Jim,
If one adds NVG's....using the existing weather minima....and visibility minima....thus providing the ability to "see" those external cues by which to control the aircraft.....including landing and take off at ALL sites approved by the NAA....where is the problem in getting Approval for that?
You pose a straw man argument when you attempt to shift this discussion to Stability and Visual Flight without sufficient Visual Cues thus requiring the use of instruments to control the aircraft.
The discussion extant is about the use of NVG's for EMS Operations.
The discussion about flying VFR in IMC Conditions is an altogether different argument.
The only correlation I see is that by the NAA's approving the use of NVG's for all phases of flight especially Landing.....those cues shall (imperative tense used on purpose) be improved, enhanced, and far more plentiful thus negating the need for what we all know would prove to be a decades long pursuit of new certifications of new aircraft and Modification of existing aircraft.
NVG's mount to a helmet and only require a compatible lighting system which is technology already in common use.
Surely, this is not that complicated a thing for reasonable, logical, and open minded people who seek to make easy, quick, and effective enhancements to night flying safety and expand the operational capability of a valuable asset such as EMS Helicopters.
In the UK or some parts of Europe where a speedy retrieval of injured and gravely ill patients is not a concern....perhaps there is no need for the capability.
In the United States....we see it differently.....and have fought this battle in the past and now the FAA is finally coming to the table on this. They came kicking and screaming....but they came.
Sounds to me like you folks are entering that stage of business where just like GPS....you will have to shed the "old way" and begin to embrace new technology.
Perhaps the NAA's should take a position more along the lines of "How can we make this happen?" Rather than the current attitude of throwing up every obstacle possible.
My impression of the EASA system is it seeks Utopia where every risk is eliminated.....no matter the cost. That is never going to work as Aviation is all about Risk....managed, controlled, acceptance of reasonable risk.
We will never see the end of aircraft crashing.....we just have to find a way to improve the chances of that not happening as best we can.
Upon consideration....perhaps the EASA way is best.....if no one flies....no one dies.....except for the Casualties on the side of the highway waiting for ground transport.