That's not the answer I got when I called the SJC FSDO a few years
back. See my other post on this subject regarding false LOC lobes
coming from the south.
You should never ask FSDO anything technical.
Very often, DME is required in feeder routes intercepting a localizer
for the reason you say; however, this approach doesn't have DME
authorized in that context.
That said, according to AirNav, the fix NALLS can be identified using
DME off of SNS. I'd guess a charting error.
So maybe FSDO and IFRR were both right.
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