VOR-DME wrote:

If it were a VOR-DME this would make sense, because of the potentially
reduced lateral precision of the VOR compared to an ILS, however on a
LOC approach the marker that is there is sufficient to locate the FAF.


Maybe not.

For a fix to be satisfactory for use as a FAF, the fix error should not
exceed +/- 1 mile. It may be as large as +/- 2 miles when the missed
approach point is marked by overheading a navaid, except for 75 MHz markers;
or a buffer of equal length to the excessive fix error is provided between
the published missed approach point and the point where the missed approach
surface begins. A normal powered fan marker has a fix error of +/- 2 miles,
a low powered fan marker has a fix error of +/- 1/2 mile.


Even though it is labelled ILS or LOC/DME the note requiring
reception of both is not specific to the LOC approach.


Where is DME used on this approach? At WEBVE and JUGBA. WEBVE is used on
the ILS and LOC/DME approaches but it's also an intersection with a CVV
radial so it can be identified without DME. On the ILS you'd leave 3000'
MSL on the glideslope and begin the missed approach procedure at DH. On the
LOC/DME you'd leave 3000' at the FAF, JUGBA, and also start your timing for
the missed approch there. JUGBA FAF is used only on the LOC/DME approach
and it appears the OM alone isn't sufficient to be a FAF, thus DME is
required only for the LOC/DME approach.


I'm guessing they are requiring the DME reception because of the
missed approach. Tracking outbound on 338 PAE they want you to use
13.9 DME to identify WEBVE INT. How far away is the Penn Cove VORTAC?


It's 18.3 miles from WEBVE, and the divergence angle of 70 degrees with the
localizer puts iy well within the fix displacement limits of an
intersection. Note that WEBVE is identified as INT on the plate.