I tend to agree with both of you. I will be holding my breath once the night ops start up (and keeping my fingers crossed). I am not an ex-mil pilot but I have flown night HEMS and CASEVAC with police units. It just stands out a mile as the most hazardous flying I have ever done.
I got the distinct impression that the CAA FOI were very much aware of the risks, and were trying to put it off. I suspect they only moved because Europe said they had to. I recall that one of the FOIs gave a presentation a few months ago, setting out their planned requirements. Can't recall the detail.
The link talks about a risk assessment to be produced by the operator.That might be a difficult document to get accepted by the CAA.
I worry that the charities just think you need to provide (pay for) the extra kit and you turn night into day
I believe you are right about inter-hospital transfer being a more sensible starting point. That is not HEMS, of course. As the NHS moves to fewer tertiary hospitals with trauma centres covering large areas, there is a REAL value in looking at this. Wales would be a good place to start: big rural area, lousy roads low population density (except for worried sheep). It can only really sustain a very small number of true trauma centres and truck transit times need a calendar rather than a stop watch.
It is the usual problem though: different budgets. I cannot see charities and communities being real happy on having their funds spent on these flights and the NHS is worse than skint. They cannot even afford helipads in many cases.