Thank you Jim.
There are one point I don't fully understand and one that in my opinion does not make sense.
1)
"(B) The helicopter occupants
cannot be adequately protected from
the elements;"
I'm not sure if for "elements" they mean weather and water temperature.
Maybe here we have a possible ENAC interpretation.
2) "
(A) For overwater
operations, the open sea areas North
of 45N and South of 45S designated
by the Authority of the State
concerned"
I think that in winter the water will kill you in 30 minutes, no matter if south of 45N (most of italian waters)
Cold Water Survival