Training & Security Group International, Inc.
P.O. Box 2603 Weatherford Texas 76086

www.tsgi09.com 817.901.9024



### _________________________________________________________________________ _

_________________________________________ ________________________________ Tactical Instruction Aviation Security Consulting 

### Page | 1 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

, d ated 10 August 2011 (Enclosure 1)

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

FAR Part s 11, 91, 135
FAA Handbook 8900

FAA F orm 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 t he reasons w hy 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 c onstraints prevent us from comply ing 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 spir it an d intent of the new law. In fact, o ur 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

m odifications 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 p rovided by the new rule

. Importantl y, 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 rout ing, and/or potentially un

- forecasted weather conditions. In addition, there are

o ther significant factors related to our operations that will e nsure 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 

### Page | 2 i) Extensive Pilot NVG Experience : TSGI employs some of the most experienced instructor

p ilots 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 16 0 th 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 5 000 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 pilot s have logged
their N VG hours in the most demanding environments , and hundre ds of their hours have been logged i n helicopters with the NVG lighting configuration we are seek ing the exemption to use

. In addition, all operations will be conducted with dual NVG trained pilots and with these instructor pilot s having access to flight controls during all operations. No initial NVG qualifications are being conducted. Overall safety levels are significantly increased by the experience level s 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, pre

planned, 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 NVG s. 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 A rmed Forces

. Our primary training objectives are
focused on helicopter overwater NVG navigation and moun tain 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 Area s : 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 i m prompt u 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, TS GI has imposed more stringent visibility requirements for our NVG training under this e xemption r equest. 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 pilo t 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 overTraining & 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 ef fect. 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. The se modifications provide NVG compatible ligh ting to insure all required instrumentation and equipment are satisfactorily illuminate d.

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 i nstrument 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 NV G compatible. This is a non

- intrusive adaptation for NVG flight

.

b. Operating limi tations under NVS largely consist of a reduced field of view that is be st overcome by training. The interior lighting configuration that we propose offers the same suppor ted 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 opera ted 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 opera tions, 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 Pa rt 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 DirectiveTraining & Security Group International, Inc.
P.O. Box 2603 Weatherford Texas 76086

www.tsgi09.com 817.901.9024



### _________________________________________________________________________ _

_________________________________________ ________________________________ Tactical Instruction Aviation Security Consulting 

### Page | 4 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