I don't see why the MOD/Home Office don't use 2012 as an excuse to remove the mil in its entirety from "civvy" SAR. As it stands now, the mil are utilised for approx 90% of their time with civvy tasking on and offshore. WHY?
We all know the mil is a lumbering beomoth financially - accepted it is falling into line with good working practice along commercial lines in a number of their depts - but there is still a long way to go, I would suggest.
Let the civvy SAR companies do what they know best - they are more maleable to market forces and can adopt and adapt very quickly.
JAR 3.005(h) gives the rules for SAR training NOT the CAA.
Currently civvies have to fly training missions (note: not live ones) where a critical unit failure does NOT jeopardise the crew/aircraft. Small cabs like the 109 / 365 etc often find this regulation difficult to attain.
How they go about it then - requires exemptions from European law, not national law.
NVG is potrntially available to the deck (and is as we speak being profiled right now, by the CAA). NVG will NOT be a hurdle for civvy SAR, believe me.
The biggest issue for any current/future SAR operator, is without doubt - litigation issues. The mil are feeling this intensely lately and I have a feeling they would want to wash their hands of it IF there is a suitable alternative......and there is. Watch CHC over the next few years [No connection with them either].