Well, I'm certainly glad you guys CLEARED up that ambiguious issue?
I've forgotten, can ATC issue this procedure if the aircraft is in IMC
or not???? And if ATC issues it erroneously, and the pilot accepts it,
who is at fault? And what am I supposed to say, as a pilot, if ATC
issues it and I don't want to accept it? "Unable, request IFR
approach?" or something like that?

Sounds like someone should file one of those NASA forms, as the powers
that be need to know this is going on.

My take on it, is if I am below the Inititial Approach Fix minimum
altitude, I need to be on an IFR approach if I do not have the
visibility to accept a Visual Approach. That's what I am comfortable
with as a pilot. (Except Contact Approach or Special VFR, which still
require some visibility). Certainly, if I'm in a cloud and below the
IAF I need to be on an IFR approach.