Very little stated by Ray in his presentation is new - it is a rehash of many 'CAT A'/'PC1' presentations in the past.
What appears to be the cogent point is Ray's statement that CAT A profiles cannot be flown with NVG unless they have been evaluated under those circumstances. Unless this is subject to a policy change, it will add a real expense to manufacturer's flight testing regimes which might have to include flight in 'rain', 'snow', 'low visibility' etc. Perhaps a more pragmatic view needs to be applied i.e. the presence of lighting.
The first thing without dispute is that operating to a PC1 heliport at night (with all of the associated lighting from Annex 14) with NVG must be acceptable under the proviso that operations with NVIS is an extension to VFR Operations under all circumstances - i.e. the pilot can come under the goggles at any time and meet the visual requirements for the manoeuvre.
The second thing without dispute is that PC1 can only be conducted to a landing site which meets all the conditions for PC1 operations - i.e. the site has been surveyed; the mass is sufficient to satisfy the RTODR/TODRH; and, obstacle clearances will be met.
Ray is a little behind with the requirements for a HEMS Operating Site (the ad hoc site or scene); it no longer says 'PC1 as far as possible' (which is oxymoronic) but PC2 (with the associated approvals for exposure).
Night Flight with NVG is one of the least problematic issue EASA has to address. More important perhaps is the lack of any airworthiness requirements for stability and control under circumstances where flight is being conducted under VFR and the visual cue environment is not sufficient to permit control without reference to instruments, or obstacle to be seen such that they can be avoided.
Jim