As I said on the previous thread on this subject; this is an important juncture in European aviation and you should be prepared at least to go to the web site and take a look at the proposal.
The HCGB do have some interesting points but have missed one thing that might have been highlighted; at the last major revision of Annex 6 Part III, a decision was taken to follow the FAA lead and separate out the SARPs for instruments into three parts: VFR day; VFR night; and IFR. EASA have not chosen not to make the same simplification - it would have made a difference.
There are two elements in the list provided by the HCGB which
do need highlighting: the requirement for a second attitude indicator for VFR night has no precedent in JARs or ICAO - it is a mistake; the requirement for an alternative source of static pressure for VFR night is also an overkill - it is usually required only for flight in IMC.
For CAT pilots: good luck in trying to establish the exact requirements for IFR instruments, the combination of inheritance, four rules and many AMCs will test your resolve to the limit.
The requirement for 'ditching approval'/'floats' for all helicopters comes straight out of JAR-OPS 3 because the ICAO text for GA is:
4.3.1 Means of flotation
All helicopters intended to be flown over water shall be fitted with a permanent or rapidly deployable means of flotation so as to ensure a safe ditching of the helicopter when:
a) engaged in offshore operations or other over-water operations as prescribed by the State of Registry
which was intended to take care of offshore operations conducted by oil companies with their own helicopters; or
b) flying at a distance from land specified by the appropriate State authority
to provide flexibility for (relatively) short over-water transits to be permitted to GA by the State.
Providing a raspberry to EASA will not do the trick; in the case of flotation equipment, it might be pointed out to them that the Commercial Rules are not proportionate and are not applied to GA in any existing regulation (if that is correct). It might also be a good idea to provide the contents of the ICAO note to these two clauses:
Note. - When determining the distance from land referred to in 4.3.1, considering should be given to environmental conditions and the availability of search and rescue facilites.
Jim