Approach ban and circling

[A4]

Thought I'd revive this one as I've come across some additional information whilst studying.

Under the "Acceptable Means of Compliance and Interprative Explanatory Material (AMC/IEM)" associated with JAR-OPS, it states as follows:

IEM to Appendix 1 to JAR-OPS 1.430, paragraph (f) Visual Manoeuvring (circling)

1 The purpose of this IEM is to provide operators with supplemental information regarding the application of aerodrome operating minima in relation to circling approaches.

2 Conduct of flight - General
2.1 For these procedures, the applicable visibility is the meteorological visibility (VIS). So Approach ban is not applicable?
2.2 The MDA/H and OCA/H minimums included in the procedure are related to aerodrome elevation.

3 Missed approach
3.1 If the decision to carry out a missed approach is taken when the aircraft is positioned on the approach axis (track) defined by radio-navigation aids, the published missed approach procedure must be followed. If visual reference is lost while circling to land from an instrument approach, the missed approach specified for that particular instrument approach must be followed. It is expected that the pilot will make an initial climbing turn toward the landing runway and overhead the aerodrome where he will establish the
aeroplane in a climb on the missed approach track. Inasmuch as the circling manoeuvre may be accomplished in more than one direction, different patterns will be required to establish the aeroplane on the prescribed missed approach course depending on its position at the time visual reference is lost unless otherwise prescribed.
3.2 If the instrument approach procedure is carried out with the aid of an ILS, the Missed Approach Point (MAPt) associated with an ILS procedure without glide path (GP out procedure) should be taken in account.

4 Instrument approach followed by visual manoeuvring (circling) without prescribed tracks
4.1 Before visual reference is established, but not below MDA/H - The flight should follow the corresponding instrument approach procedure. Again -carry on down the ILS to Circling minima?
4.2 At the beginning of the level flight phase at or above the MDA/H - From the beginning of the level flight phase, the instrument approach track determined by radio navigation aids should be maintained until:
a. The pilot estimates that, in all probability, visual contact with the runway or runway environment will be maintained during the entire procedure;
b. The pilot estimates that his aircraft is within the circling area before commencing circling; and
c. The pilot is able to determine his aircraft’s position in relation to the runway with the aid of the external references.
4.3 If the conditions in paragraph 4.2 above are not met by the MAPt, a missed approach must be carried out in accordance with the instrument approach procedure.
4.4 After the aeroplane has left the track of the corresponding instrument approach procedure, the flight phase outbound from the runway should be limited to the distance which is required to align the aeroplane for the final approach. Flight manoeuvres should be conducted within the circling area and in such way that visual contact with the runway or runway environment is maintained at all times.
4.5 Flight manoeuvres should be carried out at an altitude/height which is not less than the circling minimum descent/altitude height (MDA/H).
4.6 Descent below MDA/H should not be initiated until the threshold of the runway to be used has been identified and the aeroplane is in a position to continue with a normal rate of descent and land within the touchdown zone.

So I think it would be acceptable to ignore the approach ban - because the applicable minima is the met viz not the touchdown RVR.

Regards

A4