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I have read this thread with great interest. I am a Police Air Observer and on a few occaisions the pilot has been flying quite happily in IMC using radar vectors and an an ILS approach back to our base.
I would much rather do this than attempt a landing in the dark in poor weather is some random field in the middle of nowhere. I am also perfectly happy if the incident merits it to deploy the aircraft in legally flyable conditions knowing full well that there is a possiblity that the weather local to our Base will close in behind us. We all know police work is not black and white and we all should use the combined experience of the pilot and the crew to make a decision to deploy the aircraft in marginal conditions. One of the main reasons for declining police tasking is the weather, and Units around the Country take flak from ground based colleagues on a regular basis. In my opinion Air Support Units make themselves as available as possible as in the current finacial climate, otherwise observers and pilots alike could be looking look for work elsewhere. Bring on full Instrument ratings and we get on with the job that we are paid to do.:ok: |
"shy -
If they don't like my driving, they should stay off the sidewalks!" :ok: My grandmother often used to say whilst driving her old Ford "Look at that bl**dy idiot driving on the pavement (sidewalk)!" We used to scream: "Grandma, it's because you are driving on HIS side of the road!" She never had an accident, but saw lots...... :ooh: |
RichiePAO, a provacative little post and I'm more than happy to take the bait. If your pilot has an I/R and your 135 is certified for IFR then no probs. However, I assume that you would have mentioned that. So...if your pilot does not have an I/R (and your aircraft is not certified), then ( aside from you stitching him up ;) ), if he is making a decision to go IMC (when there is a possibility that he could land), then he is (as I understand it)
a. not flying in accordance with his licence b. not flying in accordance with the PAOM /ANO/I Spy book of Civil Flying c. not flying in accordance with the Flight Manual d. not flying in accordance with the aircrafts C of A e. probably flying outside the units insurance cover (although they are very flexible and understanding, those insurance companies) I hope the next time you are after someone who may not be driving in accordance with the Road Traffic Act, you show as much understanding. Now, it doesn't matter whether the pilot is capable of flying IMC or whether he had bags of IMC time in the military if he is not Instrument Rated (and current on type), he is not allowed to fly in IMC. Of course, if he went inadvertant IMC, a radar recovery would be in order, maybe he should at least declare a PAN (that should get some responses!:p ) and I would expect to see at least a chirp report!! |
This subject was introduced by Kalif who poured scorn on the need for NVG for the front of the helicopter and gently inferred that instrument ratings were preferable.
The fact is that the basis for the operational requirement for NVIS and Instrument Ratings are totally different. The intersection of the two issues occurs only when considering the possibility of inadvertent IMC. The main raison d’etre for NVIS is to enhance visual contact flying at night and, as far as possible, to reduce the probability of inadvertent entry into cloud (the fact that cloud ceiling is used in forecasting always introduces the possibility of cloud below the indicated level). Equally, the use of NVIS does not reduce the existing requirements for landing away from base at night - also regulated in JAR-OPS 3 (and the PAOM). When the JAA was considering the introduction of regulations for NVIS it formed a working group of interested parties from: operators with existing knowledge of NVG (REGA of Switzerland, BGS from Germany etc.); and European NAAs. This group worked on the subject for a couple of years and produced a text that was acceptable to all parties. REGA were particularly welcome because of several decades of experience and because, in Switzerland, punching up into IFR when encountering cloud is never an option. The whole basis for the work was the reduction in workload for flying at night in VMC - i.e. it did not permit the reduction of existing weather limits but increased the safety of night operations. As explained by many on this thread, the use of NVIS is constrained to enhancement of night flying - particularly in those areas where there is a distinct lack of ground references (light sources). (As a side issue, JARs do not have a minimum light requirement or, as in FARs, the requirement for visual contact with light sources on the surface.) As a matter of interest, the whole working group decamped to Switzerland at one stage to experience night operations using NVG with REGA. We debated the requirement for Instrument Ratings but, as with the parallel discussions in the CAA after the unfortunate Harding accident, we concluded that that to obtain and, more importantly, maintain recency and currency on operations that were essentially conducted visually would be too expensive and would not be appropriate (mainly in Europe we were considering NVIS for HEMS - although we thought that Police work would also benefit). The work culminated in the acceptance of the RTCA MOPS and the production of a TGL giving guidance on Operational Approval; this has been available as Leaflet No. 34. Night Vision Imaging Systems (NVIS) Operations since June 1st 2003. The document consists of six parts:
