What you say is true, of course, Ron, but one does have to keep in mind that
the 3600 ft altitude restriction applies until PT completion and then 1600
ft must be lost getting back to ILSIC. That will take some distance, over 3
nm in a 90 kt spam can at 750 ft/min descent, so not beginning the PT until
past 6 DME (CFIVO) would be a good idea.

Stan

This IAP also has a stepdown fix within the procedure turn area (CIFVO).
Criteria permits those as far out as 4 miles from the PT fix, based on the
presumption that no one will roll out of the procedure turn less than 4 miles
from the PT fix inbound.