BZ,
I completely agree with the concept you describe if not the letter of it. An example of what we are up against is the FAA's own regulations as you mention. Part 91 night flying regulations are much different than Part 135 requirements for surface light reference and such. I have advocated amending Part 91 to coincide with Part 135. I have also stated that the FAA should monitor EMS operations and when they catch pilots violating Part 135 requirements for surface light reference, they should take certificate action against the pilots and the operator.
To my knowledge, the FAA has never taken Certificate action against any EMS operator for flight rule violations, even after any of the fatal accidents we have experienced.
If I am wrong about this....someone please correct me.
I have also preached that weather checks are done in the office, briefing room, or ramp, with coffee cup in hand.....and never in the air.
Your system would work well towards reducing these night IIMC/CFIT accidents that are killing people.