I can't explain why the FAA chose to put it in that part of the ATC Handbook. In any event, I'm not convinced that John's analysis on that is correct, since he didn't reference 91.205(d)(2) and 91.7(b), which suggest that an aircraft is unairworthy for IFR flight without 2-way comm, comm is electrical in nature, and that the flight must be "discontinued" if an unairworthy electrical conditions arises in flight. However, the point here is that the guidance to ATC references the guidance to pilots, and we pilots have been given our guidance by AFS.
+1
I think you're right. Other than the removal of the "expect approach clearance" verbiage about 20 years ago, they have not changed significantly since I got my IR in 1971, and I don't think they've changed much since they were first written other than the addition of language to cover radar vectors when radar came about. Anyone remember back to DC-3's and 4-course ranges in the 1930's? At the same time, with the technological advances in radios, I suspect the rate of occurrence of true lost comm situations (not counting the occasional temporary lost comm due to switchology or the like) has plummeted, making this a low priority for anything other than IR practical tests.
Other than what's in 7110.65, nothing else of which I am aware.
I've seen that written many times before, usually with the caveat that it's not what 91.185(c) says.
I've seen that, too, in pubs like IFR magazine, and again, always with the caveat that it's not by the books the pilots are given.
+1
Until now, and with that more specific AFS guidance, I think we've put that one to bed.
To a great extent, I was trying to get an answer on what the "textbook" answer is, and I think I got that. This is often an issue on IR practical tests, in which the examiner asks "what do the regs say to do," which is a test of your rote knowledge. The answer to that question is now clear to me. The examiner usually then asks, "what would you really do," and that's a test of your judgement, not your rote knowledge. The examiner is looking to see that you know both what the rules are and also when to deviate from them in order to choose the safest course in an emergent situation.I'm still trying to think of a situation where I could justify flying all the way to the destination under the rules of 91.185, and am thinking that in case of an audio panel failure, my Garmin 296 would be a good enough backup to make up for the loss of Morse ID capability, as long as the flight was not too long. (With a really long flight, I might be concerned that the GPS battery might run down.) I also doubt that I would want to head into the Sierras with that setup. But there might be destinations where I could justify continuing, so I guess the discussion is not COMPLETELY moot, although it is still probably too rare to justify the attention we all are giving it.
I just tried Kent's examples too and fltplan.com took POBER and FAMIS but not GAMIE.
The IFR clearance number (888-766-8267) would be the next best choice after the ATC facility in whose airspace you are -- they have hotlines to them all. 800-WX-BRIEF would be the third choice. And, of course, many (most?) pilots fly with handheld transceivers, too. When you look at it from a realistic viewpoint, with all the technology we have these days, it's hard to imagine how one could really completely lose the ability to communicate with ATC while IFR in the goo without losing so much other stuff that you'd be in a barn-burning emergency requiring immediate action to get on the ground without regard to 91.185(c).
If your friends work at CLT Approach, I'm sure you're right. However, that doesn't matter when taking an IR practical test, and now we know the "correct" answer in that situation.
The facts that 1) it takes years to change an FAR, and 2) in many parts of the country they don't have radar to the surface and Class B control.
I agree with Richard. That's a LOL! Skin comes well before ticket. ALWAYS!