Actually you're wrong, my quote came from the EU OPS document which is currently in use, right now, based on the proposals in the document that you quoted from.
MDA(H) is the lowest altitude (height) for the level portion of an approach flown using the traditional dive-and-drive technique
We do not fly level, we use CDFA.
I know I'm repeating myself, again but what don't you understand about this?
The AWOSG is convinced that using the MDA/H as a DA/H offers adequate obstacle protection.
Use of the CDFA technique is considered as a significant safety improvement.
My operator and the authority that I operate under do not require us to add on a buffer.
For example, at an airport I used to frequent.
VOR/DME approach with an MDA of 530'. We used to have a DA of 580', 50' buffer you see.
We now operate the very same approach, completely legally, to a DA of 530' using a CDFA.
I have yet to be charged with flying illegally or dangerously. Even though I once flew that approach to that minima with a CAA inspector on the jumpseat.
End of story.