This document, prepared by a Sub-Group of EUROCAE Working Group 57 “Night Vision Imaging System (NVIS) Standardisation” is an abbreviated and modified version of the RTCA Report DO-268 “Concept Of Operations – Night Vision Imaging Systems For Civil Operators” which was prepared in America by RTCA Special Committee 196 (SC-196) and approved by the RTCA Technical Management Committee in March 2001. The EUROCAE Working Group 57 (WG-57) Terms of Reference included a task to prepare a Concept of Operations (CONOPS) document describing the use of NVIS in Europe. To complete this task, a Sub-Group of WG-57 reviewed the RTCA SC-196 CONOPS (DO-268) to assess its applicability for use in Europe. Whilst the RTCA document was considered generally applicable, some of its content, such as crew eligibility and qualifications and the detail of the training requirements, was considered to be material more appropriately addressed in Europe by other Joint Aviation Requirements (JAR) documents such as JAR-OPS and JAR-FCL. Consequently, WG-57 has condensed the RTCA CONOPS document by removing this material which is either already addressed by other JAR documents or will be in the future. In addition, many of the technical standards already covered in the Minimum Operational Performance Standards (MOPS) For Integrated Night Vision Imaging System Equipment (DO-275) have been deleted in this European CONOPS. The JAA is grateful to RTCA, Incorporated, for permission to reproduce text from RTCA DO-268 in this CONOPS applicable for NVIS operations in Europe. |
Semirigid wrote:
" And finally, are you suggesting that non-rated pilots fly IMC in controlled airspace for an approved approach? That is about as daft as saying that when your cockpit is NVIS you just strap on some NVG's and go!!" TC actually wrote: " While on task you go inadvertent IMC... For the non IR pilot: (a) he trains for this eventuality either for a self let down (like us), or diverts for a radar vector to an ILS (same scenario as yours). Without an IR." Note "inadvertant IMC". |
JimL
I don't want to get to deep, because I essentially agree with what your saying and its late, and I am several beers worse for wear, however, Your comment/suggestion that JAR's should stipulate a minimum light level, is like what a lot of what many people are pushing, impractical! For a long time the military pushed 2 millilux as the number, but on a cloudy night with no moon, when 2 millilux was not achievable? Then we just use ambient/artificial light! Such a get out, while fine for the military would never work in civy street. However, the idea that the pilot assess the light levels, as he does the weather in a helicopter away from an airfield, is essentially sound. We need to keep the argument sensible and achievable. All helicopter pilots with NVG experience will agree that flying in the dark without goggles is like driving a car on an unlite road without lights, ******* stupid! NVG need to be, and will soon be accepted in civil flying, and the sooner they are available to police units, the better. SiClick:yuk: |
Correct me if I'm wrong but I think the original post raised the topic that pilots should not be trained on NVGs but the 'cheaper' solution of an IR would/should suffice?
Following the originator's thread, the ideal progression would be to follow the Obs instructions to the scene of the chase then use the radalt and cheaply-installed hovermeter to lower onto the scroat's roof. To what end? We've all received banter for not doing a shout if the wx's dog (and probably flown when we shouldn't have) but some brave person mention the go/no-go decision. If the wx is that bad that you need goggs, then you are probable having to fly too low in the first place, at a speed that mocks your 'safe single engine' parameters and frankly, pushing the limits - and for what, some scroat that will be cautioned at best!! Yep, been there and done it and fully aware that once the user uses goggles and accepts certain jobs then it opens the gates for abuse by the people who account for it. Those in the know, know how much lip service is paid to millilux limits, nvg currency and crew competency. Yes, as a pilot, i would like a set of NVGs in a box by my seat, or even attached to my head, but, as someone who does not wish to rely on 2 retina-burning scopes strapped on my face, pray they stay switched OFF. If money was no object, then we should all have an IR, to use as and when. Are you telling me that without an IR we cannot fly a 180 or stay upright? Heavens, your training needs help. Safe flying folks! |
[If the wx is that bad that you need goggs, then you are probable having to fly too low in the first place, at a speed that mocks your 'safe single engine' parameters and frankly, pushing the limits]
The wrong idea about night vision aids here. They AREN'T a way of flying in worse weather, not what they were invented for. Who on earth taught you that NVG technique? |
handysnaks
RichiePAO's 135 is a SPIFR T2 and some of the pilots who fly it do have IRs, mainly relief pilots who also do IFR charter work or ferry flights. FNW :ok: |
Sorry - very late to the discussion, but it can't be left without comment.
