I asked the author of Order 8260.19. He advises me it is still somewhat a "hot potato." It is still flight inspection's call.
Yes, I shouldn't have been so definitive.
I believe the actual process is as follows:
1. If the 34:1 surface isn't clear, then Flight Inspection will assess the approach
2. During assessment, the VDA guidance will be flown "one dot low"
3. If stable descent can't be maintained at "one dot low", then VDA will not be published
4. Similarly, if a EGPWS warning occurs, then VDA will not be published
Question: When the FAA remove the VDA are they also removing the straight in minima?
VSS is a (relatively new) ICAO concept. FAA uses TERPS to determine if an approach meets the straight-in criteria.
I'm not a TERPS expert but I believe despite the obstacle, KBHM RNAV RWY 36 does meet the straight-in criteria:
- The final approach course is aligned with runway
- The computed VDA at 3.04 degrees is within limits (to MDA)
- Required Obstacle Clearance (ROC) of 250 ft is maintained when approach is flown as designed (leveling off at MDA)
- Height above touchdown (HAT) is < 1000 ft
FAA allows the 34:1 (and 20:1) protection surfaces to be penetrated. However, higher visibility limits will be imposed as a result. E.g., in this case, the minimum visibility was raised to 1 SM (5000 RVR) for Cat A
I do agree that this approach should be revisited; e.g., moving the FAF so a descent angle of 3.2 degrees can be maintained throughout.