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