Neutrino mass hierarchy determination for theta{sub 13} = 0

We examine the possibility of determining the neutrino mass hierarchy in the limit theta{sub 13} = 0 using atmospheric neutrinos as the source. In this limit, theta{sub 13} driven matter effects are absent so independent measurements of DELTA{sub 31} and DELTA{sub 32} can, in principle, lead to hierarchy determination. Since their difference is DELTA{sub 21}, one needs an experimental arrangement where DELTA{sub 21}L/E > or approx. 1 can be achieved. This can be satisfied by atmospheric neutrinos which have a large range of L and E. Still, we find that hierarchy determination in the theta{sub 13} = 0 limit with atmospheric neutrinos is not a realistic possibility, even in conjunction with a beam experiment like T2K or NOnuA. We discuss why, and also reiterate the general conditions for hierarchy determination if theta{sub 13} = 0.