I think you're flogging a dead horse here and needlessly getting toward the boundary fence of reasonable criticism. We all can, and probably have, started letdowns well above minimum heights (providing there be no contrary limitation) without any problems. I can recall several locations where that was pretty standard procedure in high wind conditions for pax comfort considering turbulence, for instance ..
aterpster is speaking to the chart rather than out of left field exception problems ..
regards, J_T