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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Date: September 9, 2011

Attention: Federal Aviation Administration 

800 Independence Avenue, SW

Washington, DC 20591

Subject: TSGI Response to FAA Letter (dated 10 August 2011) in support of Petition for 

Exemption (FAR Part 11.15) to FAR Part 91.205h

Reference: FAA Response to TSGI, dated 10 August 2011 (Enclosure 1)

TSGI Petition for Exemption, dated 24 May 2011 (Enclosure 2)

FAR Parts 11, 91, 135

FAA Handbook 8900

FAA Form 337

Dear Ms. Courtney,

This memorandum provides the additional information you requested in your letter to TSGI dated 

August 10, 2011. We trust that this information complies with the requirements of 14 CFR 11.81 and is 

sufficient to continue processing our petition for exemption. The following numbered paragraphs begin 

with a restatement of FAA’s concerns followed by our response:

1) Provide the reasons why this exemption would not adversely affect safety or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which you seek the 

exemption:

a. We are seeking this short-term exemption only to be able to complete an existing NVG training 

contract that was negotiated before the new rule became effective. The rule from which we seek 

the exemption establishes standardization of instrument, equipment and lighting modifications. 

While time and logistical constraints prevent us from complying with the letter of the new law at 

this point, the aircraft modifications that were planned to support this contract comply with or 

exceed the instrument, equipment, and lighting modifications that comprise the spirit and intent of 

the new law. In fact, our contract with our customer was drafted and signed last year with the 

intent to modify our two training aircraft in accordance with specifications that the FAA previously 

approved for over 287 customers under Form 337 prior to this new rule taking effect. All 

modifications according to such specifications address and comply with all elements required by

Part 91.205(h), thereby providing a level of safety at least equal to that provided by the new rule. 

Importantly, unlike requirements under Part 135, and unlike commercial carriers, we are not 

conducting spontaneous operations in unfamiliar conditions, e.g. un-surveyed landing zones, 

unfamiliar routing, and/or potentially un-forecasted weather conditions. In addition, there are 

other significant factors related to our operations that will ensure this exemption will not adversely 

affect safety. These factors are listed and explained below.
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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i) Extensive Pilot NVG Experience: TSGI employs some of the most experienced instructor 

pilots in the world. The three instructor pilots (IP) who will fly the two NVG aircraft for 

which we are seeking exemption have extensive NVG operator experience gained during 

assignment to the 160th Special Operations Aviation Regiment, our nation's most elite 

helicopter unit. Each of them holds a FAA CFl or CFII certificate. The IP with the lowest 

total NVG hours has 2300 hours on record; the highest has over 5000 NVG hours on 

record. The IP with the lowest total rotary wing hours has logged over 5000 hours; the 

highest has logged over 10,000 hours. All three of these instructor pilots have logged 

their NVG hours in the most demanding environments, and hundreds of their hours have 

been logged in helicopters with the NVG lighting configuration we are seeking the 

exemption to use. In addition, all operations will be conducted with dual NVG trained 

pilots and with these instructor pilots having access to flight controls during all 

operations. No initial NVG qualifications are being conducted. Overall safety levels are 

significantly increased by the experience levels possessed by the IPs at the control of 

these two aircraft, and they far surpass what is required to fly NVGs under Part 135 

commercial carrier.

ii) Deliberate Operations: The scope of NVG training we are conducting is deliberate, preplanned, reconnoitered, rehearsed, and limited in nature. All routes are detailed 

navigation routes which are rehearsed until accomplished to standard by all crews during 

day VFR conditions before performing under NVGs. Landing zones and locations are 

known and previously surveyed. No passengers will be onboard the aircraft, one of the 

three IPs described in 1a (i) above will be at the controls, and all crewmembers will be

NVG qualified pilots from the Jordan Armed Forces. Our primary training objectives are 

focused on helicopter overwater NVG navigation and mountain environmental flight 

training. We are limiting ourselves to Part 91 operations. We will not carry civilian 

passengers under FAA Part 135 or conduct other commercial activities.