Concur, in many respects, with TC & others who see NVG as the step to take BEFORE IR, if the latter can possibly be justified, operationally or financially. The one thing hardly mentioned to date (XMT Manch/L'pool) is the operating area. For those operating around Cumulo-lumps, one can only be supportive of the NVG argument. However, for those whose closest proximity to Cumulo-alluvialsand is 500' (at 1000' QNH) over the whole operating area, and further beyond, the argument is less clear - and there is even less excuse for inadvertent IMC and, by inference, IRs. For flat-landers, especially with 80+% ops in areas of significant cultural lighting, NVG or IR can only be regarded as an expensive luxury. There are those who may frequently land ad-hoc at night (normally in more remote (& probably lumpy) regions) & those who do so less than once a year. For the former, NVG make sense (if the CAA allow below 500'), for the latter, save your cash. Some reckon you could land more often with NVG - but why? The helo invariably exerts a more effective circle of influence from 1000' than grubbing about in the mud when there are troops on the ground anyway. Re the IR discussion: - whose Force can justify the initial training expense (TC, 14 Nov 10:30), as well as the currency requirements, when it's so infrequently used in anger. None of the Police kit works through cloud and we remain better orientated VCF below, en-route to a job, than hopping up above & letting down through the goo into goodness knows what. In the flat-lands the goo's the same all over, so no benefit there whatsoever. Massive cost to maintain currency though, as well as extra downtime/training hours on the Police budget, when you're trying to remain available to get the job done each day. At least NVG operators can keep current AND do the job. And finally - for those "lucky" enough to live on a real airfield, where IR procedures can be practiced regularly, don't forget those who aren't close to such luxuries. Flying to/from the equivalent of a well-lit frigate flight deck in the middle of the blank stuff might be an argument for NVG, but if it's lit i.a.w. CAA / PAOM guidance anyway, just devoid of electronic aids, it's not a problem. All in all - horses for courses. NVG won't significantly benefit everyone but it makes absolute sense for some units/areas, especially if allowed down to the deck. But IRs? An unjustified operational (and financial) burden, unrelated to the job we do. And before you ask - I've been doing the job for enough years, don't have an IR, have not flown NVG in anger, and have an equal number of landings & take-offs in my log book. I do pay taxes, however, and would be pleased to see some of the dosh going to those who can benefit realistically.:ok: |
And that is a direct reflection of what I said before: our background and experiences determine our outlook and until we get some experienced late generation NVG pilots into positins of influence, zorabs view will continue to prevail. Sadly, despite EVERY NVG pilot/crewman spouting the benefits (and some the necessity) of NVG, we continue to wallow in this doubting phase whilst more of our brethren fly into the ground.
Like the longline parallel I drew earlier, we aircrew are often slow at running with new ideas, prefering to think that what we do now is the best. Same reason we keep having the same accidents: we are reluctant to learn from other peoples mistakes and have to experience it ourselves to become believers. Given that CFIT is our second biggest killer (wires is number 1) why dont we spend money to address that? Zorab, perhaps instead of doing autos, tailrotor failure practices, etc, etc, that money could be put toward adressing the real killer: CFIT. When you deride NVG or IR as a "luxury" I would love to hear your take on all the money spent on training flights to protect us from a far smaller danger. |
Enhanced Operational Effectiveness
It seems to me the only people with reservations about flying NVG are those with no or minimal experience flying NVG. The thread so far has focussed on IF quals vs NVG qual / refit etc.
I think there are compelling operational reasons to use NVG, and focus training on IIMC recovery. If companies and the pilots working for them are conducting police or EMS or other tasks at night VFR, then they must have a set of checks and balances in their ops manuals / SOP / CAR. Not knowing those regulations, my gut feel is that a lot of those operating restrictions could be relaxed or removed if the crew use NVG. That is, either the same job could be done more safely, or more of a service could be provided. NVG ops are more analogous to day ops than to night (await storms of protest), so long as suitable legislation regarding weather and recovery plans are in place. It is a furphy to say that NVG 'suckers' you into cloud. The fact is that you can actually see through thin layers of cloud on NVG, so it IS possible to go into cloud on dark nights with min ground references. The reality is that use of your searchlight, or any ambient illum enables you to see the cloud before you lose visual reference, and NVGs allow you to descend or turn away WITH visual reference. In the same situation NVFR you would go IIMC, or you wouldn't be there in the first place because of the wx. As I said before, you can provide more of a service, more of the time on NVG. |
Helmet fire, you miss my point, or I didn't put it clearly enough.
My main drift was that NVG should be the first port of call in all cases; but that an IR comes a very poor second in the overall operational and financial equation. I am quite in agreement that NVG are an excellent aid for many operators, but they shouldn't be forced on all. We may be flying the same battle but we're not doing it in the same terrain. For those who have undulating T to FC'dI, I can only concur that there is real merit. For those whose T is flat and who operate (XMT T/O & Landing in pre-designated sites) above 500', the risk has to be balanced. I'm not a Luddite but I can't see merit in buying kit that the CAA won't let us use properly anyway - or certainly that's how it appears to date! |
Zorab 64,
I agree with the point about houses for courses. A blanket Home Office edit will be very expensive and will not be of benefit to all units. But I must remark on a couple of your statements: Quote: In the flat-lands the goo's the same all over. Those who fly around the Cotswolds, South Downs, Chilterns etc. (not mountains, just hills) will know the effects of orographic lifting. Those by the coast will know that coastal effects can come a long way onshore. Weather can be very localised for a variety of reasons, that is why there is a 30 minute (soon to be 60) requirement for instrument practice. Quote: Massive cost to maintain currency, Sorry but this is were I throw my teddy out of the pram:mad: Currency is maintaned by your normal flying. You DO NOT have to fly a seperate flight to go and fly an ILS or whatever. With agreement with NATS Nav charges etc can be reduced even waived. Next year an hour will be flown every three months (give or take a bit), what about the cost and the disruption cased by that? I will concede that I did not make it clear that if your aircraft is not already IFR approved the cost of the upgrade is prohibitive. But if your aircraft is certified it is only common sense to certify the driver as well. Helmet Fire, agree entirely, we spend to much time on a remote possibility and far to less on what is proven to be the biggest killers of helicopters. And before many of you jump down my throat, yes practice engine failures etc, should continue to be part of OPC etc but wire CFIT avoidence should be a greater part of say line check? |
RichiePAO: With all due respect, observers can never be involved in the final go/no go decision to fly in marginal weather. They may have an opinion regarding the weather but the pilot will be the final arbiter.
