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Old 28th May 2006, 08:21
  #481 (permalink)  
 
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WOW. Thank you,great page...very usefull!
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Old 28th Oct 2006, 09:54
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NVG Training: Atwood challenges legality of Latest FAA guidelines

Mike Atwood founder of ASU, Boise, ID., a company established to offer night vision training for civilian groups has been closely involved in the evolution of the regulatory base to define training and operation regulations within the FARs.

He recently reviewed a new copy of a key FAA document - an HBAT (Handbook Bulletin for Air Transportation - used to set policy guidellines for FAA districts as well as to establish standards for field inspectors. His reactions to the document are expressed in the following letter he recently sent to colleagues in the NVG training field.

Full text of the letter:

All:

I have attached a copy of the latest NVG HBAT Handbook Bulletin for Transportation document that is supposed to give guidance to the FAA, POI’s, and the operators on getting their NVG programs established.
This document affects each and every operation.

As all of you may remember, last year when this document was first going through revision, I voiced concerns about the industry not having an opportunity to provide input to this document. There were (21) recommendations forwarded to Hooper Harris for review and implementation into the HBAT document. The recommendations were based on previous operational experience and discrepancies included in the original HBAT document.
The new HBAT revision is out, approved, and not one of the (21) recommendations we had supplied were included in the revised document.

Also, the FAA has now seen it fit to increase the NVG Initial Pilot training time from 5 hours to 8 hours (Page 8).
This is a 60% increase in the training and will have significant economical impact on the NVG program.
The additional flight hours per pilot, coupled with increased aircraft flight hours, crewmember overtime, shift coverage, and aircraft out of service time will have a massive impact on the operators program, both operationally and economically.

The HBAT document is in direct conflict with the joint FAA and Industry approved training program through the RTCA Committee SC196 and contained in RTCA/DO-295, dated Oct. 19, 2004. Which was approved for (8) hours Ground School and (5) hours flight per pilot and included guidance for the training of medical and additional personnel.

I believe that what the FAA has done with this document is illegal, not only from the economic/operational impact to the operator with no justification, but from a previous legal action of RMHC vs. the FAA, where the 11th Circuit Court of Appeals ruled that the FAA cannot regulate through policy, i.e. HBAT, AC, Order, etc., this can only be accomplished through a CFR or FAR.

There is absolutely no reason or justification for this increase, especially since there are now over 100 bases, 600 pilots, and 1,800 medical crew that have been trained over the last 8 years under the 5 hour program.

If this 8 hour requirement is allowed to stay in this document, I can guarantee that the average FAA POI will interpret that the program will require 8 hours of training.

Also, I might add that during this 8 year period, there have been no documented accidents or incidents attributed to NVG operations or NVG training deficiencies.
The (2) accidents that occurred with NVG’s onboard were not attributed to the goggles and the (3) hours flight time would have had no effect to the outcome of the accident.

Also, the new HBAT has added additional criteria that increases difficulty for the operator in establishing their NVG programs, plus opens the door for more individual broad interpretation from the FAA, by individual POI’s who have no industry (civilian) NVG experience.
One of several of the criteria, calls for a “Detailed Maneuver Guide” for the NVG training program, the HBAT also states that either the POI or the NRI will give the check rides on completion of training. Based on the FAA Travel Budget, plus the Inspector’s available time, this task is near impossible, plus the delays in scheduling the observation and check-rides would be unrealistic. Why not a qualified Pilot Check Airman to accomplish this?

The NRI program that was to help and assist POI’s and operators is “Broke”. It seems that the only criteria to be an NRI, is to have been an Army aviator. Two of the NRI personnel that have been associated with NVG programs since the very first approvals in the late 1990’s and have grown with the programs, have become frustrated and quit. There does not appear to be any selection process for the NRI program, based on Operational Experience and knowledge of the operator’s mission requirements.

