Westy:
Your post is confused and confusing.
What you have not mentioned is that German Regulations do not contain the latest text of JAR-OPS 3 which deals with most of the issues you have raised. The JAA does not have competence on Heliports/Helidecks or Aerodromes - they are still the responsibility of the State.
The latest version of JAR-OPS 3 (Amendment 3 - 1st April 2004) - in the cases you have mentioned - is not
quite restrictive and if put into full force would not allow any landings at most hospital sites anywhere because they do not fullfill the necessary standards.
Whilst it is correct that a helicopter operating in Performance Class 3 is not permitted to fly over a hostile environment (except under a specific approval), that provides compliance with ICAO Annex 6 Part III. It is not true that such helicopters cannot operate to an elevated heliport under JAR-OPS 3.
As mentioned before, compliance with the heliport Standards contained in ICAO Annex 14 is an issue for the State and is not regulated under JAR-OPS 3. Whilst the 1.5D that you quote comes directly from Annex 14, most Flight Manuals require a larger FATO than that (2D being a average size).
Yes, it's sensible to have the landing sites regulated to a certain degree, but what the new EU regulations are asking for will make flying direct to hospitals nearly impossible.
It is not clear to me (and probably others) what particular EU regulations you are quoting here - it is certainly not JAR-OPS 3.
I would suggest that as soon as the German Regulations are brought into harmonisation with the latest version of JAR-OPS 3, the problems that you are describing (for HEMS in Germany) will disappear.
Once the
latest proposal for amendment of JAR-OPS 3 are published, you will also see that the link between the Category A procedure (which drives the permitted size of the heliport) and Performance Class 1 has been broken; this will allow the size of the heliport to be directly related to the performance of the helicopter and legitimise operations to most of the elevated heliports at German hospitals (without alleviation).