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We examine the possibility of determining the neutrino mass hierarchy in thelimit \theta_{13} = 0 using atmospheric neutrinos as the source. In this limit,in which \theta_{13} driven matter effects are absent, independent measurementsof \Delta_{31} and \Delta_{32} can, in principle, lead to hierarchydetermination. Since the difference between these two is \Delta_{21}, one needsan experimental arrangement where \Delta_{21} L/E \gtrsim 1 can be achieved.This condition can be satisfied by atmospheric neutrinos since they have alarge range of energies and baselines. In spite of this, we find that hierarchydetermination in the \theta_{13}=0 limit with atmospheric neutrinos is not arealistic possibility, even in conjunction with an apparently synergistic beamexperiment like T2K or NOvA. We discuss the reasons for this, and also in theprocess clarify the conditions that must be satisfied in general for hierarchydetermination if \theta_{13} = 0.

Mass Hierarchy Determination for $\theta_{13}=0$ and Atmospheric Neutrinos