NASUS: hear, hear! I agree with much of what you say.
I want to pick up your comment re the FAA rules and "world's best practice". World's best practice is unfortunately subjective terminology because it means so many different things to so many different people. We are balancing the significantly increased safety represented by the adoption of NVG versus the cost of introducing the capability. If you make the capability so expensive to introduce, or the rules so restrictive, then few get to attain the desired outcome of a safer night flying method. Conversly, if you adopt ridiculous minimums to ensure the capability is cheap, you create more accidents because the operators are unaware of the limitations.
World's best practice is a throwaway line to articulate this balance. Resource rich operators invariably come up with a different answer than do resource poor ones, and NVG is no different. During the industry consultation phases of the HAA push for NVG there were operators and individuals who made arguements for a 10 hour pilot training courses, 8 hours for crewmen, full military style cockpit mods of hundreds of thousands of dollars, and hours and hours of ICUS before command. Then there were others who argued for NVG to be an endorsement on your night rating like a NDB or VOR. A lap around the block and box ticked, a cockpit mod costing $2000 (yes there is one flying), and lets get on with it. Everyone who presented an arguement claimed it as world's best practice - but who is right?
The Australian Transport Safety Bureau concluded it's Aviation Research Report B2004/0152 – Night Vision Goggles in Civil Helicopter Operations by saying: “NVG’s have the potential to enhance safety but risk mitigation is required by ensuring a comprehensive implementation package AND properly resourcing the capability in terms of equipment and training.”
Though they too failed to quantify what "properly" and "comprehensive" actually meant. Nevertheless, it is an excellent report into the capabilities and limitations of NVG and the HAA used it to have a stab at creating Australian rules.
That brings us to the FAA rules. Years ago (1994 ish I think) the FAA comissioned an not-for-profit organisation to examine the adoption of an appropriate set of rules for NVG flight. That organisation (the RTCA)subsequently formed Standing Committee 196 (SC-196) and invited representatives from all over the world - including incidently, Mick Haxell from Australia (amongst others) and Mike Atwood from Aviation Specialties Unlimited (see link above) essentially steered the committee. I believe pprune's JimL was also there. SC-196 created and published a number of standards documents that have essentially become the international standard for NVG use - or at least the starting point.
This then begs the question - has this international group of subject matter experts got it so wrong? Or could they be said to have created "world's best practice"?
In accordance with the CASA CEO stated vision of adopting established international practices unless a safety case prohibts it, finding middle ground in the Oz industry views, PLUS recognising that SC-196 might have got it right, the HAA went down that line. So did the FAA.
The HAA "Australianised" it a bit: for example few other countries have a night LSALT like Oz (and the SC-196 does not refer to any) and tightened up some of the definitions in response to industry concerns - such as pilot flight training will be a min of "5 hours NVG flight time", not just "5 hours", and instrument profficiency must be demonstrated prior to commencement of the course.
Have the HAA got it that wrong?
Your last comment was:
If you think training is expensive try having an accident.....
What about Malborough and Mackay? 8 fatalities that I contend would have been prevented if NVG were in use. 8 fatalities that have occured since the SC-196 pointed the way forward. 8 fatalities that have occurred while CASA have tossed and turned over the meaning of "world's best practice" without resolution. How does that sit with your quote?
And if it was not for Tavcar, Beasey, Anderson (you named him above, I am not sure what role he played) VPAW,and now Byron, I shudder to think where development would be.