Boslandew
I think the paper you describe is in fact the MOD response to the Select Committee in which it notes the Committee's report but does not accept its conclusion.
MOD seem quite clear (the rules after all are their rules) that a helicopter flying below 140 knots airspeed requires the aircraft to remain clear of cloud, in sight of the ground or water and with a forward visibility of at least 1000 metres.
I agree that it does appear that some contributors have a different view.