freezingflyboy's organization has the right idea. When will the new pilots first approach to actual minimums be? In a controlled environment with a second pilot of more experience next to him as a backup/safety valve? Or on his own at the end of a long night in a complex twin flying cargo? Or with 30 people in the back and an incompetent captain? I have personaly seen the effect that these overly conservative artificial minima have on young pilots, as I've given IOE to them. They are expected to "just do it" at the airline, as their Commercial/Instrument ticket would indicate that they can. Yet they show up in the airline world having never seen the inside of a cloud, never shot an approach to 200+1/2, having never landed in a crosswind of more than 10 knots. Their first attempt at a 30kt crosswind is in a 27000 pound airplane, with 30 paying customers along for the ride. Unsurprisingly, it isn't pretty. The effect on their confidence is then problematic. Common sense would dictate that the 100 hour pilot shouldn't blast into 200 overcast to practice approaches on his own, but the envelope has to be expanded, and arbitrary minima such as you've described fail in that task, and thus fail the student.