No descent below 4000 outside 13nm LHR

[Del Prado]

Googled this :

"Pilot-interpreted Approaches (eg ILS) Phraseology
The phrase ‘cleared ILS approach runway xx’ has, in the past, introduced some ambiguity whereby pilots have taken this to mean they are cleared to the altitude/height depicted on the approach chart immediately prior to the final approach fix. This should not be assumed; normally clearances to descend at this point will be given distinctly."



I guess it's like being at 4000' and then (erroneously) being cleared RNAV. A local crew would always challenge that but what would (insert foreign carrier with bad reputation here) do?
It's happened too often in the past and because there is so much traffic below the risk v benefit doesn't justify "cleared ILS" from 4/5000.


But I'm not sure that's exactly the problem or solution from the initial post. I think there is a problem when aircraft establish very close to (and inside)the 13/11/9 mile restrictions. There is a very small window of opportunity in which to descend to 3000' before the aircraft ends up high on the glide. R/T congestion makes it difficult to prioritise that call.
"When LOC established, descend..." doesn't necessarily help if the glide is hit before the LOC.
Descending before 13 dme because there is nothing on radar is non conformance and potentially conditions the pilots into expecting early descent and further contesting R/T when they request 3000' (see original post)

IMHO the best solution to this is to run a longer final (outside 14 dme) then the "when established,descend....." phraseology works or there is sufficient time to get in a LOC established call and a "descend ILS".