Your senior pilot is an IR and no doubt you might get the odd relief pilot with an IR, hence your penchant for IMC flying. You are also blessed with being based on an airfield with procedural recoveries..luxury of luxuries. But I would suggest the majority of police ASU's do not have these facilities and taking off in marginal weather is both folly, unprofessional and impractical. We wouldn't be able to recover to base and all future tasking would be jeopardized. There was a meeting at the glass house yesterday with reps from the police/CAA/HO/commercial. It was the second meeting about NVIS. The first was about certification and this latest was about technical and training. There are many hurdles to overcome before full implementation, but it now seems that these hurdles are being dismantled rather than being errected! "Everyone" wants this to happen and it is hoped that the authorities will help rather than hinder...With an experienced, ex-police driver at the helm, I feel optimistic that common sense will prevail and that this long overdue enhancement to flight safety will see service, sooner rather than later. There can be no question - and as zorab stated, those whose terrain is not conducive to NVIS, should not be coerced into purchasing it. Ironically, the met (who are purchasing 3 x EC145's) will be specifying NVIS. NVG's will NOT be used to lower existing POM I weather and visual limits. Those will always be there as our safety nets. |
FNW, Ritchie PAO thanks for that (That is a relief!). In which case the first part of my answer stands
If your pilot has an I/R and your 135 is certified for IFR then no probs. ( What's it like to have a section 4?):p |
SRR - The Cotswold "Hills", South "Downs" and Chiltern "Hills" are all, by their suffix, not "flat"! Take a trip over to East Anglia to see "flat", an area also devoid of significant orographic causal factors.
Some units have already adopted 60 mins IFP in order to give them enough useful time using the IFR aids, and to get to an instrument approachable facility. IR currency (unlike NVG) cannot be maintained by normal operational flying - an efficient operation spends the least time getting to/from a job to allow max time on task, hardly conducive to en-route IR currency convenience. Yes, flying ILSs for currency may be possible, with minimal impact on operations, when in an appropriate area - it's what many units do already. Practicising holds etc. requires dedicated operational time & cost. Quote: "If your aircraft is certified it is common sense to certify the driver as well" - I would suggest is ammended to "If you have the kit to get you down safely, after inadvertant IMC, drivers should know how to use it" - which is exactly where we stand now - a sensible compromise which effectively & efficiently utilises the SPIFR machine's capabilities in the Police operating environment, improving safety at a sensible, risk managed, cost. |
You may have guessed that I have had some NVG experience, more than some less than others. I have had the pleasure of flying in 0.2 millilux at 25’ and although challenging not impossible. The idea of using NVG to allow for flight with reduced Wx minima, however should not be a consideration, and was not when I was in the Mill. What if the goggles failed, could the Police do there job in reduced vis and 500’agl, inadvertent IMC low-level would be interesting (remove goggles, revert to white light, terrain avoidance, establish on instruments, fly the aircraft, [not necessarily in that order]).
IMHO The Wx minima that we fly to now is fine to get the job done. NVG would be a valuable asset in some instances and for sure in rural areas. IF ratings would be great. Can I have all of the above please? RichiePAO You said, “I am also perfectly happy if the incident merits it to deploy the aircraft in legally flyable conditions knowing full well that there is a possibility that the weather local to our Base will close in behind us.” Poor decision making abilities I would say. What flying license do you have? Just interested in you qualifications re your post. |
I thoroughly agree with the above poster.
I was, in a prevous life, a QHI teaching NVG on an operational conversion unit. We were once (briefly) given revised / reduced weather limits for use whilst flying NVG. We very strongly objected because it meant that a pilot suffering a goggle failure had no other option but to carry out an IMC abort. Thankfully, common sense prevailed and the previous wx limits were reinstated. |
nvg in oz civil ops
the canberra refueller was telling me last night that CASA are about to release directions to FOI type staff for operations using NVG. Seems they came under pressure internally, from the standards talking committee and the safety forum.
Anyone else heard the rumour? Would be good if it was true. The eye. |
I too have heard that an NVG Compliance Instruction has been signed and delivered.
Without industry consultation. Good that someone (Victorian Police Airwing) is now able to conduct a sanctioned civil NVG operation in Oz. About time. Mike Tavcar (a contrinuter to these pages) deserves significant accolades for achieing this result. It has taken him over 8 years to get this far - well done Mike. But there are some small issues: Some of the provisions will place significant obstacles in the way of other operators possibly stopping their aspirations for NVG. Thus the flight safety benefits of NVG cannot be realised by the majority of operators whom need the kit. These factors were not of particular concern to VicPol operations, but they will be of significance to most others (QES aside), which unfortunately takes the gloss off the exemption. Secondly, industry was not allowed input into what has become a standard for the industry. How is that allowed to happen? :uhoh: |
Good to see some action, at least...sounds like you have a bit of info about the details, Helmet Fire; has some draft legislation been released?
