212 man
Surely there are two distinct points here? The first is whether or not CDFA procedures are “mandated” for helicopters - surely they are not since all of the guidance / regulation appears in FW material (e.g Eu-Ops, from which helicopters are expressly exempted).
The second point is a discussion over whether or not it is a good, better or worse procedure for helicopters. That isn’t a straightforward answer, since it doesn’t aid older helicopters at all, but just adds height to the minima (the CDFA ‘DA’ is always higher than an MDA(H)).
Your point about what to do when the missed approach point is past the threshold is surely moot? This is really just the official point from which to start the Go Around - I certainly wouldn’t expect to try to recover from there BUT I will have probably been flying a level segment at the minima for some time prior to the MAPt so would expect to commence a visual approach from somewhere before the MAPt - possibly from a similar geographic position that the CDFA would have put you at, but from a lower altitude.
I just don’t think we have the same problems as the FW guys with the ‘level ‘ bit of the current procedures, particularly at the sort of airspeeds you can elect to fly the approach if it looks marginal.
We have had no indications at all from the Authority here that we are expected to use CCDFA procedures.
The quickest answer to Geoffers problem is surely to switch to Aerads?!