|Gilbert Martinez, chief inspector and R&D supervisor for Aero Dynamix, looks at a panel at the company’s facility in Euless, which recently underwent an expansion. Aero Dynamix|
Despite the challenges of the global marketplace, cutbacks by public-use helicopter operators and new guidance in the form of FAA Order N8900.152 that took effect in April 2011, companies that provide night vision goggle (NVG) cockpit modifications are doing well, posting higher year-end returns and expanding at a time when many businesses are pulling back on the reins.
Rotor & Wing spoke with three of the major commercial NVG cockpit modifiers—Aero Dynamix Inc. (ADI), Aviation Specialties Unlimited (ASU) and REBTECH—to gauge the state of the specialized market and find out the impacts of N8900.152, Special Emphasis Inspection of Night Vision Imaging System Lighting Installations, on both operators and modifiers.
“Across the board, NVG demand lately is high,” says Dennis Trout, general manager of Euless, Texas-based Aero Dynamix. “Back in the old days, and I’m just throwing figures out there, probably 10 percent of rotary wing aircraft required NVGs. Now, even though the market for aircraft is down overall, roughly 30 percent of new aircraft require NVG. All market sectors are up—EMS, police, law enforcement, offshore, military—it’s across the board, they’re all turning to NVG.”
The percentage of NVG users “has continued to grow, even in the economic situation that we have,” he adds. “Once the economy returns in earnest, we expect to see the demand for NVG to go even higher than it is today.”
The worldwide economy “has had only a slight impact on REBTECH over the past few years,” notes Richard Borkowski, president of the Bedford, Texas-based company. “The market is pretty strong right now. We do foresee that it’s probably already hitting its peak—maybe. Our sales have continued to rise at a pretty healthy rate over the past four and a half years.”
While the numbers are steadily going up overall, Borkowski observes that some taxpayer-funded operations are “being forced to go with the lowest modification bid over a source which is sometimes preferred by the pilots and maintenance personnel. Many in the law enforcement field have seen their operational budgets cut drastically to the point of not being able to acquire NVG equipment at the moment, or in piece parts over a period of time.”
But in the next few years, he sees “more and more air applications needing and benefiting from the use of NVGs,” including those units who had previously held back because of budget concerns.
Shawn Woodworth, director of maintenance for ASU out of Boise, Idaho, says his colleagues have been expecting this business to start dropping off soon. “But for the past three years, every year we’ve been [modifying] more and more aircraft—2011 was a booming year for us despite all the challenges we’ve had, and 2012 is starting out to be a boom year too.”
Hannah Gordon, director of sales and marketing for ASU, explains that EMS is the company’s biggest sector. “It used to be police, but under the ‘new economy,’ public uses have taken the biggest hit on extra spending.” She adds that ASU sees the global marketplace as a major growth area—although that brings its own challenges, due to U.S. government export regulations and varying rules among different countries.
The increased awareness of the importance of NVGs as a safety tool has helped isolate some of the losses experienced in the public use arena.
“NVG is an operational requirement in many cases these days. Before it was a luxury, but today a lot of operators won’t do without it,” Trout observes.
“We’ve seen a trend to go toward NVG,” says Borkowski, “whether you’re a law enforcement, EMS, offshore operator, etc. We do a lot with operators like the Ontario Ministry of Natural Resources, for example—those that fly power lines at night, those that check on control towers or cell phone towers. They are flying all the time and they’re realizing that they’re a lot safer if they are trained properly, have an STC-approved cockpit, and using a good quality set of goggles. They’re seeing that there’s not as many nighttime crashes” for operators with NVGs.
Unfortunately, says Jeff Stubbs, senior vice president of operations and systems technology for REBTECH, public service aircraft units, with a few exceptions, have historically “been treated as an unwanted evil, and NVGs as toys. Once we can convince a decision maker that this could save lives and avert a possible ‘incident,’ then we can move forward.”
