Bookworm... thanks for the reference to the real chart. Sadly, I've been having MANY more problems than usual with my internet connection from this backwater of the world, so I haven't even attempted to download it. However, I see what you're saying and agree that it makes little difference to the overall synopsis.
I'm sure that, if I've actually forgotten more than you'll know, I run the risk of not knowing enough. I do, however, try to put myself in the situations that I create, to see what sort of problems it creates. If that had been my procedure, I'd have moved Heaven and Earth to install a LLZ/DME fix to show when descent from 3200 to 3000 is possible.
I guess that, for all practical purposes, one could invent a DME distance that equates to about 4 miles NE of the BN beacon and use that for the descent to 3000 feet. However, there's no way of knowing whether or not the designer considered that and, if so, why it was not incorporated.
In any event, I would never even consider creating a procedure in Controlled Airspace without close collaboration with ATC. It is entirely possible that this particular procedure has been based on some very specific ATC requirements. These requirements need not be specified on the chart, but there would be a set of instructions available to the ATCOs to assist them to manage the approach.
FJ... there's no shame in losing an argument. Quite the contrary in fact because there is great shame in not having that argument in the first place. In practice, when all else fails, I have always survived by erring on the side of safety. It might not always be the most efficient way, but there's a better than even chance that it will keep your butt safe.