Many US operators have decided, on their own, to limit circling approaches for their operation to minima equal to VFR minimums (1000 feet and 3 miles).
That's what I was ranting about earlier -- i.e., the FAA's "1000-3 club".
"Equal to VFR minimums" does not imply 1000 feet of ROC.
TERPS provides 300' above the controlling obstacle and very little maneuvering room.
No crew should ever infer that circling at 1000 AFE is a walk in the park.
Note that the Cat D circling MDA at
KORH is almost exactly 1000 feet above the airport.
How many pilots fully grasp that the circling maneuver at KORH in the "comfort" of 1000-3 weather will include trolling for obstacles a scant 300 feet below?