“There are obviously times when we know that an operator’s going to get a couple of aircraft completed and due to their budget situation, will drop NVG—but it’s a pretty rare occasion comparative to what it was four or five years ago,” notes Tonka Hufford, operations manager for Aero Dynamix. “Back then NVGs might be the first thing off the list, today it’s one of the biggest things that people fight to keep on the list.”
One of the recent issues impacting operators in the NVG modification industry is FAA’s N8900.152, which took effect in April 2011.
Stubbs says that the biggest challenge for NVG operators and modifiers in dealing with the FAA “is that unlike any other STC, civil NVG approval can be subjective.”
Regardless of experience, education or training, he continues, “ultimately an individual is making a decision that is based on perception or opinion.”
Kim Harris, director of operations for ASU, agrees. Much of the NVG program within the FAA is kind of a round peg in a square hole, he says.
Both Woodworth and Harris elaborate that NVG evaluations can be very subjective—while one inspector might decide that daylight readability in a particular aircraft is adequate, another might have a different opinion.
Describing it as an ongoing “learning experience for both the industry and the FAA,” the process of developing and enforcing the regulations has created additional time and costs for NVG modifiers, according to Harris. The company worked with FAA in 2007/2008 in a process that involved “paperwork cleanup and a lot of special emphasis inspections,” Gordon explains.
The initial aircraft reviews were “a huge expense for us, but a definite learning experience for everyone—us, the FAA and the operators,” Harris says, adding that when the special emphasis inspection guidelines came out in 2011, “the lessons learned from our experience helped the entire industry.”
According to Stubbs, “when we were first made aware of N8900.152 a couple months before it came out, I was probably the ‘chicken little’ of REBTECH, running around concerned about what was going to come out of it.”
But in reality, he continues, “out of our 300 aircraft, we really did have less than three percent of our fleet affected by 152, and that three percent was solely operators who had modifications a few years ago and they lost documentation. It really did not impact us much at all. For other companies, it nearly ruined them.”
For operators, “one of the biggest challenges is the budget,” Trout says of N8900.152. “These new demands have a big impact on their budget—some instruments either have to be updated, or the user wants to make changes to improve safety or effectiveness. From our side, the regulations have given the operators and maintenance providers more awareness of what the FAA guidelines have evolved to.”
That increased awareness, Hufford explains, “has driven the operators to realize that, while they may have added a couple small units over the years and thought everything was just fine, often times the maintenance providers may have overlooked the impact the change may have had on the NVG certification.”
Aero Dynamix has experienced “a huge increase in demand [to answer] questions. That’s driven a very large, new requirement for STC updates and re-certifications. That is, aircraft that were field approved before 2003/2004, or even as far back as the late 90s, that are now coming back and requiring a full FAA STC,” Hufford continues.
The increased demand has been a factor in helping drive a recent expansion of the Aero Dynamix headquarters in Euless to 23,000 square feet, with a workforce now approaching 100 people.
Stubbs says that the FAA Special Emphasis Inspection “was not only needed but long overdue. N8900.152 has provided the FSDOs with initial NVG training and a regulatory format in which to insure the NVG STC is maintained and documentation is current. Many of our operators have taken N8900.152 and are implementing it into their quality system as well.”
From an operator’s perspective, “it’s an entire shift in how they perceive modifying their aircraft,” says Gordon. “So in that regard, there’s a lot of discrepancies a lot of modifiers are dealing with. A good 30-40 percent of those problems have to do with an operator upgrading their GPS but not realizing that they have to get an ECO [engineering change order] to do that. They can’t do it with a [Form] 337 anymore.”
Economics is based on filling a demand, and the demand for NVG modifications remains high and it should continue to be a productive segment for many years to come. While the sector involves a very complicated product—with issues like daylight readability still a case-by-case challenge—it clearly isn’t on the decline.
“Filtering infrared light today is not the hardest part of modifying equipment, it’s the balance and the daylight readability,” Trout explains.
“It’s easy to make a cockpit NVIS compatible, but can you read it during the day? That really is the challenge,” adds Woodworth.