In addition, the aircraft type certificate requires the flight engineer regardless of Part 121, 91 corporate or military use. The other positions you mention are duty positions not required by type certification. Of course, a certain carrier converted all its perfectly good DC10s to a MD10 but that's another story.....the flight plan stills shows it as a DC 10 so perhaps if you jumpseat as an ACM in the old FE seat for 500 hours some third world country will count it towards an ATP? :(

Castle Bravo
09-27-2017, 12:53 PM
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.

OK, here is my thought process, but first, some historical info;
Once upon a time, FEs flew on airliners like DC-8s and 727s. Often these were "third pilots" who didn't log PIC/SIC time, but FE time. When the new law was passed, FE time was included, and so (my assumption) the military FEs were also included, but at a 3-1 rate. A mil FE with 1500 total FE hrs could credit 500 of those toward ATP.

Now for a disclaimer: I can't argue for UAV pilots; not my cup of chili.
I'm not looking for Nav time to be counted as pilot time 1 for 1 w/regard to ATP...neither is FE time. This is about the FAA approved 3 for 1 rule.

My argument is this:
AF/Navy Nav/NFO/WSO/CSO whatever they're called these days, all have:
- A 4 yr college degree (minimum)
- Passed a military flight rating program of at least 12 months in length (longer for NFOs 'cause the Navy can't schedule for $hit)
- Have at least 6 yrs experience as crewmembers in high performance acft (many of us 20 yrs plus), global flight ops, & in class A airspace.
- Take the same Instrument Tests and Approach Plate tests as the pilots (once you're in the fleet).
- Extensive navigation and flight planning experience

Comparatively to the above list, AMC FEs have (in general terms) only the crewmember experience in high performance acft (plus C-130s) :D
Yes many have college degrees, etc, but that is not a reqmt for their job, like it is for Nav/NFOs. Again, I'm not trashing FEs, just making comparisons.

Additionally, the civilian kid who graduates from Mother Mary's Junior College with an Associates Degree and a CFI can reach ATP mins in 1250 hours. But he/she has most likely never flown more than 172s and an occasional Baron, never been in Class A airpsace, and never flown long duration open water flights. Staying "ahead of the jet" for them means thinking at 100 knots, not 420 or 600.

So, in summary, this is a problem solving expedition. A) The Regionals need many more mature, experienced pilots with high-speed and high altitude backgrounds; and B) I'd like to see a path to more Navs/NFOs getting jobs in aviation and out of these cubicle $hitholes.

If a military FE with no college degree(s), limited Instrument knowledge, no formal "Rating" (like Pilot/Nav) etc can get 500 hrs credit, and Johnny from Mother Mary's Jr College that has the same PPL/IR/CPL/ME/CFI tickets as a Nav/NFO can get by at 1250, then I'd like to see a Nav/NFO with a 4 yr degree(s), 6-20+ yrs flight and Instrument experience catch the same break.

Again, not trying to equate to Pilot flight time (1 for 1); not to trying to hate on FEs (good for them); not trying to degrede Johnny's JUCO degree, but I think Nav/NFos far surpass that level of experience and creditability, especially when we will all have the exact same licenses up through CFI.

This may all be a moot point depending on what comes out of the Senate bill in Congress right now.

Ready for incoming...

155mm
09-27-2017, 01:44 PM
Ready for incoming...

If I were you, go buy a small single engine aircraft and fly the **** out of it until you have 1500 hours. Some of these LSA aircraft are basically lawn chairs with wings as well and you can get a CFI LSA at 150 hours. If it has a N number log it and you'll be light years ahead over fighting a dysfunctional government.

Brillo
09-27-2017, 04:45 PM
If I were you, go buy a small single engine aircraft and fly the **** out of it until you have 1500 hours. Some of these LSA aircraft are basically lawn chairs with wings as well and you can get a CFI LSA at 150 hours. If it has a N number log it and you'll be light years ahead over fighting a dysfunctional government.

Agree. Don't know what your timeline is, but unless you're more than 5 years away from getting out, you're much better off just getting the time on your own.

Even if everyone you deal with is 100% on board with your ideas and wants to help you make the change, and you face zero road blocks, to get something like this done is a multi-year process.

More power to you, and if it helps the generations after you, then good on you. But again, if you are trying to get hired in the next couple of years, I wouldn't count on this as plan A.

Castle Bravo
09-27-2017, 07:14 PM
More power to you, and if it helps the generations after you, then good on you. But again, if you are trying to get hired in the next couple of years, I wouldn't count on this as plan A.

A) I'm pressing ahead on my hours regardless of this project, as you suggest.
B) The new Congress Bill will determine if it makes sense to press ahead on this issue.
C) The payoff is for the rest of the naviguessors behind me...with GI Bill, etc, etc and the hiring going on, I hope this make a much easier path to the Regionals for them.
D) Yup, the slow wheels of Congress/FAA means I'll hit 65 by the time this is ready for a decision!

ItnStln
10-24-2017, 02:33 PM
Never trust a Nav that doesn't wear glasses.



Iíve heard that actually!



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