SMA X HAD CONFLICT WITH SMT Y ON CIRCLING TIMED STRAIGHT IN APCH. SEE AND AVOID CONCEPT.

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PA28 SMA X WAS CONDUCTING VOR RWY 11R APCH; CIRCLE TO RWY 4; FOLLOWED BY PA44 SMT Y; DOING THE SAME. ZMA PROVIDES APCH CTL SVCS TO VRB AND HAS ON NUMEROUS OCCASIONS VERBALLY RENDERED THE OPINION THAT IT IS PERMISSIBLE TO CONDUCT TIMED APCHS BTWN ACFT CONDUCTING CIRCLING APCHS AND/OR DISPARATE TYPES OF APCHS INCLUDING VISUAL APCHS; AN OPINION WHICH SEEMS TO CONTRADICT FAA ORDER 7110.65J PARAGRAPH 6-7-1 ('TIMED APCHS') NOTE-A; WHICH SAYS IN PART: '... FOR A STRAIGHT-IN APCH...' IN REGARD TO THE INTENDED APPLICATION OF THE PARAGRAPH. I HAVE; ON NUMEROUS OCCASIONS; ATTEMPTED TO CHALLENGE THE VALIDITY OF THIS OPINION TO MY SUPVRS; MGR(S); AND THROUGH THE QTP (QUALITY THROUGH PARTNERSHIP) PROCESS; WITHOUT SUCCESS. TODAY'S OCCURRENCE; I WAS WORKING LCL CTL ('TWR') AND WHILE X WAS ON THE L DOWNWIND TO RWY 4 IN HIS CIRCLING MANEUVER; I HAD TO INSTRUCT Y TO TURN TO THE R TO AVOID X. HAD THE SUN BEEN LOWER; I WOULD NOT HAVE SEEN Y IN TIME TO TURN HIM; AND I BELIEVE THAT A TIMED APCH SHOULD NOT PLACE ACFT IN SUCH A PREDICAMENT THAT RELIANCE ON ANTICIPATED VISUAL SEPARATION BECOMES SOP. THIS PROCEDURAL APPLICATION IS UNSAFE.