My company's advice is that as this is now a circling procedure you are basically going to fly a visual circuit onto 21,and thus the procedure onto 21 is superfluous as you cannot use it to fly straight in.
Personally if I have to fly an approach onto 21 I would rather complete the ILS on 03 to circling minima and then when visual establish into a left down wind leg for 21.I think this is simpler than flying the 210 radial LTE to the map at 1.5 D and then turning hard left into the downwind leg ,especially if the visibility is right on minima and you are trying to lose 2400 feet.