Hi Jim,
Germany doesn't have the latest JAR's. Still running on the first papers from 1999, fresh in national law.
with more special permissions than Einstein could still hold in mind.
The whole new paperwork isn't in national law and therefore couldn't be official used.
It's impossible in Germany to adopt the latest versions in national law (Ohoooo!!!). This 80 mio inhabitants country doesn't have enough CAA officers.
Now with EASA the interest in implementing JAR's, IEM, AMC is descending to sub zero. The "public interest sites " isn't an official thing in germany. Why? Version 1 JAR-OPS 3 doesn't have "public interest sites" and the german law therefore also not! May be you can have an CAA officer who knows the term" public interest sites". But i wouldn't bet.