wouldn't then you then be following the OCP gradient exactly that's not a zero ROC
---the operator has to worry about such things as bleeds as that would be detailed performance data...not applicable to the procedure design...only if the expectaion is similar to flying above the NTOFP...a protection that can't be had generically in the
IAP criteria-the operator is responsible for assuring that the airplane meets FAR 25 WAT limits ...and that a minimum gradient can be maintained.
one can not have the same luxuries as the gross vs NTOFP--in determining the minims w/o writing expensive special procedures just for an extremely rare WAT limiting case