Yes
RBF, I completely agree with what you and
Westhawk have said about TERPs circling criteria. I'm also aware that the FAA has been wrestling with that criteria for quite a while - in fact, it was brought into very sharp focus by a rather messy prang, some years ago, involving a Bisjet (I think it was) using a circling approach in lousy weather in Colorado.
The argument against appears to concern the loss of utility projected to occur as the result of the higher minima which would be required as a consequence of the larger obstacle protection areas dictated under this standard.
The opposing argument is the greater safety and greater flexibility that is available when using more realistic circling area dimensions. Yes, sure, there's every chance that circling MDA will be increased by the larger circling area, but I've always reckoned that this was the very reason why the TERPs circling area criteria is unrealistic.
As a Pans Ops procedure designer for most of the last 20-odd years, in a place where circling MDA is often quite high, I've found some flexibility in the use of it's circling criteria that has allowed a reasonable compromise between circling area dimensions and aircraft maneouvrability, especially for Cat. D and the larger Cat. C aeroplanes. I think that the FAA's real problem is that they'll have to put in a LOT of design effort which could cost them a lot more than they'll ever be able to recoup. I hope that I'm wrong about that but I fear that the real argument relates more to dollars and cents than to safety.