JimL,
The entire point to this debate is whether there should be such a practice as NIGHT VISUAL APPROACHES.
My argument, from the outset, is this practice should cease.
All night approaches should be conducted as monitored Instrument approaches, through the MAPT, to the FDP/CTB.
I accept that at present there is no formal recognition of the FDP/CTB.
The crux to the stability and therefore the safety of the approach is that there should be recognition of this theoretical and then physical point in space, and build the profile around it, and the MAPT.
Just because these things do not exist at present it does not mean they should not be invented.
I accept that many of you in the industry have been working on this subject for many years. Guess what....the solutions that have been implied by the current regulations and guidance do not work properly. This incident, and many others like it are the physical manefestations of failings in the past to recognise, once and for all, that night VMC over the sea simply does not exist.
The solution I have proposed works. Very well. It is safe, controlled and easy to mandate to implement.
The principles which it employs, that taken together to produce a complete profile, work regardless of the weather experienced during the approach. This is the key to preventing poor decision making due to slant range visibility during the initial descent leaving the crew "stranded" trying to execute some kind of VMC procedure.
I said from the outset that the proposal is radical. It is. It abandons some archaic presumptions which in my view are a throwback to the time when full IFR monitored procedures were something of a novelty.
For the most part, we now have equipment that if operated correctly, removes majority of the "Human Element" to night approaches and this is the key, just as it is during and ILS or NDB.
The fundemental chanllenge is to get the industry and the regulators to swallow the simple fact that being 50 feet above the deck (in extremis), when the wx is poor, is a nigh on impossible ask of a large transport helicopter. Increasing this margin is in my view a major step forward, not only providing the dynamics for a stable approach, but inherently improving the safety of such approaches.
DB