SND - thanks for your very helpful post.

THE CHOPPER - unless you are lucky enough to have un limited budget EVERYTHING has to be justified.

In this case, the rules allow Flight in circumstances I believe most experience pilots would agree, challenges the margins of safety. Sometimes compliance does not always mean SAFE.

I have an open mind but tempered by experience and gut feeling. However, it has to be justified to customers in a marketplace where the guy next door would offer a better, compliant as a maximum, deal.

DB - just goes to show that the rules are not infallible - the concept that night overwater is VFR is a nonsense - as anyone who has done it will tell you.

If people argue with your safety concerns regarding the SAS vs ATT question, take them over the water in the dark and ask them what they are looking at to fly the aircraft - it will be the instruments not the external horizon.

I once did a search from Cyprus for several hours in classic Mediterranean goldfish bowl conditions, with a Nav in the LHS talking me onto vessels that we let down to identify to confirm they weren't the one in distress we were looking for. I was working hard (Wessex only had SAS equivalent and a very poor baralt hold) and we decided to head for Paphos for refuel after one more homing. The Nav vectored me onto a light and we started towards it - until he mentioned that it didn't seem to be getting any closer. I looked up and realised we were trying to home to a star and he admitted he had had the leans for the last hour or so. We went home!

We also lost a Wessex overwater at night in the Med after a minor emergency distracted the pilot and he flew into the sea.

Bugger the EASA rules - it is IFR over water at night and the aircraft needs to be properly equipped - Ie SPIFR. Don't wait to lose an aircraft to make your safety case.

In fact, I'm sure your FFS must have night capability and possibly overwater as well. Get people to fly a medium workload sortie with the odd minor emergency in SAS mode with no height hold and see what happens.

I took part in a series of simulator test flights many years ago at RAE Bedford to look at handling qualities in DVE (which is what night overwater is) and aircraft stability was the major factor in safety.

Hi CRAB for once me and you are in perfect alignment. Quite why the authorities have never fully recognised that there is no such thing as VMC over the water at night, until we see lights AND depth perception, is beyond me. Unfortunately the minimum equipment requirements don't stack up to what you eloquently describe, is the overriding safety case.

UK CAA did make very positives steps to alleviate this after the Mathew Harding accident. They mandated AP for SP Night including over the land. Unfortunately this got overruled when EU-OPS became the law. Maybe Brexit will give them back the teeth they need.

DB