helmet fire, i don't know which european HEMS you have seen, but what is Europe? Did you mean JAA land?
1.
"Institute a night lower safe altitude even when VFR. Make it 1000 ft for VFR" - JAA lowered the allowed weather at night for VFR - HEMS from 1500ft to 1200ft, on route shorttimed 1000ft, visibility 3000m - not good
2. There are many HEMS bases without IR pilots (in Germany and Switzerland at least 60%) and sometimes without IFR helicopters in Europe - not good. No sweat, JAA don't want it.
3. There are also single pilot VFR night HEMS flights (also without AP!). The HCM is in the back assisting the MD. JAA have not specified up to today the place of the HCM on a front (copilot) seat. He have "to assist the pilot", what ever that means. - not good
4. There are no HCM
"with pilot theory passes", no existing JAA rules about the special and determined HCM training. Mostly they get 20-40h theory and 10 supervision missions (different between the operators) including refueling, pushing a helicopter into hangar, sweeping it and other simple stuff. Especially
they will never have IFR theory or NVG hours. - not good
5. Therefore at night the HCM is only a cheap place holder. Pilots are too expensive - not good
6. "The point is that there are two
aviators in the front." You are joking?
7. Also Europe has seen devastating VFR night HEMS accidents. Why not so much as in US? I bet, it's only a question of the numbers of flights and some other small points. Only statistics! As example, in the more than 80 million inhabitants Germany you will find only round about 10-12 night HEMS bases. They do not fly really much at night and mostly short hops 50-150km. Jobhopping is not so common in Europe than is the US. Therefore the most pilots in the business in Europe have very much experience in their small mission areas (diameter 100-200km at night), in their helicoptertypes and in their local weather situation. Much alternate landing sites also around! Good ATC and full radar coverage additionally!
I'm not sure if the european system is really better than the american.
And just one last point, in all the last german HEMS VFR night accidents were involved only IR pilots and IFR ships. There are no night accidents with VFR pilots and simple ships. Why? Simple, the IR pilots in trust in their clocks and APs went straight ahead in CFIT, the VFR pilots turned back or canceled the flight before take off after weather check because they fear the clouds