Thanks, Jim, for your explanation.
Sorry to keep on about Battersea Ops., but I guess it is an easily recognised example and important to a number of operators.
My understanding is that one significance of NPA 38 is that this is likely to be the last NPA before the demise of JAA and the enthronement of EASA. So the version of JAR-OPS resulting from NPA 38 will pass into European Law within the next couple of years.
At this stage the existing operations "permitted under JAR-OPS 3 with exemptions", will cease, as the CAA will no longer be in a position to issue these exemptions (?)
There is a justifiable concern that the current generation of light twins and singles will be then prevented from operating out of Battersea.
We could see the situation where Battersea Heliport is available to private flights only, as commercial operators are unlikely to be able to meet the requirements, particularly with respect to UMS.