My pleasure, sir. You are one of the most sensible and gracious SMEs on these topics.
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I was using passive aiming to mean not using a pointer, not necessarily no emissions at all, since the emphasis is on the aiming part.
If your use of illum is strictly for navigation, then it's much less of an issue, but for those that are using it as part of shooting, the helmet mounted illuminator is going to be subpar. IMO, one should have illum both on the helmet and on the firearm. In urban environments, it'd be pretty tough to get away without a rifle mounted illuminator if trying to do work.
One could fairly easily use the spill of the illuminator to try and PID something without directly pointing a weapon at someone, though you'd obviously have to stress that in your statement.