Posted 12 years 258 days ago ago by Admin
By Randy Rowles & Adam Aldous
The NVG Dilemma
Night flight usage and technology have grown exponentially in the past few years and the dilemma from FAA mandate to have a minimum of 2 crewmembers for NVG flight operations below 300’ AGL has evolved as well. There are two general sides taken in this discussion. The first is the belief that NVG operations can be conducted safely with only the pilot using NVGs, while others believe that NVG flight operations below 300’ AGL is a multi-crew task. Each side of the discussion believes the alternative to be undesirable. In this article, we will take an objective look at this issue.
The dilemma stems from the current verbiage, imparted by the FAA, contained in the Limitations Section of most NVG aircraft lighting STC holder’s rotorcraft flight manual (RFM) supplement which states “an additional crewmember shall be equipped with and use NVGs during landing at unimproved sites to assist in obstacle identification and clearing and during takeoff when operational conditions permit.” Because of this limitation, many operators that would normally operate single-pilot (or NVG pilot only) in a given area are now required to operate with an additional NVG equipped crew-member when conducting NVG operations. The dilemma is further exaggerated due to the fact the same operator would not be restricted to the above limitations for operating in the same given area without NVGs.
It is important to note that civil aviation NVG use is comprised of much more than air medical and law enforcement operations. Many other civil operations such as fire fighting, utility, and on-demand transportation benefit from the use of NVG technology. Many of these operations are routinely conducted with a pilot-only crew during all flight profiles, like day and night-unaided, except for NVG.
Military aviators accumulate thousands of NVG flight hours having only operated in a multi-crew environment while the civilian aviator counterpart may spend their entire career as the sole pilot on board an aircraft. When each is introduced to NVG flight, perception of challenges associated with NVG usage may differ due to experience level and proficiency in crew concept. Additionally, the type of operation or flight task and the way in which they are conducted while using NVGs may differ from military to civil use. These fundamental experience related differences may provide subjective variation(s) in opinion on the issue of pilot-only versus multi-crew NVG operations. The issue should not be one of “Who’s right,” but rather “What’s right.”
As the use of NVG technology increases within civil aviation, the balance between implementation and regulatory oversight is critical. Rules, policies, and guidance provided by the Federal Aviation Administration (FAA) and other regulatory bodies along with NVG implementation standards by operators must be able to adapt to the new technologies of tomorrow. In addition, the regulations should also provide flexibility so the operator can decide how to best implement this technology into their operation.
Pilot-Only NVG Operations
The FAA has accepted NVG technology and any operator that has a night flying requirement is a potential user. Many operators do not have the luxury of an additional crewmember on-board nor is there a requirement to do so. NVGs would provide an enhanced measure of safety for these operators.
For the most part, NVG operations are permissible with only the pilot using NVGs with the exception of flight operations below 300 feet above ground level (AGL). This is usually a Supplemental Type Certificate (STC) limitation of the aircraft(s) NVG lighting kit, but may include the operator’s Operating Specifications (OpSpec) as well. It is within this flight environment the FAA deems a second NVG equipped crewmember be required.
The flight training an NVG pilot receives is typically not inclusive of an NVG equipped crewmember. NVG pilot training is often conducted with only the pilot and instructor on-board the aircraft. The pilot will be taught to fly with NVGs and measured against a set of FAA standards applicable to the type of pilot certificate held. This flight training includes takeoff, landing, hovering and other operations below 300 feet AGL while using NVGs. The pilot must demonstrate the ability to conduct these maneuvers without assistance.
Pilots conducting on-demand operations are evaluated annually in accordance with the requirements of the Federal Aviation Regulation (FAR) Part 135. If the pilot will utilize NVGs during these operations, a portion of the annual flight check will be conducted while using NVGs. This annual check will be conducted with the pilot only not requiring a second NVG crewmember. The pilot must demonstrate the ability to conduct these maneuvers without assistance.
However, there is a difference between training for a task and conducting a task as a single pilot. Certain flight profiles have a multi-crew requirement. One such flight profile is hoist operations. The pilot can train and be evaluated on aircraft control while in the hoist profile, but the hoist operation requires a crew. The complexity of certain NVG flight profiles may not be prudent for pilot only operations.
Limiting all NVG operations below 300 feet AGL to multi-crew operators may be an extreme brush stroke of policy. A limitation to pilot-only NVG operations should have a practical relationship to the safety of flight.