Big job for CASA to get sorted out to bring goggles into general use for authorised organisations and rated crews, but surely the expertise is there around the world (and here) to do this with acceptable safety and expediency. |
Sounds on a par with the CAA in the UK!
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oz nvg's
katfish has also heard the rumour that CASA (Mick Haxell etc), have been told to make this a high priority, and we may very soon see a set of operating and training instructions. Like most of us, I believe it will raise the safety level of our night ops enormously. Possibly the best thing since electric gyros!
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Don't know if many of the CASA guys have done much goggling; that will probably be an issue in the implementation.
Also they are a double-edged sword, to use a well-worn cliche, in that people will expect them to be a magical cure-all without perhaps realising how limited they can be on nights with low ambient illumination. |
FYI
I don't know how old this is but read this for info.... (apologie for the large post, can't get it ti link)
Challenges for Global Aviation Operations Page 1 Handout #3 NIGHT VISION GOGGLES Topic: The hours of darkness add to a pilot’s workload by decreasing those visual cues commonly used during daylight operations. Night Vision Goggles (NVG) has provided the industry with the ability to see at night and enhance operations. NVG’s have been cited in several FAA/Industry studies as a means to prevent Controlled Flight Into Terrain (CFIT) accidents. Continuing technological improvements have advanced the capability and reliability of NVGs that FAR Part 135 on-demand operators have requested use of the NVIS in commercial operations as a tool for night. Night Vision Goggles (NVG) is the common term use for NVIS operations. The complete description and performance standards of the NVG and cockpit lighting modifications appropriate to civil aviation are contained in the Minimum Operational Performance Standards (MOPS) for Integrated Night Vision Imaging System Equipment (RTCA/DO-275). Currently, these systems consist of: • Night Vision Goggles (NVG) • Interior and exterior aircraft lighting modifications • Cockpit windows (e.g., windshield, windows, chin bubbles, etc.) • Crew station design and components • Radar altimeter Since NVG do have performance limitations, it is important that proper training methods and detailed operational procedures to minimize NVG limitations. Industry request. Discussion of Issues: Initially developed for the military, Night Vision Goggles are devices that collect light energy, amplify and present the light providing the operator with an enhanced view of the scene outside the aircraft, thus improving situational awareness during night VFR operations. Part 135 operators initially petitioned the FAA to allow NVG operations use in the late 1980’s. It was determined at that time that NVGs were not advanced enough to be utilized in civil operations. A later 1994 FAA study (DOT/FAA/RD-94/21, 1994) summarized the need for NVG by stating: “When properly used, NVG’s can increase safety, enhance situational awareness, and reduce pilot workload and stress that are typically associated with night operations.” Challenges for Global Aviation Operations Page 2 Handout #3 The military use of NVGs was to enable tactical Nap-of-the-Earth or low-level terrain flight at night. This is not intent of civil use of NVG. The intent of the FAA is to authorize the use of NVG to improve the safety of night-flight. This means that all FAR requirements must be complied with during a flight. The use of NVG will not enable any mode of flight which cannot be flown within the framework of the existing FAR’s. The civil use of NVG will be approved for the purpose of enhancing the operational safety. FAA determined that that NVGs are an appliance and require FAA certification and specific approval according to specific procedures outlined in 14 CFR part 21 and that the use of NVGs in Part 91 and 135 operations may only be authorized with specific FAA approval. The FAA worked with RTCA to define the training and certification of pilots and other crewmembers, aircraft, and for the development of a night vision goggle TSO to allow their usage in the NAS. The RTCA is a not-for-profit corporation formed to advance the art and science of aviation and aviation electronic systems for the benefit of the public. The organization functions as a Federal Advisory Committee that develops consensus based recommendations on contemporary aviation issues. Flight Standards has completed the development of operation specifications, to allow Part 135 Helicopter Emergency Medical Service operators to perform night vision operations. Initial Approval Process. When the military first started using NVGs, they initially suffered a high accident rate due to non-standardized training and equipment. When the decision was made to allow civil NVG operations, we were determined not to repeat the mistakes of the past, but to learn from it. Three major areas of emphasis were identified: 1) the goggles, 2) aircraft interior and exterior lighting, and 3) training. The FAA worked with RTCA and the industry for the development of a Technical Standard Order (TSO) for the goggles NVGs. RTCA also addressed the aircraft interior and exterior lighting and training issues. The FAA has also coordinated its efforts with the UK CAA, European JAA, EUROCAE, the Australian CAA and the US Department of Defense. The FAA also coordinated its activities with operators of NVGs, including other federal agencies and Rega, a Swiss air ambulance organization. CRITERIA The FAA determined that NVG’s would be used ONLY as an aid to VFR flight and that no reduction in VFR minimums would be permitted. Initial Operational Approval was limited to Limited to Part 135 Air Ambulance operators. This process required the use of the Flight Standardization Board (FSB) process for Challenges for Global Aviation Operations Page 3 Handout #3 certifying 14 CFR Part 135 operators to conduct operations and training in the use of NVGs. Once approved, the operator was issued 2 STC’s, one for the aircraft lighting modification, and a second for the training program. Operators were also issued Part 135 NVG Operations Specifications. Current approval process. We now have 5 years of Part 135 NVG operational history. The industry has been conducting training and operations with standardized NVG training programs. The Minimum Operational Performance Standards (MOPS) for NVG’s has been developed and published by RTCA, Inc in RTCA/DO-275. The NVG