I appreciate your comments but I stand by what I said. The AAIB have assumed what the Pilot did without much evidence to back it up. In my opinion they should have considered what I have mentioned above. They didn't. It is so easy to make this mistake and it is my belief there is a high probability that the Pilot did just that. This Pilot had plenty of experience reading plates and in the majority of cases a distance range between 2 points (DND and Base Turn) is just that. It is not normally off a dme positioned elsewhere. I agree, making up your own approach is dangerous and substituting NAV AIDS is not a good idea. I just think in this case it is more likely that in this Pilots mind when he arrived at the DND he was thinking 8 miles then I make the right turn. It is without doubt a poor depiction that could easily be rectified. If nothing else comes from the recommendations made by the AAIB then a simple ammendment to the plate would ensure that this latent error won't be the cause of an accident in the future.