I am reluctant to come into this debate so soon and should really leave it to others to comment on this first; however, having analysed the whole package and produced a JAR-OPS 3 conformance matrix, and distributed it to a number of interested parties, I can state that there are no substantial changes to the HEMS requirements.
The main change for HEMS is the removal of the PC1 requirement for the HEMS Operating Site in a hostile environment - requiring instead the more practical PC2 (with exposure). Even this is not new because it was developed by the JAA following a discussion with HEMS organisations/operators in the UK and Europe.
Although the JAA proposal is included in the EASA text of Part OPS, there is the subsidiary issue of a choice over the additional requirement for a Risk Assessment and the fitting of UMS. The choices are enumerated in Attachment D of Appendix 1 to 'The Explanatory Notes and Appendices' - they need to be read, understood and appropriate comments made.
Crying wolf is not going to help in this process - there needs to be careful assessment of the proposal; necessary changes will be achieved only by reasoned argument and alternative proposal.
Jim
Last edited by JimL; 20th February 2009 at 12:16.