One of the major problems that the FAA refuses to admit, that industry has taken the lead and has developed the expertise and experience for civil NVG operations, “Not the FAA”.
Because an individual flew NVG’s in the military, this does not give them the knowledge base, operational experience, and absolute qualifications for civil NVG operations, especially if they have never flown civil operations.
It seems that there is a mentality within the FAA that they need “To protect us from ourselves”.

Conversely, industry has NVG qualified IP’s who possess both military and civilian operational experience, which makes us uniquely qualified to recognize the differences in these operational environments.

This has gone on long enough. The old adage, “Go along to get along”, does not apply in this case, we have been patient and have been told that the FAA is working on streamlining a document that will give “Clear and Concise” guidance in establishing NVG programs. In actuality, we have now taken a giant step backwards.

I urge each of you as an individual, as a company, or an organization to send an email protesting this latest HBAT document and demand that we have a voice in making the change.
I cannot stress enough the importance of the potential damage to NVG programs this document can cause.
If you don’t, then we will be stuck with an inadequate document. All of us have spent too much time, energy, and money incorporating NVG’s into civil aviation to allow this to happen. We have been on committees (RTCA), attended conferences, and given 100’s of presentations in support of night vision goggles in the interests of “Safety”. This has apparently gone unnoticed to the FAA.

It is probably time to call for assistance and support from our Congressmen, Senators, and the News media.
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Old 29th Oct 2006, 07:44
  #483 (permalink)  
 
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Anvis now approved for UK Police pilots.

Heard the other day that following a modification to the power supply, Anvis NVG's have now received approval from the CAA to be used by UK Police pilots - ending the monopoly in that particular market, although their web site Defence Optical Systems does not seem to carry the info yet.

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Old 29th Oct 2006, 08:23
  #484 (permalink)  
 
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About time!

Finally the CAA have realised how useful NVG are whilst operating in the night low level enviroment, its a shame that its taken as long as it has to grant the authority to use something which without doubt adds to flight safety.

Having used NVG for years I appreciate how effective they are at seeing obstructions and terrain, especially on low or no moon nights away from the house or street lighting.

MS
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Old 29th Oct 2006, 08:32
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MIN,

The CAA had already realised - It's just that there had previously only been one approved manufacturer / type, so this should open up some healthy competition.

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Old 29th Oct 2006, 11:02
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Coconutty,

Thanks for filling in the details, do you know what the delay was in approving this other NVG type, surely the technology of one manufacturer is similar to another all be it some have battery packs as a seperate box and are mounted differently with slightly different ways to focus the tubes, or was it just too complicated an approval procedure that other NVG manufacturers couldn't be bothered with the obstacles until now?

Or am I just being cynical



MS
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Old 29th Oct 2006, 18:23
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MinSelf, the reason why

I think you will find, as I did when I tried to buy some last year, that the CAA only like the made in England, Lithium battery powered, £15,000 a throw, made in England, no back up power to tubes, but made in England, very smart, however not used by any other nation, NVGs.

I contacted the UK company mentioned above who make ANVIS for UK Apache but it seemed they couldn't get the ANVIS concept past a certain former CAA person, (known to all in the industry for various certification antics over the years, now working for Augusta) they have been trying for 2 years to have ANVIS accepted without modifications, but have now finally given in and degraded the system to comply with CAA requirements. On the plus side you can probably use them this winter without needing a letter from both of your parents, countersigned by the last King.

I am still unsure how the rest of the world seem to be ok with ANVIS but the UK CAA know better, it must be all of that military and Para mil experience they have..........
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Old 30th Oct 2006, 09:01
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That's pretty much the deal - Previously the only gogs that CAA would certify were the Fenns version which has an independent power supply to each tube, so in the event of a battery / power failure, you would still be left with one tube working and not totally blind. ( Seems to make sense ).

Other makes, including Anvis, had a power supply that powered both tubes simultaneously, with a back up set of batteries selectable with a flick switch, and the CAA didn't like that.

