Thanks Steve, #54
I agree with all of your points; however its the unusual regulation or its interpretation that might lead us astray, e.g.
"
10. other visual references specified in the operations manual."
AMC1 CAT.OP.MPA.305(e) - Commencement and continuation of approach,
https://www.easa.europa.eu/sites/def...rch%202018.pdf page 157 / 158
And within that, weak knowledge within the regulatory authorities - your '
a basic ignorance of the meaning of instrument approach minimums, required visual reference, and what is needed to continue below DH or MDA.'
It has not been established which particular regulation the operator was using, nor the interpretation of this or any rules from previous employment, however misguided that might be.
Even so, flight over featureless sea with minimum horizon has significant risk.