Technical Standards Orders (TSO) will be issued shortly. The FAA has published new handbook guidance to be used by principal operations inspectors (POI) when evaluating request for use of night vision goggles (NVG), evaluating a NVG training program, and Minimum Equipment List (MEL) and prior to the issuance of OpSpecs. The FAA Aircraft Certification Office is responsible for: • Approving the STC modifications of the aircraft. • The aircraft lighting and NVG installation. • The flight-tests for NVIS compatibility. • Rotorcraft Flight Manual supplement. Now only one STC approval will be issued for the installation of NVG compatible equipment (lighting). NVG INSTRUCTORS In order to maintain a high quality of instruction the operators approved training program requires all instructors to have a minimum of 100 HNVGO in equivalent NVG equipment. Potential for Future Work: Flight Standards has completed a rulemaking project, “Pilot, Flight Instructor, and Pilot School Certification Rules” which includes the establishment of pilot and flight instructor training, recency of experience, and qualification requirements to perform night vision operations. The FAA proposes to issue a NVG SFAR dealing with the following: • Defining night vision goggles and night vision goggles operations. Challenges for Global Aviation Operations Page 4 Handout #3 • Logging of NVG time. • Criteria and standards for logging night vision goggle time. • NVG recency operating experience requirement in order to remain PIC qualified for night vision goggle operations. • Training for operating with night vision goggles. • Night vision goggle proficiency check requirement in order to regain PIC qualified for night vision goggle operations. • Flight instructor qualifications for giving the PIC night vision goggle qualification and recency training requirements. • Certification requirement of aircraft and pilot in order to conduct NVG operations. Of note are the following....... “When properly used, NVG’s can increase safety, enhance situational awareness, and reduce pilot workload and stress that are typically associated with night operations.” The FAA determined that NVG’s would be used ONLY as an aid to VFR flight and that no reduction in VFR minimums would be permitted. The use of NVG will not enable any mode of flight which cannot be flown within the framework of the existing FAR’s. It will certainly be an expensive exercise for whoever takes it on when you take into account the issues as discussed in the FAA document. Aircraft modifications and approvals, flight tests, flight manual supplements, MEL's, Instructor training and approval, 100 hours NVG experience for instructors etc etc.................. |
This is an excellent, well overdue step for Aus. industry.
The jist of FAA guidance and control seems quite appropriate (although I can't open the link to read the detail). If the crux of it is that the operations will be conducted IAW with all of the existing rules for night VFR ops then the goggles will enhance safety. When combined with white light , the NVGs are an excellent aid for getting into and out of unprepared pads, in addition to many other chores. NVGs are a FLYING aid however; they are next to useless for searching. Gibbo |
Gio, I cant do the link thing either, but I am assuming it refers to the FAA NVG release in Feb 2004. As you point out, NVG will not reduce the wx minima for NVFR in the States, nor allow any mode of flight not currently permitted by the FARs, however, this is where we in Oz, and those in the UK have sufficient difficulty translating the FAA bits, and where NVG WILL permit increased flight profiles for us.
What are the wx minima for NVFR in the US? I have previously been told that they are not very prescriptive , and may be the same as for day. I do know that the NVFR requires a visible horizon which we dont in Oz. As I understand it, the fundamental difference in Oz is that we have a prescriptive Lower Safe Alt requirement, where as neither the USA nor NZ have. Instead, they have a visible horizon requirement that we do not. (No idea about the UK, how do you guys do it?). Thus, NVG will have a significant impact on our allowable flight profiles in that they will allow cruise flight at 500 ft, and do away with all the visual approach criteria, therefore saving time/fuel and money. As I understand what has happened in Oz is that a Compliance Instruction has been signed for the Victorian Police Airwing (VPAW). Unfortunately, that document will also be used as a standard exemption to apply industry wide, but the industry has been unable to be involved in its evolution. In other words, CASA have formulated a standard industry exemption with no consultation by claiming "client privledge" with VPAW. All quite legal and in accordance with the rules, but when seen in the bigger picture, it is hardly conducive to the consultative image they are trying to portray. So what we have now is a tremendous leap forward by officially condoning NVG flight, and we have an organisation (VPAW) that will be able to take up NVG when they can complete all the mods and training. As I said above, this is a significant achievement for VPAW and Mike Tavcar in particular - and he should be congratulated. On the downside, we now have a set of rules that are "Oz only", and do not conform to the logical FAA rules which is almost an absurdity given the push by CASA for us to adopt FAA style rules in all other areas. The document well suits VPAW and their resource rich environment, but it runs contrary to the wishes of the vast majority of the industry who supported adoption of the FAA regulations. Indeed, if some changes are not made, the exemption currently creates an unjustifiable cost barrier to the adoption of a far safer mode of flight. A slight disclaimer: I have still not seen the completed document, but I doubt those changes would have been incorporated. Lastly, some comments on the previous posts: Gio, despite your concern of outlay V benefits, 18 US HEMS organisations were approved for NVG and flew them regularly in preference to NVFR by Jun 2004. A further 30 have completed the necessary mods, completed training and documentation and were awaiting final FAA sign off (but there are so few inspectors capable of conducting this sign off). REGA in Switzerland have been operating NVG for more than 10 years. I would put it to you that NVG DO represent a significant cost/benefit ratio, or there are a lot of very wrong people. Does anyone know of an organisation that has been NVG for several years, then stopped due lack of benefit? AOTW, you have raised an excellent point, and I am still trying