Hugh,
Your references to circling would be correct if they represented the lowest value for circling with adequate visual reference to the airport and the aircraft was 300' above the highest obstacle in the circling radius. Any operation of the aircraft below the published minima in anything other than a visual maneuver is careless and reckless operation. Your assertion that a circling approach is an instrument procedure is in defiance of airmanship as well as legislation.
Yeah, well, we know where these guys are getting their ideas!
I'm glad you've enjoyed working with your crews.
Good Luck!!