A BAE4100 DSNDS TOO SOON DURING THE EWR ILS APCH TO RWY 22L. APCH CTLR'S CLRNC WAS CITED AS BEING CONTROVERSIAL AND IN CONFLICT WITH THE APCH CHART.

Narrative

NEW YORK APCH CTL ISSUED THE CLRNC '3000 FT UNTIL ESTABLISHED CLRED THE ILS RWY 22L EWR.' WE WERE ESTABLISHED ON THE LOC PRIOR TO TEB VOR AND UPON XING; WE BEGAN A DSCNT TO THE PUBLISHED ALT ON THE APCH CHART OF 1500 FT MSL. TWR ADVISED US THAT WE WERE SUPPOSED TO MAINTAIN 3000 FT UNTIL GS INTERCEPT; WHILE WE WERE DSNDING BELOW 2000 FT MSL. WE THEN CLBED BACK UP AND INTERCEPTED THE GS. THERE WERE NO TFC CONFLICTS. IF INTERCEPTING THE GS AT 3000 FT IS WHAT THEY NORMALLY EXPECT; IT SHOULD BE NOTED ON THE APCH CHART OR SPECIFICALLY ISSUED. SUPPLEMENTAL INFO FROM ACN 428877: ON RADAR VECTORS WITH NEW YORK APCH; GIVEN A HDG AND '3000 FT UNTIL ESTABLISHED ON ILS RWY 22L LOC; CLRED ILS RWY 22L EWR.' FLT WAS ESTABLISHED ON LOC PRIOR TO TEB VOR. 1 MI PAST TEB VOR; FLT STARTED DSCNT TO 1500 FT AS PUBLISHED ON ILS RWY 22L EWR CHART. AT APPROX 2000 FT; TWR INSTRUCTED THE FLT TO CLB BACK TO 2500 FT DUE TO TEB TFC. TWR THEN ADVISED THAT ACFT ARE TO MAINTAIN 3000 FT UNTIL GS INTERCEPT. I BELIEVE THAT IF ACFT ARE TO MAINTAIN 3000 FT TILL GS INTERCEPT THAT THE APCH PLATE NEEDS TO BE UPDATED TO STATE THE '3000 FT TILL GS INTERCEPT' INSTRUCTION.