Good Business Sense
The Safety Sense 25 document was a lot of tosh when it was badly written in 2009 and eight years later it reads even worse. Even in 2009 there were more LPV approaches in the USA than ILSs - many, many of them without an ATC facility.
Badly written according to you but not according to the CAA, EASA or any official source. Part-NCO and the ANO are current as of now and say operating minimums cannot be less than those approved by the state. It is irrelevant how many LPV approaches there were in the USA in 2009 because they were all approved by the FAA whereas this thread is "Unpublished let-downs".
In 2009 I talked to the chap in the CAA who was in charge of GPS rollout, who I believe wrote the aforementioned document, and I was told that the use of GPS and GPS approaches was still all a bit too dodgy/risky and it was not a mature technology. Thankfully, he had the good grace to wind his neck in when I mentioned that his comments were a concern as my airline, one of the largest in the world, had been doing them in widebodies every day for many years.
You will of course be able to name the airline and reproduce the
unapproved GPS approaches that you were carrying out every day to
below safety altitude in IMC
The introduction of WASS in the states... many years ago ...... brought the accuracy of GPS down from 10-15 metres to around one metre. The equipment available at reasonable cost, with all the protections, even for the smallest, lightest aircraft, is incredible - knowing your position down to 10 metres or so is unbelievable.
Again, no argument that WAAS is a huge step forward. But it doesn't matter if it is 10 meters or 10cm accuracy, it still needs to be an approved procedure if you are going to descend below safety altitude in IMC.
... and here in the UK we are still screaming, "here be dragons"
Nobody is suggesting that GPS approaches are less safe than ground based approach aids. The argument is about home-made approaches. It is the job of the regulator to check that approaches are designed to the requisite standard. The CAA lag way behind the FAA in facilitating the approval of RNAV approaches, there is no argument about that.
if you are a reasonably experienced instrument rated pilot you should be able to plan a sensible, safe, non airport located, cloud break with a device that tells you your position to within 10 metres and the basic IFR law allows for this.
Only down to safety altitude unless you are using an approved procedure.
Pace:
Exactly you would probably cross the NDB confirmed with GPS and ATC and let down in a teardrop a so called un published but safe approach
It isn't much of an approach unless it gets you down below safety altitude, and it cannot do that legally unless it has been approved.
ANO Operating minima:
(3) For flights under Instrument Flight Rules, the pilot in command must select and use aerodrome operating minima for each departure, destination and destination alternate aerodrome which—
(a)must not be lower than those notified, prescribed or otherwise designated by the relevant competent authority
Part-NCO NCO.OP.110 Aerodrome operating minima — aeroplanes and helicopters:
(a) For instrument flight rules (IFR) flights, the pilot-in-command shall select and use aerodrome operating minima for each departure, destination and alternate aerodrome. Such minima shall:
(1) not be lower than those established by the State in which the aerodrome is located, except when specifically approved by that State
ICAO Annex 6 2.2.2.2 Aerodrome operating minima:
The pilot-in-command shall not operate to or from an aerodrome using operating minima lower than those which may be established for that aerodrome by the State in which it is located, except with the specific approval of that State.