I also support the HCGB stance.....If you fly an R22 or similar ,you cannot fit floats and would have to detour just to fly from Bristol to Newport ,whilst the Isle of Wight would be out of bounds.Also where do I put the liferaft?
The point..... well made by others.... is for pilots to evaluate the risk...wear lifejackets and take a PLB ( a lot more useful than telling the rescue services where your sunken helicopter is !).
Almost nothing in the proposals makes practical sense ,none of it is borne out by the historical accident record and it is just going to cost private pilots a whole shed load of money ,and in some cases ground the aircraft because they cannot economically comply.
If you read the HCGB respones you will see a very well argued case ,with practical alternatives suggested and as many people as possible need to write with similar views.
Incidentally I found the circuituos comments route quite difficult to navigate and instead sent separate e mails ,quoting the relevant NPA numbers ,to the npa easa address.
It obviously worked as I got an acknowlegement.