EC,
Reading through Ray White's presentation....it strikes me as being a telling discussion on how "Rules" once written seem to take on a life of their own and are never amended or repealed to include situations not considered when the original Rule was crafted.
We all know RFM's can have different forms....with the Performance Section and/or Limitations Sections having restrictions on how the aircraft is operated but with one Section being Mandatory and the other not.
Ray talks of a Failure of the NVG's at the Critical Point of the Maneuver and insufficient visual reference being available to complete the maneuver. Yet, he accepts the notion that NVG's are to be an aid and not alter the conditions under which the aircraft is to be operated. Which makes me wonder why you can do the maneuver without NVG's to begin with.....but cannot with a NVG failure and reverting to your MK 1 eyes....if the conditions are the same for each situation?
I think even Ray is getting confused.
He spends a fair bit of time talking about Certification of the Aircraft, the RFM, and requirements for Cat A/Class One Performance and Take Off/Landing Profiles....and shows how they create difficulties for getting NVG use approval by the various NAA's. It seems the NAA's are more prone to vary from existing policies re landing site requirements for the Class 1 profiles but seem to get very reluctant to make any variation for NVG's. The focus upon NVG's failing at a critical point in the Profile seems very important to the NAA's but in my opinion those concerns are excessive.
I can think of some other failures at the Critical Points that would be far more dangerous than a Goggle Failure. The Safety Enhancement of NVG use for all phases of flight far exceed any additional risks they might pose should they fail at the critical point following an engine failure.....as we are talking about a very small risk of the engine failing to begin with.....and then adding the very slight chance of having a Goggle failure at the same time. I am not a Statistician by any means.....but that seems like a very weak argument against using NVG's.
The concept of requiring Class 1 Performance is another topic that needs to be argued......as again.....Engine Failures are pretty darn remote and present a very small hazard compared to the most common killers of EMS Crews who fly at night.
Weather, Wires and Obstructions, and CFIT are the killers of EMS Crews.....not engine failures.