Many operators believe single-pilot landing and takeoff from an un-improved landing site can be conducted safely through risk management, training, and standards evaluation.
Multi-Crew NVG Operations
Anyone that says “I don’t want or need a crewmember’s assistance” may be shortsighted to the benefits in safety. Having a second set of eyes properly trained to support NVG flight operations may be the best possible solution. This is the position that many FAA personnel within the Rotorcraft Directorate have taken on the issue. However, the FAA did not exclude any particular flight environment from NVG operations and have developed policy within the STC process directing a second set of eyes required only for near-the-ground NVG flight profiles below 300 feet AGL.
The use of NVG technology in flight operations came from the military. Through years of trial and error, the military developed NVG flight procedures to include mandatory multi-crew requirements for most of their operations. Logically, implementation of NVGs into the civilian industry was facilitated by heavy military influence. Most of the FAA personnel selected for NVG implementation into civilian aviation were selected based upon their previous military NVG experience. For this reason, what many believe to be subjective opinion for multi-crew NVG operations below 300 feet AGL became policy.
The question is whether this was a data driven decision or a decision based upon subjective opinion? No one within the FAA denies that subjectivity often drives policy. The policy surrounding NVG implementation is riddled with subjective perspectives.
What must be remembered is that the subjective opinion of FAA personnel regarding multi-crew NVG policy is often based on actual NVG experience of crew concept. As an industry, embracing such experience is paramount to safely implementing NVGs into civilian aviation. In many cases, the FAA admittedly defaulted to a more sterile, conservative approach to NVG implementation and policy development.
In 2000, the FAA approached RTCA, Inc. to research appropriate implementation options for NVGs into the civilian aviation industry. During these committee meetings, debates over pilot-only versus multi-crew NVG operations were had. Today we see the compromise of this debate. The FAA permits pilot-only NVG flight unrestricted throughout the United States National Airspace System. For NVG flights within 300 feet AGL of the earth’s surface, you will need a second set of eyes on NVGs to do it.
Are Two Heads Better Than One?
Not always! To be an effective NVG crewmember, the individual needs to have aptitude, attitude, and experience. Initially, experience is substituted by training. The quality of an NVG equipped crewmember begins in the classroom. To develop the skills needed to function as an NVG equipped crewmember, a comprehensive NVG training program is paramount. A poorly trained NVG crewmember is a liability to safety much like a poorly trained pilot.
If using a second NVG crewmember, a set of requirements that mirror those of their pilot counterparts need to be mandated. These requirements may include 1) a minimum number of NVG flights before acting as second NVG crewmember, 2) a minimum number of NVG flight operations within a specified timeframe, and 3) a set procedure to regain NVG recent experience if time between uses is lengthy.
Although not regulatory, many NVG operators have proactively implemented procedures to address these issues.
To use a baseball analogy, a catcher is behind home plate based on the belief the batter will periodically miss the ball. Having an NVG equipped crewmember would then be prudent if there is a belief the pilot may miss an obstacle or other hazard to the flight. However, in batting practice a fence is used for the same purpose as a catcher. For pilot-only NVG operations, pilot-only policies and procedures would have the same affect and ensure safety of flight operations.
A recently conducted NEMSPA survey of nearly 700 HEMS pilots showed that the vast majority of pilots preferred having a second set of eyes during NVG operations. However, that same survey revealed that those same pilots did not want to be restricted from accomplishing an NVG operation simply because that second crewmember was not available, or did not have NVGs available.
Whether an operation chooses to operate NVGs pilot-only or multi-crew should be the decision of the operator. Either operation can be conducted safely with proper training, procedures, and oversight.
This author believes proactive oversight providing for pilot-only NVG operations below 300 feet AGL would require a similar thought process of a single-pilot IFR flight program. Not all aircraft may be appropriate for pilot-only NVG operations. In those cases, the operator would decide what is best for them and the equipment must meet the requirements.
It is not possible, nor practical to set a single standard for all NVG operations. Simply based on the diversity of type of operations within aviation, flexibility within the NVG oversight community would prove beneficial to all.
Randy Rowles is the VP Business Development & NVG Training Programs for Night Flight Concepts of Port St. Lucie, Florida. He is also an active EMS pilot with Children's Medical Center of Dallas. He serves a Board Member for NEMSPA and is the Chairman of HAI's Flight Training Committee. He and his wife Samantha reside in Ft. Worth, Texas.