RVDT
There are historical precedents for the non carriage of the RFM insofar as British Airways Helicopters received approval from the UK CAA not to carry the 4 kg of (useless) Sikorsky S61 RFM and it was replace by a (coherent) document that contained all the relevant data but in a format that was easy to find, unambiguous and free from errors.
I think from a legal standpoint if you can demonstrate that the required airworthiness data was included in the OPS MAN Part B then you may get away with it.
The problem with the RFM is that we expect it to be a Pilot's Handbook but actually we find it is a technical manual designed to meet certification from a legal obligation point of view.
The information contained does not necessarily relate to the exact version of the airframe you fly unless the Part 5 Supplements are taken into account and these may actually contradict the instructions in the basic RFM thus making the reading of it rather difficult not to say impracticable. Hence the JAA approach - write a version of the RFM that incorporates:
a. Basic RFM procedure modified where appropriate by the relevant Supp.
b. Additional requirements specified by the operator (these may be more restrictive than the RFM but not less so).
c. Advice relating to the specifics of the operating location and task.
I have said it before but I don't believe the Emergency Procedures in the RFM are a substitute for a good Emergency Check List. This will feature 'Immediate Actions', 'Subsequent Actions', and 'Considerations' and have the objective of giving the pilot the best advice consistent with the technical and operational issues as well as Company Policy.
G.