Part 91 NVG Operations

[lbingham]

All,

I work for a part 91 operator who is wanting to get into NVG use. Myself and the owner both fly the Agusta A109E we are wanting to utilize. My question is, what are the requirement in order for us to legally operate with night vision goggles?

Background: I am a military RW aviator with a couple hundred hours of NVG experience. I am not a novice and am very comfortable flying helicopters solely referenced to goggles. I am just looking for the legal requirements for us to operate part 91. 

[helonorth]

I don't think there is much difference between part 91 and 135 as far as goggles are concerned. You will have to get the aircraft certified for NVG's which is no small or inexpensive task. Figure $20k for filters, installation and testing. I think the goggles themselves run about $10K a pop and they need to be inspected every 180 days. You will have to go somewhere to get the pilot training or maybe you can get somebody to come to you. You have to stay current or you will need a check out.

Unless you are operating off airport to unfamiliar LZ's at night (which is the only thing you will need them for, they are not much good for anything else), I would skip the goggles and just fly IFR at night. 

[Spike]

The last I remember, the requirements to fly NVG's are: hold a Private or Commercial Helicopter rating, a valid medical certificate, obtain 8 hours of ground and 6 hours of flight training.

Simply Google "helicopter NVG training" and you'll find a number of vendors who can provide the training and some of them can also provide the modifications to the machine. I've had personal experience with Aviation Specialties Unlimited Inc and Helistream and both were top notch.  

[Thedude]

4 hours ago, helonorth said:

Unless you are operating off airport to unfamiliar LZ's at night (which is the only thing you will need them for, they are not much good for anything else), I would skip the goggles and just fly IFR at night. 

Having flown both civil and military aviation I much, much prefer flying goggles over unaided. There are huge benefits with goggles even if you aren’t flying to unfamiliar off airport destinations. 

[iChris]

On 4/10/2023 at 7:50 PM, lbingham said:

All,

 My question is, what are the requirement in order for us to legally operate with night vision goggles?

 I am just looking for the legal requirements for us to operate part 91. 

For  Part 91 operations in your aircraft not under 91K or an LOA, no operational approval is required for NVG demonstration or training. Still, the equipment installation must have FAA approval, and the operator must meet the requirements for NVGs contained in parts 61 and 91, see below. The FAA Chief Counsel's legal interpretation below gives more insight to get you started. 

14 CFR: 91.205 ( h ),  61.51 ( k ),  61.57 ( f )( g ),  61.195 ( k ),  61.31 (k ) additional training.

Legal Interpretations & Chief Counsel's Opinions on this Issue.
https://www.faa.gov/sites/faa.gov/files/faa_migrate/interps/2011/Fasthoff_2011_Legal_Interpretation.pdf

Part 91 operators not operating under part 91K or an LOA do not require operational approval to conduct NVG operations. However, the NVIS installation must be FAA-approved, and the NVG used must be compatible with the NVIS installation. All pilots and operators, including those operating under part 91, must comply with the applicable NVG regulatory requirements in 14 CFR parts 61 and 91. 

Part 135 Operations. Follow the guidance in FAA Order 8900.1 Volume 4, Chapter 7, Section 4, Night Vision Imaging Systems.
https://drs.faa.gov/browse/excelExternalWindow/84622bd1-6443-4178-bba0-92ab0d89d5c6

 

Edited April 16, 2023 by iChris
correct link

[Spike]

"For  Part 91 operations in your aircraft not under 91K or an LOA, no operational approval is required for NVG demonstration or training."

With that, the next question would be, as a 91 operator, will a NVG vendor allow you to purchase goggles without having accomplished an "official training" grogram. Sure, money talks, but the liability aspect would be concerning....

[iChris]

On 4/14/2023 at 7:44 AM, Spike said:

"For  Part 91 operations in your aircraft not under 91K or an LOA, no operational approval is required for NVG demonstration or training."

With that, the next question would be, as a 91 operator, will a NVG vendor allow you to purchase goggles without having accomplished an "official training" grogram. Sure, money talks, but the liability aspect would be concerning....

In the United States, U.S. Persons (Citizens or Permanent U.S. Residents) may own and use Night Vision and Thermal Optics. However, it is against the law to take these devices out of the country unless specifically approved by the U.S. State Department with proper licensing. Night Vision and Thermal devices fall under the International Traffic in Arms Regulations (ITAR ). 

 Some sellers may have policies restricting their selling; however, it’s just that, policy and not regulatory. On the legal side, you’ll always have lawyers and judges that will blame the night vision goggles and goggle manufacturers instead of the bad judgment or mistakes of the individuals. 

Side note, Night Vision Goggles and Thermal Optics are described as major weapon systems capable of being configured for military use under 15 CFR Part 742, Supplement #7 (11)

 https://www.ecfr.gov/current/title-15/subtitle-B/chapter-VII/subchapter-C/part-742/appendix-Supplement%20No.%207%20to%20Part%20742

 

 

 

Edited April 16, 2023 by iChris
Add side note

[helonorth]

On 4/14/2023 at 10:44 AM, Spike said:

 

With that, the next question would be, as a 91 operator, will a NVG vendor allow you to purchase goggles without having accomplished an "official training" grogram. Sure, money talks, but the liability aspect would be concerning....

Concerning to who? I guess if they want to sell me some goggles, that would be their problem, not mine. 

If I had an IFR twin, I would fly IFR most of the time at night including doing instrument departures and avoid off airport stuff altogether, especially confined areas. The departure from an off airport LZ is the most dangerous part, in my opinion. I would avoid it like the plague unaided. If you do routinely land and take off off-airport, I would definitely get set up for NVG's. I knew a pilot that departed a golf course at night and didn't get far, killing both her and her passenger. You just don't know what's out there weather-wise until it's too late. Goggles can allow for a safe aborted take off from a confined area. 

So yes, NVG's are doable for anybody. Just a question of time and money. 

 

Edited April 15, 2023 by helonorth

[Spike]

22 hours ago, helonorth said:

Concerning to who? 

The vendor who sells the goggles.....

If a vendor sells a pilot goggles without ensuring the pilot is competent to use them or, the aircraft is properly modified for google operations and the pilot crashed and died while flying with said goggles, a jury may find the vendor liable for selling the pilot goggles without training or aircraft mods............ 

One of the goggle suppliers mentioned above required the training and mods to purchase to goggles. Plus, the STC for the aircraft mods stated particular required pilot procedures while operating with goggles. It's unknown if all goggle suppliers require this level of protection (for themselves).  That said, like guns and drugs, one can probably purchase goggles from someone, somewhere and blaze their own trail..... 

[helonorth]

2 hours ago, Spike said:

The vendor who sells the goggles.....

If a vendor sells a pilot goggles without ensuring the pilot is competent to use them or, the aircraft is properly modified for google operations and the pilot crashed and died while flying with said goggles, a jury may find the vendor liable for selling the pilot goggles without training or aircraft mods............ 

One of the goggle suppliers mentioned above required the training and mods to purchase to goggles. Plus, the STC for the aircraft mods stated particular required pilot procedures while operating with goggles. It's unknown if all goggle suppliers require this level of protection (for themselves).  That said, like guns and drugs, one can probably purchase goggles from someone, somewhere and blaze their own trail..... 

Once again, I'm not going to worry about somebody else's percieved problem. If you're so worried about their liability, don't use goggles. You are required to have the training in order to use them, though. Does Bell require you to show them a pilot certificate before they will sell you a helicopter? Why are we even talking about this. 

[Spike]

Nice to see some of us still stop by and provide opinions.......:-)