"Apparantly", despite a number of factors and arguements put forward, the CAA would not move on that issue so the company have modified their Anvis so that the power supply does what the CAA require. The main difference is that Anvis are powered by 4 x standard Duracell type "AA" batteries ( 2 powering each tube ), whereas the Fenns version uses Lithum ones.


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Old 30th Oct 2006, 13:35
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What a feat of *rse - the beauty of Anvis was that, in the unlikely event of a battery failure, a simple flick of the switch gave you both tubes back instantly. On the 'battery per tube' type you have a major faff on your hands to change the battery while you give control to the other pilot or climb to MSA. I know which I think is the safest.
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Old 30th Oct 2006, 13:53
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..... the other pilot

This is for UK Police single pilot ops !

( And didn't you get advanced notice with Anvis when the batteries were getting low - a warning LED came on, letting you flick the switch well before it all went dark )

With most flights well under 2 hours, and battery life well in excess of that ( 30 odd hrs ? ) it would be interesting to know the reasoning behind the CAA mandating that there must be independent tube power sources.

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Old 30th Oct 2006, 15:18
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Coconutty - that was part of my point, for single pilot ops anvis would be much better, I don't fancy trying to fly and change a battery and it would certainly reduce your operational effectiveness while you sorted your life out.

And yes you got a red led warning of impending battery failure so the changeover was always preplanned. I've given up trying to work out how the CAA comes to some of its conclusions.
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Old 30th Oct 2006, 21:38
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I followed this up with the UK reps DOS over the weekend and it seems that all is still not ready and they are in fact still waiting to get their hands on what they describe as EASA [not CAA] paperwork before they go public with it.

It seems that the rumour you heard was a 'quiet' pre-launch briefing to likely users.

Anyway they expect to go public this month so my pen is only temporarily sealed!
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Old 1st Nov 2006, 03:40
  #493 (permalink)  
 
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NVG's

Most know that NVG's are useful aid to safer night flying...that is if used correctly, with proper training and procedures in place. However, it is also a double edged sword where it can be one's worst nightmare.
I certainly feel that its about time that civvy ops eg EMS and police work be given the green light for countries still opposing it.
Civvy regulators IMO should take the more prudent step in adopting the procedures and measures that the military have in place and not try to "re-invent the wheel". These measures can then be tailored accordingly to the demands of civil operations over time.
There have been countless accidents in the military when NVG's were first used and we should learn from these mistakes.
The US army flightfax magazine is an excellent resource for lessons learnt with lots of info on NVG's.

Just an example:
NVG Currency
Perishable Skill — Currency is Not Proficiency



Perishable Skills. We have all heard the phrase, “That's a perishable skill,” but what does it really mean? I have heard it for almost 20 years and always thought of my golf swing as my most “perishable skill.” But a recent accident investigated by the U.S. Army Combat Readiness Center brought the phrase back to mind in a much more appropriate way.
This UH-60L accident serves as a prime example of how perishable some skills really are. It involved a crew that no one ever expected to have an accident.
The instructor pilot had over 8000 hours of rotary-wing experience; the PI was young but highly thought of; and all the crew members had flown together many times in the past. Both aviators were qualified and current for the night vision goggle environmental training mission.
The problem? Neither crewmember had significant recent experience in NVG flight. The hostile conditions overcame their skills. They became disoriented during a takeoff and crashed, destroying the aircraft. Fortunately, everyone on board will fully recover from their injuries.
We are all aware of “NVG currency” requirements as stated in the Aircrew Training Manual (ATM) for each aircraft. Instructor pilots and unit commanders constantly monitor aviators to ensure that everyone remains current by flying at least one hour every 45 days under goggles. As long as we maintain that standard, we can report combat-ready goggle crews to the chain of command every month.
But, in the back of our minds, we all know that one flight every 45 days does not maintain the proficiency necessary to execute the tough missions we may be called upon to complete. This mission is a perfect example.
The aviators involved in this accident were NVG current. They met the ATM standards required to conduct the mission. However, neither crewmember had flown more than 3 hours of NVG flight in a single month for over 7 months. We have all seen this in our units at one time or another. Other mission requirements, administrative obstacles, or flight time restrictions have put nearly everyone in this position at some time. Most often, we manage to get the mission accomplished when called on. The problems arise when an aviator who is just maintaining currency is placed in conditions with which he is unfamiliar and that requires real proficiency rather than currency.
In this case, we put these aviators in a dusty, windy environment, with low illumination, with little recent experience under NVGs, and all these things added up to a situation primed for an accident. The cumulative effect of the 16 risks associated with this mission exceeded the capability of the crew, and a major accident was the result.
If any one of the conditions — low recent experience, dust, winds, or low illumination — had not been present, perhaps the accident would not have occurred. If the aircrew had more recent experience, they would have been better able to deal with the harsh environment. If the illumination had been better, their low recent experience might not have been a factor. If the conditions had not been as dusty, perhaps the crew would not have become disoriented. If, if, if...
The key lesson to be learned is that there are perishable skills. Night vision goggle flight is one of the most perishable skills in our business. When circumstances force us to maintain NVG currency rather than proficiency, we must be aware that those aviators are not ready to proceed directly into harsh environments. Commanders must transition through the crawl, walk, run scenario. NVG currency is the crawl. NVGs in adverse conditions, such as the desert or other severe environments, are Olympic events. We can't expect aircrews to go straight from one to the other.

