crewmember shall be equipped with and use NVGs during landing at unim‐ proved sites to assist in obstacle identi‐ fication and clearing and during takeoff when operational conditions permit.” Because of this limitation, many opera‐ tors that would normally operate sin‐ gle‐pilot (or NVG pilot only) in a given area are now required to operate with an additional NVG equipped crew‐ member when conducting NVG opera‐ tions. The dilemma is further exagger‐ ated 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 avia‐ tion NVG use is comprised of much more than air medical and law enforce‐ ment operations. Many other civil oper‐ ations such as fire fighting, utility, and on‐demand transportation benefit from the use of NVG technology. Many of these operations are routinely con‐ ducted with a pilot‐only crew during all flight profiles, like day and night‐unaid‐ ed, except for NVG.


Military aviators accumulate thou‐ sands 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, per‐ ception of challenges associated with NVG usage may differ due to experi‐ ence level and proficiency in crew con‐ cept. Additionally, the type of opera‐ tion 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 opera‐ tions. 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 bal‐ ance between implementation and reg‐ ulatory oversight is critical. Rules, poli‐ cies, 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 technolo‐ gy and any operator that has a night fly‐ ing 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 mea‐ sure 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 train‐ ing 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 opera‐ tions are evaluated annually in accor‐ dance 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 crewmem‐ ber. The pilot must demonstrate the ability to conduct these maneuvers without assistance.


However, there is a difference between training for a task and con‐


ducting 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 com‐ plexity of certain NVG flight profiles may not be prudent for pilot only oper‐ ations.


Limiting all NVG operations below 300 feet AGL to multi‐crew operators may be an extreme brush stroke of pol‐ icy. A limitation to pilot‐only NVG oper‐ ations should have a practical relation‐ ship to the safety of flight. Many operators believe single‐pilot landing and takeoff from an un‐ improved landing site can be conduct‐ ed 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 safe‐ ty. Having a second set of eyes proper‐ ly trained to support NVG flight opera‐ tions may be the best possible solution. This is the position that many FAA per‐ sonnel 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 sec‐ ond 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 proce‐ dures to include mandatory multi‐crew requirements for most of their opera‐ tions. Logically, implementation of NVGs into the civilian industry was facil‐ itated by heavy military influence. Most of the FAA personnel selected for NVG implementation into civilian aviation were selected based upon their previ‐ ous military NVG experience. For this reason, what many believe to be sub‐ jective opinion for multi‐crew NVG operations below 300 feet AGL became policy.


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