RPTR AT DEN IS CONCERNED THAT A NEW LOA EXPLAINING PROCS FOR ILS APCHS IS NOT LEGAL OR SAFE.

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AT DENVER INTL THE ATCT AND TRACON HAVE ADOPTED A LOA AUTHORIZING CONVERGING SIMULTANEOUS ILS APCHS TO VARIOUS RWY CONFIGNS. PER THE LOA THESE APCHS ARE AUTH IF THE OFFICIAL WX IS RPTED AS AT LEAST 1000 FT AGL AND 3 MI VISIBILITY (BASIC VFR). THE PROB IS THAT THE MISSED APCH PROCS IN SEVERAL OF THE CONFIGNS CONFLICT IN SUCH A MANNER THAT IF ONE OF THE ACFT EXECUTE THE PUBLISHED MISSED APCH PROC; IT WILL PUT THE ACFT OPPOSITE DIRECTION TO ACFT FLYING THE OTHER ILS APCH. SINCE FARS AND AIR TFC REGS AUTH AN ACFT TO FLY THE PUBLISHED MISSED APCH AND LOSS OF COM IS ALWAYS A POSSIBILITY HOW CAN THIS PROC BE DEEMED SAFE AND LEGAL. I HAVE NOT BEEN ABLE TO FIND ANYTHING THAT WOULD LEGALLY AUTH THIS IN THE FAA 7110.65. WHEN I BROUGHT MY CONCERNS TO THE FACILITY MGMNT THEY TOLD ME THAT A LACK OF ANYTHING IN THE FAA 7110.65 SAYING SIMULTANEOUS CONVERGING ILS APCHS ARE NOT ILLEGAL; MUST MEAN ITS LEGAL. AT A FACILITY WHERE WE ARE AUTH SIMULTANEOUS ILS APCHS TO 3 RWYS WHICH ARE A SAFE PUBLISHED PROC; IT APPEARS UNSAFE AND NOT PRUDENT TO ALLOW THE ABOVE MENTIONED PROCS.