Ahha, now we're cooking. For my money that 737 Captain was completely wrong to descend below 4000 FT at the reported stage of flight. The LLZ course is clearly within the 4000 FT MSA/MVA sector so he had no right to assume that the 3000 FT MSA/MVA applied.
Being a procedure designer, I've encountered incidents of confusion in the depiction of a holding pattern and a racetrack pattern. For this reason, I've elected to show the holding pattern as a short fat-ish shape with the racetrack longer and thinner - especially where a speed limit below holding speed is necessary in the racetrack procedure.
I believe it's quite feasible for a racetrack to have a lower minimum altitude than a holding pattern. This is primarily because the racetrack does not provide sector entry protection. The design parameters assume that the aircraft has already completed the relevant sector entry. Thus, the overall area to be protected for the racetrack is usually not as wide and, therefore may eliminate obstacles that the holding pattern must provide protection against.
So, yes, in this case, lowest holding is 4000 FT and this must be maintained until the aircraft is established in the holding pattern and has turned outbound in the racetrack and has reduced speed to a maximum of 220 knots IAS. At that stage, descent to 2800 FT may be commenced. Then, on turning inbound and established on the inbound track of the racetrack procedure, descent may be continued to 2500 FT until overhead the FAP/FAF at glidepath intercept.
The reason this approach seems to convoluted is the location of the FV Locator. It's just too close to the threshold to arrange the procedure any other way. And, as it's obviously impractical to reposition it out in the Atlantic Ocean, there is no other way that this procedure can logically be constructed.
The fact that the flight in question was approaching from the east - ie in the 3000 FT MSA/MVA sector - is irrelevant. The procedure gives him no authority to descend below 4000 FT until he meets the speed and tracking requirements of the racetrack procedure. Thus, he should have maintained at least 4000 FT, as our friend Julioviana was entitled to expect.