Training & Security Group International, Inc.

P.O. Box 2603

Weatherford Texas 76086

www.tsgi09.com

817.901.9024

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Tactical Instruction Aviation Security Consulting

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Attention: U.S. Department of Transportation May 24, 2011

Docket Operations, West Building Ground Floor, Room W12–140

1200 New Jersey Avenue, SE., Washington, DC 20590

Subject: One-time field approval for a 337 and/or Petition for Exemption (FAR Part 11.15) to

FAR Part 91.205h

Reference: FAR Part 11, FAR Part 91, FAA Handbook 8900, FAA Part 135 and Form 337

TSGI seeks relief for a period of up to 6 months to allow sufficient time for it to acquire the 

necessary funding and complete modifications to bring its aircraft into compliance with the 

requirements for use of Night Vision Goggles. This "One-time Field approval” (Directive from the 

FAA) for a 337 be approved for use as per the previous rulings under 337 for Interior and Exterior 

aircraft lighting systems required for NVG operations FAR Part 91.205h. If applicable, TSGI, Inc. 

requests a Petition for Exemption (FAR part 11.15) to FAR Part 91.205h. TSGI, Inc. requests this 

“One-time approval and Petition for Exemption to apply to our training from May 23, 2011 

through December 20, 2011.

TSGI, Inc. requests this approval for exemption to apply to aircraft serial numbers:

o MD500D N775BD

o MD500E N13KJ

TSGI, Inc. will comply with this request per serial numbered aircraft with FAA order 

8900.1, Vol. 4, Chapter 9.

History of the FAA involvement with Night Vision Goggles concerning Federal Aviation 

Regulations: Over the past several years the FAA has accepted field approval of modifications to 

aircraft for the purpose of NVG lighting and equipment requirements under form 337. Recently 

the FAA has interpreted a statement for the FAR's part 91.205h that requires the operator to get 

the FAA's approval of Interior and Exterior aircraft lighting systems required for NVG operations in 

the FAA's handbook 8900.1 (figure 4-68) that requires Flight deck lighting changes to support NVG 

use, or any approvals related to NVG must have an STC (Supplemental Type Certificate). This new 

procedure makes all the previous 337 modification obsolete (there were 287 approvals). These 

Regulations and handbook procedures have been largely written with concern for FAR Part 135 

Medevac operators, because no one has attempted to work NVG training under FAR Part 91; and 

therefore the FAA has not fully addressed FAR Part 91 flight training. This gap in the FARs has

brought on a hardship TSGI, Inc.—the FAR Part 91 operator

Public Interest: TSGI, Inc. is currently under contract to conduct military flight training,

with a Department of State approved customer, with the intent to improve this customer’s ability 

to support US/DoS interests as part of a coalition force (Afghanistan) in 2012. This training 

benefits the US public by expanding support to US coalition forces, thereby reducing demand on 

US military forces while ultimately reducing demand on US resources. The benefit to the public is 

national security interests by protecting US interests abroad. Under this charge, TSGI, Inc. is to 

conduct Night Vision Goggle (NVG) training with two MD500 helicopters in the Salt Lake City area. 
Training & Security Group International, Inc.

P.O. Box 2603

Weatherford Texas 76086

www.tsgi09.com

817.901.9024

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Tactical Instruction Aviation Security Consulting

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TSGI is under lease for the two helicopters and have currently modified the two helicopters with 

NVG compatible lighting previously authorized and safely utilized by our pilots. Additionally, TSGI 

initiated training IAW the contract on May 9, 2011. NVG training was due to start May 23, 2011 

and scheduled to conclude on or about December 20, 2011. If any further details are required 

please contact the undersigned.

Public Safety: TSGI, Inc. retains some of the most experienced Instructor Pilots in the 

world. These Instructor Pilots have extensive NVG operator experience from Department of 

Defense’s 160th Special Operations Aviation Regiment (Airborne)—our nation’s most elite 

helicopter unit. Each of our instructors holds a FAA CFI certificate and has up to 5000 NVG hours 

in the most demanding environments. As a risk mitigation measure, TSGI, Inc. company policy 

imposes internal control measures that restrict our NVG training operations to 1000 foot ceiling 

and 3 miles visibility in controlled and uncontrolled airspace requirements as per known or 

forecast prevailing conditions along the route of flight. There is no initial NVG qualification being 

conducted. All NVG training is conducted with military-rated aviators current and qualified in NVG 

operations. All training will be dual-pilot NVG training. All instructor pilots and students have 

flown together for nearly two years aboard and in the US with stringent cockpit crew coordination 

standardization. Procedural control measures, and coordinated NVG flight training routes are in 

place with local airport authority to de-conflict nonparticipating aircraft. Day VFR familiarization 

and training is conduct over the same terrain and in the environment as the proposed NVG 

training. Finally, all NVG navigation training will be in either sparsely populated areas or areas 

with no population at all. Therefore, we firmly believe our extensive experience and risk 

mitigation procedures provide required safety expectations equal or greater to that of a modified 

aircraft. Thus, there is no increased risk to the public.

TSGI, Inc. has met all the requirements to conduct safe operations as per the Federal 

Aviation Regulations concerning pilot qualifications, safe operations and compliance with public 

safety. However due to new regulations and handbook procedures—concerning chiefly FAR Part 

135 operators aircraft equipment certifications—this recent change has brought an unrealistic 

hardship on the FAR Part 91 training programs. TSGI, Inc. is not requesting to operate outside of 

any safety concerns put in place by the FAA. TSGI is only requesting to operate in accordance with 

previous rulings concerning field approvals by the FAA under 337's. Additionally, TSGI, Inc. has 

been coordinating with the Utah FSDO on this request. The Utah FSDO has assisted and 

encouraged TSGI, Inc. to request this ‘one-time field approval’ and/or petition for exemption.

Request: TSGI, Inc. requests a "One-time Field approval” (Directive from the FAA) for a 

337 be approved for use as per the previous rulings under 337 for Interior and Exterior aircraft 

lighting systems required for NVG operations FAR Part 91.205h. If applicable, TSGI, Inc. requests a 

Petition for Exemption (FAR part 11.15) to FAR Part 91.205h. TSGI, Inc. requests this “One-time 

approval and Petition for Exemption to apply to our training from May 23, 2011 through 

December 20, 2011.

Summary: TSGI seeks relief for a period of up to 6 months to allow sufficient time for it to 

acquire the necessary funding and complete modifications to bring its aircraft into compliance 
Training & Security Group International, Inc.

P.O. Box 2603

Weatherford Texas 76086

www.tsgi09.com

817.901.9024

__________________________________________________________________________

_________________________________________________________________________

Tactical Instruction Aviation Security Consulting

Page | 3

with the requirements for use of Night Vision Goggles. This "One-time Field approval” (Directive 

from the FAA) for a 337 be approved for use as per the previous rulings under 337 for Interior and 

Exterior aircraft lighting systems required for NVG operations FAR Part 91.205h. Recently the FAA 

has interpreted a statement for the FAR's part 91.205h that requires the operator to get the FAA's 

approval of Interior and Exterior aircraft lighting systems required for NVG operations in the FAA's 

handbook 8900.1 (figure 4-68) that requires Flight deck lighting changes to support NVG use, or 

any approvals related to NVG must have an STC (Supplemental Type Certificate). 

Point of contact for this request is Stephen Schiller at 817.901.924, Frank Ippolito at 

817.771.2383 or Dan Laguna at 801.891.3856.

Stephen M. Schiller Dan Laguna

Colonel, US Army (Retired) CW4, US Army (Retired)

Senior Vice President Program Manager

Chief Operating Officer Director of Aviation Training