ACR PLT COMPLAINS THAT VOR RWY 13L/R APCH TO JFK; NY; IS AT BEST CONFUSING AND AT WORST ILLEGAL ACCORDING TO COMPANY AND CHART PROCS.

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LOCATION: VOR RWY 13L APCH AT JFK. AS PER PROCS; CAPT AND MYSELF QUESTION WHETHER IT IS LEGAL TO EXECUTE THE VOR RWY 13L/R APCH AT JFK. THIS IS ESPECIALLY TRUE AT NIGHT OR IN WX WHEN CLRED FOR VOR RWY 13L APCH. THERE ARE SEVERAL AREAS WHERE WE ARE CONCERNED. 1) THIS TECHNICALLY IS A VOR CIRCLING APCH; NOT A VOR STRAIGHT IN APCH. AS PER FM PART 2; AN APCH THAT IS GREATER THAN 30 DEGS OFF THE RWY HDG IS EITHER A CIRCLING APCH OR A VISUAL APCH. CIRCLE TO LAND ON THE VOR RWY 13L/R APCH IS NOT AUTHORIZED. 2) ACCORDING TO ACR PROCS; IF YOU ARE IN VISUAL CONDITIONS AT THE MDA; CONTINUE AT THE MDA TO A POINT (VDP OR COMPUTED NDP) FROM WHICH THE AIRPLANE CAN COMMENCE AT A NORMAL RATE FOR LNDG. THERE IS NO VDP DEPICTED AND IT IS NOT POSSIBLE TO COMPUTE AN NDP WITHOUT DME OR TIMING. ADDITIONALLY; AS PER NORMALS; THE RWY OR RWY LIGHTING (NOT JUST APCH LIGHTS) MUST BE IN SIGHT TO CONTINUE DSCNT BELOW THE MDA AND LAND. THE APCH PLATE; HOWEVER; SAYS '...WHEN VISUAL REF ESTABLISHED; FLY VISUAL TO ARPT VIA LEAD IN LIGHTS TO RWY 13L OR 13R.' THE APCH PLATE AND COMPANY PROCS ARE CONTRADICTORY SINCE I AM ON/CLRED FOR A VOR APCH. THE APCH PLATE TRANSITIONS ME TO A VISUAL APCH; WHICH NOW NEGATES AN MDA. THEREFORE; I AM NOW FLYING A VISUAL APCH AND CAN COMMENCE A DSCNT AT THE MAP. THIS CAN LEAD TO AN ACFT DSNDING TOO LOW; TOO EARLY; ESPECIALLY SINCE THERE IS NO VDP; COMPUTED NDP OR VISUAL LANDMARK. IT IS INTERESTING TO NOTE THAT THIS SAME VOR APCH IS ALSO A VISUAL APCH TITLED 'SHORE VISUAL RWY 13L/R AT JFK.' ON THE SHORE VISUAL THERE IS A VISUAL REF POINT; TWIN STACKS; USED TO CONTINUE THE DSCNT TO RWY 13L. NO SUCH VISUAL REF POINT EXISTS ON THE VOR RWY 13L/R APCH. PLEASE TAKE A CLOSE LOOK AT THIS APCH. I FEEL IT IS AMBIGUOUS TO OUR PROCS AND COULD LEAD TO A SERIOUS MISHAP. ONE LAST FACTOR; THE FLT ORIGINATES IN BOSTON; IS A SHORT LEG TO JFK; IS THE LAST LEG OF A 13+ HOUR DAY; AND IS AT NIGHT. FIRST TIME CREWS INTO JFK IN THIS SIT ALREADY HAVE THEIR HANDS FULL. THIS APCH IS GOING TO GET SOMEONE INTO TROUBLE. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: RPTR INDICATED THAT HIS CARRIER REQUIRES A GAR IF THE RWY ENVIRONMENT IS NOT IN SIGHT AT THE MAP. HE CONTENDS; AND IS PROBABLY CORRECT; THAT THE RWY IS NOT VISIBLE FROM THE MAP AT 800 FT EVEN ON A CLR NIGHT. IN THIS CASE IT WAS NOT AND A GAR WAS EXECUTED. HIS AIRLINE ALSO DOES NOT ALLOW THE USE OF LEAD IN LIGHTS WHEN THE RWY IS NOT IN SIGHT AND HE SUGGESTS THAT THIS APCH BE REMOVED FROM THEIR MANUAL SINCE THERE IS A VISUAL APCH THAT PARALLELS THE VOR APCH; BUT USES HIGHER MINIMUMS. THIS WOULD ALLOW THE ACFT TO BE AT 1500 FT AT THE 2.6 DME; WHICH IS AT OR ABOVE THE NORMAL PROFILE FOR MOST ACFT; GIVING THE CREW A BETTER CHANCE OF SEEING THE RWY. IT WOULD ALSO ALLOW THE USE OF THE LEAD IN LIGHTS AS AN AID UNDER HIS AIRLINE PROCS. RPTR EXPRESSED THE CONCERN THAT THE TENDENCY IS TO BEING A DSCNT FROM THE MDA TOWARD THE RWY AND THE INEXPERIENCED CREW WILL THEN BE MUCH TOO LOW TOO EARLY. RPTR IS FOLLOWING UP ON THIS PROB WITH HIS COMPANY.