wrote:
Looking at the FAA version of the approach plate, profile section, it
has
2800 to DOCAP, then descend to 2100 at CICAL for the final approach
into
OLV.

The 2,800 ft segment you see is the Hold-in-Lieu. A HIL is part of the
initial segment, which doesn't begin until the IAF. From your
direction of flight, the HIL wasn't required for you, so its altitude
didn't apply.

Regardless, ATC has a right to assign you an altitude to maintain until
you arrive at a certain fix; only AFTER you arrive there do published
altitudes apply. Until then, you're relying on their MVA to keep you
safe.

ATC has an obligation to assign an offroute altitude. If they don't
then the pilot has a regulatory obligation to challenge the lack of an
altitude assignment (one of the many changes provided by TWA 514
crashing into Mt. Weather on Dec 1, 1974.)

In this instance it would have been reasonable for the pilot to
challenge the 2,100-foot assignment since 2,800 is shown at DOCAP.

When this change to the AIM and ATC Order was discussed, I think
everyone envisioned 2,800 being assigned for a direct-to DOCAP. But,
once the real-world takes over...

The controllers really have to know the IAP to assign any altitude less
than that shown in the profile at the IF. I am not sure that is the
conservative way to go, but it is certainly legal so long as there isn't
a step-down in the intermediate somewhere that is missed.


If they had cleared you to ECILE, and told you to maintain 2,100, then
there would have been a problem. You're fine until you get to ECILE,
but the moment you pass that fix, you're in violation of 91.177.

Same thing if you had come from the north direction to DOCAP. You'd be
fine at 2,100 until the fix, but the HIL is required from this
direction and you'd be in violation of 91.177 once you started the hold
entry.


Sam: The fix DOCAP is labeld IF/IAF. Does the segment from DOCAP to
CICAL use initial or intermediate ROC ?

That is the intermediate segment with 500-foot ROC requirements. But,
at a location like this, airspace and descent gradient requirements are
limiting, not ROC. There is probably at least 1,200 feet or more, of
ROC in this particular intermediate segment. The MVA overlying this
intermediate segment is 2,000 feet.