Zeffy,
Yes, you are right. Sorry. I guess that's why you bolded the bit you did?
FYI, here in Oz we can do whatever we like for RNAV waypoints (inc SIDs or STARs), but only above the MSA (below the MSA you have to use ATC or gorund navaids to permit further descent). We have to check the tracks and distances, and if we create our own waypoints each crewmember has to independently check each one. Not that I'd bother making my own waypoints for a STAR; radar vectors are much more exciting.
