PHL CTLRS VOICED CONCERN REGARDING SUPVR DIRECTION TO CONDUCT VISUAL APCHS WHEN WX WAS BELOW MIN LISTED IN ATP 7110.65.

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OFFICIAL WX AT PHL 10 SM -RA OVC017. WE WERE RUNNING VISUAL APCHS TO RWY 35 EVEN THOUGH THE CEILING WAS LESS THAN 500 FT ABOVE THE MVA (1500 FT). IT IS NOT CLR TO ME WHY WE AS A REGULATORY AGENCY WOULD EVEN TRY TO CIRCUMVENT OUR OWN RULE OR HOW WE WOULD TRY TO EXPLAIN IT. IT IS A DIFFERENT RADAR SECTOR THAT RUNS APCHS TO RWY 9R THAN TO RWY 35. IN ORDER FOR THE SECTOR THAT RUNS APCHS TO RWY 35 TO HDOF AN ACFT TO THE SECTOR THAT RUNS APCHS TO RWY 9R THEY WOULD HAVE TO COORDINATE A SEQUENCE WITH THE CTLR THAT JUST HANDED OFF THE ACFT TO THEM. IN ORDER FOR THE ACFT TO SEE THE ARPT THEY HAD TO BE DSNDED TO AN ALT BELOW THE MINIMUM XING ALT (1800 FT) FOR THE FAF FOR RWY 9R. THERE IS NO WAY SOMEBODY FAMILIAR WITH OUR OP WOULD NOT BE AWARE OF THESE THINGS. WINDS DID NOT PROHIBIT LNDG RWY 17. IT IS NOT CLR WHY WE DID NOT RUN CONVERGING APCHS TO RWY 9 AND RWY 17 SINCE THE CONVERGING APCH WAS DESIGNED FOR JUST SUCH WX CONDITIONS. SUPPLEMENTAL INFO FROM ACN 762877: SUPVR INSISTED THAT CTLRS INITIATE VECTORS THAT WOULD ULTIMATELY RESULT IN ACFT BEING POSITIONED FOR VISUAL APCHS EVEN THOUGH THE CEILING WAS LESS THAN 500 FT ABOVE THE MVA. THE SUPVR STATED THIS WAS A LEGAL OP BECAUSE THE ATIS DID NOT ADVERTISE VISUAL APCHS; WE WERE NOT TELLING THEM TO EXPECT A VISUAL APCH; AND THAT 'WE HAVE BEEN DOING IT THAT WAY FOR 25 YRS.' HE ALSO STATED THAT THE AREA MGR HAD BEEN CALLED AND HE WAS IN AGREEMENT THAT THIS OP WAS NOT IN VIOLATION OF ATP ORDER 7110.65 7-4-2.