Just my opinion
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Old 1st Nov 2006, 04:02
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Civvy regulators IMO should take the more prudent step in adopting the procedures and measures that the military have in place and not try to "re-invent the wheel"
You may like to know that an international committee of NVG subject matter experts convened in the 1990s with just that goal - to bring NVG out of the military and into the civil world by establishing a set of minimum operating standards.

The committee became known as Standing Committee 196 (SC-196) formed by the RTCA, and was almost exclusively made up of military or ex-military personnel with an NVG background from around the world. These military people were at pains to translate as many of the military lessons across as they could, but at the same time, to leave behind unnecessarily restrictive practices borne out of earlier generation technologies or military mission requirements.

They invented the wheel for civvy ops. Specifically designed it for civvy ops.

So rather than go back and re-invent the wheel by importing all the military stuff, why not simply use the wheel specifically invented for civvy ops, designed by military and ex-military people with all the factors in front of them? Designed by the same people who probably helped write most of the military procedures you are referring to.

The question is – can an international committee of NVG subject matter experts be trusted?

Just a devil’s advocate here with the UH60 accident: are the perishable skills NVG or dust operations?
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Old 1st Nov 2006, 08:33
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NVG's

Just a devil’s advocate here with the UH60 accident: are the perishable skills NVG or dust operations? [/quote]

Helmet,

The example was from the flightfax. Each individual will learn certain things from there and if that's the case, then i think it has served its purpose.

Wont comment on the accident, however as i believe you would agree that whenever an accident occurs, all factors are considered and normally it would not point to a single sole factor but a combination of contribution factors of varying percentages, with environmental factor (dust and poor illum) as part of the cause.

With this in mind, its hard to detect detiorating weather/brown out on a dark night when using goggles. Of course, poor video noise and halos will give you indication of moisture content. This will certainly spell trouble if non-IR.

I guess whats holding back NVG's for civvy ops is really the $$ cost versus benefit factor.

Quite surprised that Shawn Coyle is missing in here. Have seen the excellent sand table in the dark room at his facility in Mojave. You would be able to appreciate quite a lot eg moon angle, moon illum, shadows etc without having to actually be airborne.
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Old 1st Nov 2006, 21:50
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Cougar,
You inferred that the accident article was your opinion, that is why I asked.
Just my opinion
The author of the article concentrates on NVG perishable skills as the major contributing factor here, but it is hard to see how the outcome would be any different day, night unaided or even in snow. brown out and white out have the same recovery technique regardless of the flight conditions - level the wings, adopt hover attitude, apply beaucoup de climb power and non flying crew members strain for an outside glimpse of reference to help.

