It would be a pity to miss one premise of the paper that Civil Certification does not provide adequate (or any) guidance for establishing dynamic stability for other than flight in instrument conditions. This despite this text in Part 27:
27.141(c) Have any additional characteristics required for night or instrument operation, if certification for that type of operation is requested. Requirements for helicopter instrument flight are contained in Appendix B.
It is argued in the paper that the present guidance considers only VFR flight in a Usable Cue Environment (UCE); this in spite of the fact that the probability of an encounter with a Degraded Visual Environment (DVE) - because of lack of horizon or surface lighting - is extremely high at night. It is also argued - on the basis of accident reports over the period examined - that encounters with DVE by day can be mitigated/tolerated only by improving the handling qualities. This leads to a recommendation for a change in certification so that the anomaly is resolved.
It is accepted that a change in Certification can only provide improvements for new types (but still needs to be done); hence other recommendations that attempt to reduce the probability of an encounter with a DVE.
It is extremely difficult to provide a descriptor of a UCE - by day or night; depending as it does upon: the weather conditions; the stability of the helicopter; the skill of the pilot; Field of View (FOV) etc. In view of this and in spite of the comment by 'Crab' that we are not shown anything new in the paper, it attempts to pull together recommendations that cover the whole range of solutions: Certification; Operational Regulations; Aeronautical Decision Making; Risk Assessment tools; Information; and Training.
It suggests that black and white is adequately covered but all shades of grey have to be dealt with. What this paper does not do is to suggest that the answer is flight on instruments at really low levels or that the problem can be cured with another sophisticated instrument on the panel (in fact part of the problem with IIMC is the inability of most pilots to come into the cockpit and transition to flight with other than visual cues).
Yes, as suggested by 'Nick', PinS procedures are necessary but as explained by 'Hihover' this cannot be done without establishing the obstacle environment both fixed and mobile. At the moment PinS requires 'survey' and 'safeguarding' - which can be done for specific locations and heliports; obstacle clearance for "defined points in space such as highway intersections and motorway exits" might require an add-on to the MDA that would render them impractical.
The reality is that the majority of LOC accidents occur to small and unsophisticated helicopters which are flown VFR in conditions that are, or deteriorate to, DVE. To meet the declared target of a reduction of accidents by 80% in 10 years requires an improvement - for that population - in the understanding of why these accident happen. Hopefully this paper, and discussion that are stimulated by it, might play their part in that education.
Jim