to find out if illumination has been mentioned in the compliance instruction. I think it is a failing of the FAA document that they do not have a millilux limitation. But also remember that we are now talking Omnibus IV technology as the stated minimum acceptable equipment, and I believe your experience was Omnibus III and lower, as was the vast majority of mine. I did not believe the improvement that the IV offered, and you would literally need to see it to believe it. But, it doesnt matter which omnibus: neither can amplify complete darkness, thus an illumination minimum may be something to institute as a risk management tool. Gibbo: "Useless for searching" is a big call. Certainly trying to find a covert enemy is next to impossible, or someone bobbing along in the ocean, or someone running through lit urban areas, but ANY light source on a lost/missing/crashed survivor will stand out like dogs balls. A torch can be seen for 10nm or more some nights. A strobe on a liferaft will be seen for 30 plus miles. A small fire from a crashed aircraft, invisible to the naked eye, will be seen for 5 plus miles. And, NVG will allow you to SAFELY fly through mountain valleys looking. I personally think they are right up there with IR, (I suspect probably even more useful but I have not used advanced IR) in civil applications for searches. |
Helmet fire is quite correct in his asumption about NVG vs FLIR. Having used both I have found FLIR to be effected greatly by enviromental/atmospheric conditions eg dust, humidity, sea spray and temperature meaning when an object becomes cold soaked particularly in water the limitations of FLIR become very apparent equally in hot conditions the same applys. Give me NVG any day but remember 6000 x black is still black.
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G'day Helmet et al,
'useless for searching' isn't intended as a wind-up and I agree with your points; a successful search can be perfromed under the conditions you described. The point I didn't expand is that IMHO the NVG should be used to get the A/C, crew and other assets to the scene, on job without contacting the ground or other obstacles. If it is a search job, by a dedicated SAR A/C then it should be suitably equipped with day/night camera, FLIR, RF locator or similar devices to complete the search. All of the tools should come together. If the NVG are assumed to be good enough to search, and they are the primary search tool, then a lot of hours will be wasted and a lot of missions will fail when nothing is found. Having recently used the latest gen FLIR (technology, not brand) I am sold on the kit! I haven't used current gen NVG, and would like to see the improvement over the Omnibus III. As I said, my observation is that the tool is great, but not a panacea. A step forward for the industry! A good topic for beers I think. :ok: Gibbo |
I guess I better put every one in the picture seeing that I have been intimately involved in the CASA approval of NVGs in Aust. and working towards this for the past 8 years!
1. The Compliance Management Instruction (CMI) 04/74 Version 1 for Night Vision Goggles for Helicopter Operations was indeed signed by Head of Compliance, CASA in November of this year. 2. A copy is available in all CASA regional offices (or so it should be) 3. IT IS NOT AN INDUSTRY STANDARD. It is a compliance matter only not a Standards regulation. It was drafted over the past 2 years in response to Victoria Police Air Wing's formal application to conduct NVG operations as a result of it's successful NVG trial conducted November 2002 (Post Trial Report available if you email me). 4. The CMI is to guide CASA Compliance to issue a concession to CAR174B to allow operations at night before LSALT (in Australia there is a rule prohibiting flight by anyone at night below a LSALT). 5. Until such time as CASA Standards can regulate NVGs through the normal industry process into Part 133 the CMI is an interim measure to start operating on NVGs now with some measure of control to allow maturity and experience to be gained by the civil sector. 6. Although this CMI was written in response to our application obviously it cannot be denied to anyone else, therefore anyone can apply for the use of NVGs in Australia if complying with the requirements of the CMI. 7. VPAW had a personal meeting with Mr. Bruce Byron, CEO of CASA last week to lobby for the regulatory process on NVGs to be given a higher priority so that it can be incorporated into the new CASR Part 133. This will require industry input through the DP and NPRM process and therefore will become the industry standard. Mr. Byron gave an undertaking to examine prioritising the regulation of NVGs. 8. The CMI has gone one step further than most regulatory operators overseas...there are two parts to NVG ops under the CMI, (a) Wx below Night VFR minimums and (b) Wx that is night VMC. In the former if wx is not VFR NVG ops will still be able to be done as long as the pilot is IFR rated and current and the aircraft IFR capable. In the later if the wx is VMC then only require a night VFR rating in a NVR capable aircraft. Also NVG flight can be conducted in all phases of flight from T/O to landing. 9. Two crew will be required during NVG flight in the front of the cockpit. This was a hard fought battle as CASA wanted two pilots but VPAW convinced them that this was unacceptable in the civil sector and a compramise was reached whereby the use of a NVG qualified pilot and NVG qualified crewmember can be used in lieu of two pilots. 10. Another battle was NVG training hours but CASA would not budge from a 10 hour endorsement for pilots and 6 hour endorsement for flightcrewmemember (an overkill for NVG civil ops but something that can be adjusted later once some experience is gained to argue otherwise). 11. The CMI as whole is a very workable document and goes further than other overseas regulatory bodies in some aspects of NVG use, especially in poor wx conditions (read IMC conditions). 12. During the NVG trial we looked at 6 objectives, one was SAR and AUSSAR was onboard. NVGs do allow effective searching at night and allows a more effective use of the FLIR especially in mountainous terrain. Instead of waiting for first light before launching (and hence more often than not looking for a body) the helo can be activated immediately to start a search therefore ensuring a better and more successful outcome for the survivor(s). The effective regulation and safe use of NVGs will not only enhance an operators capability, it will increase levels of safety in SAR, EMS and Law enforcement roles. |
Mike, thanks very much for filling us in.