iii) Rural Training Areas: NVG operations will be conducted in Class E and Class G airspace 

with routing selection such that flights are conducted over sparsely populated or 

unpopulated areas. All training areas and routing will be flown during day VFR conditions 

prior to NVG training operations. No impromptu landings or emergency procedure 

training will be conducted unless an actual emergency exists. All NVG routing and 

training areas of operations are coordinated with Salt Lake FSDO and departure airfield 

(Sky Park Airport, Salt Lake, Utah). In addition, TSGI has imposed more stringent visibility 

requirements for our NVG training under this exemption request. We will not fly NVGs in

weather forecasted to be less than 5 miles visibility and we will require cloud clearances 

of 1000’ above, 1000’ below, and 1 statute mile horizontal.

2) Section 91.205(h) satisfies safety issues by requiring instruments, equipment and lighting 

modifications for NVG operations. Your request only addresses the ability of the pilot and 

associated training needed to operate the aircraft while using night vision goggles (NVG). How do 

you intend to meet the instrument, equipment, and lighting modifications of 91.205(h)?

a. As outlined in 1(a) above, when we contracted our customer last year, our intent was to modify 

our two training aircraft in accordance with specifications that the FAA previously approved for over 
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

287 customers under Form 337 prior to this new rule taking effect. All modifications according to 

such specifications address and comply with all elements required by Part 91.205(h), thereby 

providing a level of safety at least equal to that provided by the new rule. These modifications 

provide NVG compatible lighting to insure all required instrumentation and equipment are

satisfactorily illuminated.

b. TSGI uses NVG compatible transparent film over system gauges and instruments as well as NVG 

compatible blue-green replacement bulbs in hood and hand manipulated lighting. With this 

configuration all instrumentation conforms to Part 91.205(h), is clearly visible, and imposes no 

limitations or restrictions under NVGs, night VFR or instrument flight. This method has previously 

been safely and successfully used for far more complex training and contingency operations than for 

what we are requesting and it was an approved method when we engaged in this contract last year.

3) The field approval process is not authorized for aircraft lighting modifications for the purpose of 

NVG operations. Aircraft lighting modifications for NVG operation is a major change to the 

aircraft type design and affects the operation of the aircraft. The aircraft lighting system as a 

whole is affected by the modification and is categorized as a night vision imaging system. How do 

you intend to address operating limitations and information necessary for safe operations? A 

supplemental type certificate would be required for lighting modifications for the purpose of NVG 

operations. 

a. We understand that the field approval process is no longer authorized, and that the STC is 

required as of 29 April 2011. While the modifications outlined by the required STC do in fact change 

aircraft type design and potentially affect aircraft operations, the temporary modification that we 

have used and are proposing with this exemption request does not change basic aircraft systems. 

The NVG compatible film and hood light bulb replacements use existing systems and flight 

instrument lighting to make them NVG compatible. This is a non-intrusive adaptation for NVG flight.

b. Operating limitations under NVS largely consist of a reduced field of view that is best overcome 

by training. The interior lighting configuration that we propose offers the same supported 

operational capability with respect to visibility of instruments and gauges, especially considering the 

experience level of the instructor pilots who will be at the controls. These IPs literally pioneered 

NVG use in rotary wing aircraft and have operated with this very type of configuration for years. 

The rated aviators they will be flying with have already received their NVG qualifications.

c. Since our operations exclude any passengers, functions, or equipment not related to our NVG 

training operations, we do not share the secondary risk of other commercial operators who would 

need to guard against accidental use of non-NVG compatible devices or lighting while in flight. 

4) In summary, this is a Petition for Exemption from the new requirements of Part 201.5(h) for a period 

of 3 months (previously 6 months, ending o/a 20 December 2011) to allow TSGI to complete a 

previously negotiated contract and provide sufficient time to acquire the necessary resources to 

accomplish permanent NVIS modifications. We are requesting the appropriate FAA Directive 
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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necessary to obtain permission to use previously approved lighting modifications for the purpose of 

NVG operations. 

5) Please contact Stephen Schiller at 817-901-9024 or Dan Laguna at 801-891-3856 with any questions 

concerning this request.

Stephen M. Schiller

Senior Vice President

Chief Operating Officer