tc, you are actually ahead of us Aussies if you are considering single pilot NVG at all! The FAA have allowed single pilot NVG passenger charter. They have been running single pilot (to the ground) for 10 years without accident. We Aussies seem to feel the need to change that.
What I don't get is why we replace a more risky operation without redundancies (nitesun approaches) with a fully redundant, far easier, and much less risky operation (NVG) and then make a requirement for another crewmember in the front. It just doesn't compute. And in Australia this requirement rules out NVG operations for all but the richest and most highly resourced organisations. The poorer, less resourced non IFR, single engine mobs who need it the most will be excluded (resource wise) from NVG use by these requirements, for other than transit at and landing to prepared LZs. Now add that to the excessive training requirements and ICUS, and hope fades fast. Without considering the extra crewmember required by the CMI in Oz, I calculate that the training bill for a single aircraft 24/7 EMS operation will be about 40 hours more training than the US regs require (with their 10 years of operational experience) and 95 hours more ICUS. Thats a big cost for a small organisation.
tc, the FAA standard is 5 hours per pilot.
There are some other issues, such as the prohibition of flight into visible moisture, that can be debated, but dont let these issues, or even my arguements above, detract too much from the step forward that Mike Tavcar (and a CASA bloke called John Beasey)has achieved as there is a lot right with this CMI, but discussion inevitably centres around what is wrong with it. The previous discussion centred around whether it would be easier to argue the case prior to setting a standard, or getting one and trying to change it. Now we have got one, we can see how difficult it will be to modify: you Brits should watch closely in order to choose your path.
Mike, I have a different perception of your belief that the CMI is not an industry standard. I quote the following from a letter to the HAA from Bruce Gemmell, CASA Deputy Chief Executive Officer
and Chief Operating Officer, dated 10th January 2005.
The Compliance Management Instruction (CMI) on the use of NVG technology was developed to allow for standardisation on the use of NVG prior to the development of formal legislation surrounding the issue. The development of such legislation will follow the finalisation of Civil Aviation Safety Regulation (CASR) Part 133.
The CMI provides CASA staff with guidance on how to assess applications for exemption from Civil Aviation Regulation 174B, ensuring that that operators are aware of the safe introduction, standardisation and regulation of limited helicopter NVG aerial work operations. As a part of this guidance, the CMI also contains appendices for applicants as to what CASA will expect in their application. The CMI is used to support a standard approach by CASA.