My recently retired friend with 46 years of fling-winging spent his entire EMS career on the night shift and un-aided. He would vehemently disagree with you. Then again he flew his Huey into a hornet's nest to get his brothers in arms out alive. What's one got to do with the other ? I don't know either, just flapping gums.
Well it's good that he's survived all that but I don't know of anyone in the HEMS industry or anyone flying military who believe unaided is safer than aided. At least anyone that has experience flying NVGs. Common sense would suggest that when you can see your surroundings such as mountains, clouds, unlit towers, etc., you have a better chance of not flying into those things.
I have a friend who spent almost his entire first year flying HEMS in a BK-117 unaided. He'd be the first to tell you aided is far safer than unaided. A week prior to his operation going aided, they had another BK crash killing everyone on board. i think that accident was the impetus in his program going NVGs.
None of the FAA's changes this year provide any substantial safety benefit. OCC and the new risk analysis? Hilarious. As if I need a number or a color to tell me I'm low risk. We joke that even if you worst case the thing, it's still "low risk." Low risk is flying in an airliner with two pilots and redundancy out the a$$ from one 10,000 ft long runway to another 10,000 ft long runway. Low risk isn't getting waken up at 0300, doing a quick weather check, flying an unplanned route, to a non TERPd no VASI mountainous road intersection with gusty winds, MVFR, single pilot & single engine, operating at the limits of what the aircraft can do. There's definitely some risk involved there.
FAA is trying to solve our accident problem with technology but they overlooked the one critical piece. Perhaps since most operators are already full up NVGs it wasn't worth requiring, I don't know. Of course you could say that about some of the other requirements as well though. I don't know of anyone hiring pilots who aren't IFR certified and aircraft that aren't equipped with a RA and HTAWS.
I think this is a start in the right direction but I don't think we'll see any drastic change in the accident record of HEMS. It'll be a couple years before we can draw any real conclusions to these changes and safety records. Unfortunately we're already off to a bad start this year.