Originally Posted by
giggitygiggity
Is it!
You request to do an orbit and you're under a RADAR service, ATC is monitoring you, you make a request and they either approve it or deny it. .... .....Whenever you're inside a given sector of the MRC, any instruction/approved request should give you the legally required terrain avoidance - subject to your cross check of the relevant chart (in this case, your minimum radar chart).
giggity, not saying you're wrong, I agree with what you've posted, but even if this wasn't under radar control, you's still be performing the orbit within the published hold, on the same side of the localizer as the published hold, and at or above the published holding altitude. Radar control is just an additional layer of safety.