HELICOMPARITER
Having read your post again re "ARA Minima are not valid in this case"....
What I am proposing is that "MDH" is valid in ALL CASES VMC or IMC (ARA)
It is the complete lack of minima applicable once VMC has been gained that leads to these and other incidents.
Forget the ARA......I am not aware of any incidents like this one happening during an ARA...WHY....becasue the ARA provides an intrinstcly stable approach, albeit to (what is my opinion) in extremis at night (Ie at absolute minima)......an MDH that is far too low to GUARENTEE a safe final descent from the CTB.
Think about the ILS 200 DH and then try to justify to yourself why you should only have effectivley a 50 foot DH when approaching a deck, bearing in mind there are no lead in lights, no horizon and a !!!! load of sodiums producing utter confusion right up to the point where you reach the CTB (less than 100m from the deck).
This was a visual flight and two trained and checked crew, with a very experienced and competent P1 hit the sea. It is the procedures that were wrong, not them!!!