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“I’m an NVG Instructor”…Are you sure?

Posted 8 years 335 days ago ago by Randy Rowles

In October 2009, the Federal Aviation Administration (FAA) released new regulations related to the use of Night Vision Goggles (NVGs) in the US National Airspace System. Inclusive of these newly minted FARs was guidance on NVG pilot training and certification contained within FAR Part 61. Additionally, specific criteria was established to be an NVG Instructor. Although the regulation is clear as to the specific eligibility requirements to be an NVG Instructor, the guidance to provide an NVG instructor the required endorsement per FAR 61.195(k)(7) is non-existent. Since the release of these new regulations in 2009, FAA personnel have struggled to find unity among their colleagues on this issue.

With the release of these new regulations, every NVG pilot and instructor had to find a method of compliance to continue operating in the same manner in which they had been prior to the release of the regulations. With the pilots, most were either conducting Law Enforcement or Air Medical operations. The Law Enforcement pilots were provided relief in FAR 61.31(K)(3). Since most Air Medical pilots operate under Part 135, they were approved under their company Part 135 NVG training program. All other pilots desiring to operate with NVGs would simply have to find an Authorized NVG Instructor and receive training identified in FAR 61.31(K)(1-2). So who is an ‘Authorized’ NVG Instructor? This answer has been elusive…until now.

FAA Inspectors that were working with operators already conducting NVG training simply provided each instructor an endorsement under FAR 61.195(k)(7). All that was required was a simple review of those items required by FAR 61.195(k)(1-6), and the instructor was qualified…period. However, as the NVG industry has expanded and more NVG instructors have been trained, the FAA has taken a second look at the process by which an NVG instructor is endorsed. In many cases, NVG instructors were providing the NVG instructor endorsement to other NVG instructors they had trained. Although not uncommon among other endorsements contained with FAR 61.31 such as a tail-wheel endorsement, this was not the intent of the FAA.

In early 2014, my status as a Designated Pilot Examiner (DPE) with NVG Instructor Authorization was removed. Since I too was a victim of the lack of clear guidance to support the NVG regulations in the October 2009 release, I contacted the FAA in Washington DC on this issue. In an effort to remedy the situation or at least obtain some guidance, I reached out to the Airmen Certification and Training Branch AFS-810. I received an answer on May 21st, 2015.

In an email received from FAA Office AFS-810, FAA staff clearly agreed that this issue was significant and that guidance to provide the remedy to this situation is forthcoming. However, since there is no standard for the NVG Instructor endorsement under FAR 61.195(k)(7), nor any guidance to determine qualifications for the person authorized to provide the NVG Instructor endorsement…there is NO person authorized to provide this endorsement. The FAA FSDO Manager does have the ability to select a “best qualified” FAA Inspector for such a purpose, however the endorsement that would be issued does not exist at this time. Once developed, the NVG Instructor endorsement will be added to AC 61.65.

I know this article will bring more questions than answers. In August 2015, NightCon, the Night Vision Goggle (NVG) industry’s only civilian conference will be held on August 27th and 28th in Dallas, Texas. During NightCon, representatives from the FAA and other international regulatory agencies, NVG operators, service providers, and educators will meet to discuss this issue among many others. Come join us to have your voice heard and remember…your opinion matters!

If you have any questions related to the subject matter of this article, please email me at [email protected]. Please write NVG Instructor Endorsement in the subject line.

About Randy: Randy Rowles has been a FAA pilot examiner for 20 years for all helicopter certificates and ratings. He holds a FAA Gold Seal Flight Instructor Certificate, NAFI Master Flight Instructor designation, and was the 2013 recipient of the HAI Flight Instructor of the Year Award.  Randy is currently  Director of Training at Epic Helicopters in Ft. Worth, Texas.