Jim
I think most of the posters here are familiar with the limits you quote. The point is that there are holes in those limits - whilst my minima for an ARA might be deck height + 50 etc, once I am visual there are no limits. If at DH+50 or 300' at night, I can just see the bright lights of the installation through the mist, there is nothing to stop me descending further to get below the thin cloud base of 100', then running in and climbing up to the helideck. The visual sector is not really defined - it can't be because the deck might be at 50' - at some point I have to descend to 50' to land on it.
Ditto for an en-route descent. I might have 1200' and 5km at the bottom of my descent, but as you know, the met reporting from offshore is hit and miss, all the more so at night, and whilst I might have surface contact, its hard to know the forward visibility unless within 5km of the destination, which is probably too close to be still at 1200'. Once below 1200', in sight of the surface and on descent for landing (lets say to my 50' deck) there is no control over my height. I must be allowed to descend to 50' or I can't land, but does it say anywhere that I must even be visual with the destination at that point, never mind with good visual cues? I might think I have 1200' and 5kms, but can't be sure if I am more than 5kms from the installation. I will not see that fog bank that is lurking between me and the installation.
I might be above it at 200', looking down through only a few 100' or so, getting good visual with the destination, then I descend to 100' and now looking through 1/2 mile or so of the same mist - total loss of visual references.
In summary, I totally disagree with
There is no freedom to fly below the VFR limits.
- there has to be, otherwise I can't land on a low deck
All that said, I don't think that legislation is the way to fix this problem, its too complex. It has to be more to do with good SOPs, training and an understanding of the pitfalls.
Regarding the apparent sleight against the Authorities, and your statement
recognise that the Operator writes and owns the OM - not a faceless committee in Europe.
unfortunately that is no longer true. It was a big negative step when we were forced to align our Ops Manuals with JAR-OPS 3 paragraph by paragraph. In my opinion this was done to make it easy for the Authority to check that our manuals were compliant with Jar-Ops 3 - it was not done to make the manuals easy to interpret by flight crew. A lot of good stuff was lost from the manuals as a consequence and its less easy to read as a result.
There will always be the need for competent handling skills in helicopters
Of course, but lets keep it to a minimum - use the automation until really close, when the visual references are reasonable and we are manually flying for the shortest time.
HC