Alt 3 et al
"Ultimately, it is all about liability." Yes!
In other words the operator and FAA could care less as long as following an accident the agrieved can go after the pilot's estate long after he/she is deader than dead just because they, the operators and FAA (and NTSB), don't have the stones to tell the industry to slow down and get it all right in the first place via using the rules, regulations and good operating practice that is already in place as part of pilot certification.
This revision to AO21 is really sad stuff - just as despicable as the large banks doling out 18.4 billion US $ in bonuses for their worst performance since the great depression - some things just do not make sense.
I'd say we in HEMS have run smack dab straight in to our Achilles heel - failure to take the responsibility for slowing down and doing things right from the get-go.
WIII