Why is it that we never seem to blame brown out and white out day time incidents on the perishable skills of day flying, or even dynamic roll overs on the perishable skills of take off and landing? But throw NVG into the mix and it nearly always seems to be the NVG that are the problem.

I guess whats holding back NVG's for civvy ops is really the $$ cost versus benefit factor
I agree totally. The more we impose a military training regime on the civvys, the worse the ratio will be. Fortunately, the military gurus before us have created a reasoned set of minimums for us to adopt, and we need to spread the word that NVG can be achieved cost effectively.
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Old 2nd Nov 2006, 03:26
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Helimun

BTW Helmet,

Have you had an opportunity to pass your bifocals over the Helimun equipment? Pretty much the same specs as ANVIS, but without the crippling US export restrictions...

We have the distributor snapping at our heels and we have referred him to the HAA; we thought he may have some stuff of interest to you...

Scouts out!
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Old 2nd Nov 2006, 04:39
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NVG's

Helmet,

I should have inserted the line "just my opinion" right after the 1st para before the example.

Quote "I agree totally. The more we impose a military training regime on the civvys, the worse the ratio will be. Fortunately, the military gurus before us have created a reasoned set of minimums for us to adopt, and we need to spread the word that NVG can be achieved cost effectively."

I believe there are quite a bit of differences between mil and civ ops where its not in agreement eg. mil special ops go in with all lights "off", dont think you can do that for civil ops as you need to display your nav lights.

Have to be careful with "cost effectively", dont want civil operators to try and spend the bare amount as it would then make NVG unsafe putting the lives of crew and pax at risk not mentioning the $$ cost of aircraft.

The best should be given and nothing less to do the job safely and sucessfully ie.
1. External lightings mod with IR landing light, aux anti-col and dimmed position lights - prevention of flicker vertigo.
2. Internal lightings mod - mentioned before in numerous past posts hopefully UV lightings for cockpit as well as cabin.
3. Best possible NVG equipment for the job - with proper maintenance support.
4. Good training and training aids - to equip crew with proper knowledge to do the job safely. Have a dark room to check googles with Hoffman set.
5. Proper SOPs in place - Crew rest and duty periods, flying hours limitations (we use 2 times ERF), currency requirements, go-no-go criteria (weather, illum etc).
6. Some may disagree but i feel Instrument Rating is necessary.

These are the basics we should insist as we are the ones in the aircraft. EMS should all be NVG equipped (if not already so). Lives saved outweight the cost many mnay times.

Just my thought that the best should be provided rather than rush out and strap on that pair of "miracle tubes" which can lead to undesirable consequences for those that are not quite ready.
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Old 2nd Nov 2006, 05:06
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Originally Posted by cougar77

The best should be given and nothing less to do the job safely and sucessfully ie.
1. External lightings mod with IR landing light, aux anti-col and dimmed position lights - prevention of flicker vertigo.
2. Internal lightings mod - mentioned before in numerous past posts hopefully UV lightings for cockpit as well as cabin.
3. Best possible NVG equipment for the job - with proper maintenance support.
4. Good training and training aids - to equip crew with proper knowledge to do the job safely. Have a dark room to check googles with Hoffman set.
5. Proper SOPs in place - Crew rest and duty periods, flying hours limitations (we use 2 times ERF), currency requirements, go-no-go criteria (weather, illum etc).
6. Some may disagree but i feel Instrument Rating is necessary.

These are the basics we should insist as we are the ones in the aircraft. EMS should all be NVG equipped (if not already so). Lives saved outweight the cost many mnay times.
I don't know about the UV lighting Cougar, but I think your list is good for starters...
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Old 3rd Nov 2006, 01:45
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Cougar,
Good list in parts, but what is wrong with the SC-196 requirements?
Why "re-invent the wheel"?

vpaw pilot: thanks mate, will keep an eye out for them. Do they hold the TSO or will they get CASA approval? More importantly - have you guys achieved the dream yet? We are all desparate for you guys to get going and provide that industry break through.
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