I take it from your post that NVG ops below LSALT are allowed given appropriate pilot qualifications for VFR or IFR conditions as the case may be. What have you worked out in regards to being at low level on goggles with weather around and having to possibly get up to IFR LSALT for inadvertant IMC? This can be a bit of a bugbear in that you can be tooling around at low level in hilly terrain, for example, and find that the vis becomes unacceptable, then be faced with having to get up safely. I'm sure you have considered it, but would be interested in the policy re reduced vis, low light levels etc. Also, is it just the 6 hrs crewman NVG time you were fighting or the pilot time as well? I'd say 10 hrs isn't unreasonable for a pilot by the time you get general handling, emergencies and a bit of nav out of the way. Good on you for doing the hard yards to get it rolling. |
Mike,
I would just like to second Arm's congratulations. Well done to you for getting this through. I am certain this will open up avenues for Rescue, EMS and Police ops to enjoy the kind of safety NVGs afford. Well Done. |
Guys a couple of quick responses to your queries....
1. Although flight in wx less than IMC is now allowable with NVGs in Australia it comes at a price....not only are the crew to be IFR current and capable but you need an IFR helo. There is also an inadvertent IMC plan required before launching under these circumstances, which are mandated in the CMI. When you read the CMI you will find further restrictions, such as, flight into visible moisture is prohibited and storm cells are required to be avoided by 5 nm...requiring a wx radar. Anyhow things don't really change that much in your normal day practice....don't push it to the point of becoming IIMC. We found during the trial that cloud avoindance with goggles was very good and was not hard to avoid cloud. The danger is if there is heavy rain about one could easily suck themselves into embedded cloud. You have to learn to recognise increased scintillation on the tubes as possibly going into such conditions and decide to turn around. Personally I believe the chance of IIMC would be very rare but we have a policy at VPAW of a high level of IFR recency and awareness to overcome such events. We will also have an illumination policy in that when the ambient illumination levels fall apprecially due to cloud, etc that there will be an ASI restriction and use of landing/nightsun to improve illumination...we found that the landing light itself provides good illumination forward of the aircraft and at slower speeds it is easier to navigate on goggles on those very dark nights. I recall using around 80 kts on a really black heavy overcast night up in the bush, which was fine. It all comes down to common sense...if the conditions are deterioting and not looking good, its time to turn back and either find an alternative route or go home to fight another day (night). Pilots get unstuck because they push beyond their limits and qualifications/recency. 2. I lobbyed that the 10 hours for pilots should be around 7 hours as more reasonable for civil ops and 4 hours for flightcrewmember. Note that the CMI has further requirements...once you get your endorsement as a pilot that is not it...you can't go PIC on goggles until you have accummalated an additional 15 hours of ICUS NVG time. |
Mike,
What sort of information was included regarding aircraft lighting etc? Were the Vic Pol machines already kitted out for NVG ops prior to the trial? Cheers |
Rotorque,
For the Trial we developed with Oxley Avionics, England (a NVG cockpit company) a trial fit requiring no CAR 35 for trial purposes only. The fit was temporary and not suitable as a permanent fit. it worked very well and sanctioned by CASA prior to the trial. Actually it worked so well that it was a pity to pull it off. |
Merged threads.
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The UK CAA are not far behind you aussies.
They're looking at single pilot ops above 500' no need for a crew man to be next to him, but another option to fly <500' takeoff and land might need revisiting - hope not. 5hrs trng for pilots might be the entry level for NVG. Good news globally then:ok: |
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. |
Helmet fire:
Thanks for that. What surprises me most about issues like this, is the fact that 'authorities' dont take a leaf from other books. Why didnt the aussie CAA visit the JAA, or better still the FAA. Sit down with their equivalents and share ideas. Think of the time and effort saved. Simply cut and paste. If the yank model is so sturdy, then for christ's sake pinch it!! Too many ego's too much national pride. The big picture is being missed methinks. congrats for joining the real world, but with a little more homework, the grades would have been better? Our (UK) CAA seem to have finally switched onto this and are fully embracing european and american experiences... is it a coincidence that there is a fresh team in the CAA (H)???? Thank ther lord. |
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