Lost Comms clarification from you professionals?

justin jiron

Filing Flight Plan
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Jan 13, 2022
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Denver, CO Centennial
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Punkwood2k
Now, I get it, when you lose comms in IFR, you got MEA & AVE F.. no problem there..

But what about 91.185(b)... "If the failure occurs in VFR conditions, or if VFR conditions are encountered after the failure, each pilot shall continue the flight under VFR and land as soon as practicable"

My question is.. Suppose I lose comms in IFR, and abide by MEA & AVE F. But then I encounter VFR conditions.. Does this mean I now have to fly by VFR altitudes & rules, thus disregard my IFR route & altitude? What if my IFR route was in Class A, do I have to immediately descend out of Class A?

2nd question... "land as soon as practicable".. From prior explanations, in IFR conditions, I would fly my assigned route, all the way to my clearance limit (usually the destination), and then an approach... But if I encounter VFR before my clearance limit, do I now have to divert to a "soon as practicable" airport? Since "soon as practicable" might not be my clearance limit airport?
 
If the VFR conditions will get you to an practicable airport, that’s what 91.185 says to do. The unstated part is that you call and let someone know where you landed, although more than likely they’ll already know.
 
If the VFR conditions will get you to an practicable airport, that’s what 91.185 says to do. The unstated part is that you call and let someone know where you landed, although more than likely they’ll already know.
Seems more dangerous to me, to have a flight switch from an IFR plan, where controllers can anticipate your intentions, even without comms.. Suddenly changing to unfiled VFR, descending in the blind, and ATC just has to wildly guess your intended alternate? Just my rookie opinion..
 
Seems more dangerous to me, to have a flight switch from an IFR plan, where controllers can anticipate your intentions, even without comms.. Suddenly changing to unfiled VFR, descending in the blind, and ATC just has to wildly guess your intended alternate? Just my rookie opinion..
Yes, normal VFR flight can be terrifying.
 
I wonder if you were able to phone ATC if they'd let you continue to your destination IFR/VFR.

Seems like another good practical option if you started you flight less than an hour ago to just reverse course and return home. I can't imagine them getting mad at you for that.
 
Keep in mind there's a big difference between this happening to you in a C-172 and it happening to a large airliner flying under Part 121. If I encountered VFR conditions and saw I could clearly go land at some small untowered airport, I'd squawk 1200, descend, and land NORDO. For an airliner, trying to deviate to another airport is a huge deal for that new airport for the reasons you suspected. It's easier for everyone for the airliner to continue to the original destination along the route ATC expects. An airline pilot told me that, but also pointed out that they have much more redundancy than we do to prevent lost comms anyway.
 
Lost comms and into VFR - Land and get your radio fixed... not that complicated.
 
Keep in mind there's a big difference between this happening to you in a C-172 and it happening to a large airliner flying under Part 121. If I encountered VFR conditions and saw I could clearly go land at some small untowered airport, I'd squawk 1200, descend, and land NORDO. For an airliner, trying to deviate to another airport is a huge deal for that new airport for the reasons you suspected. It's easier for everyone for the airliner to continue to the original destination along the route ATC expects. An airline pilot told me that, but also pointed out that they have much more redundancy than we do to prevent lost comms anyway.
I’d also note that if my Part 25 airplane goes NORDO due to multiple systems failures, I’d probably go nearest suitable rather than nearest practicable if I found the VFR conditions to get there. ****’s getting ugly.
 
I both understand and don’t understand the directive to land. You have a busted radio and you need to land. But if it’s severe clear, couldn’t you squawk 7600 for a minute or two to indicate lost comms, then switch to 1200 and continue to your destination under VFR rules? Or to be legal, you must land before you take off again nordo VFR and fly home?
 
I both understand and don’t understand the directive to land. You have a busted radio and you need to land. But if it’s severe clear, couldn’t you squawk 7600 for a minute or two to indicate lost comms, then switch to 1200 and continue to your destination under VFR rules? Or to be legal, you must land before you take off again nordo VFR and fly home?
Imagine how confusing this reg would be if it included every permutation of equipment, weather, getthereitis, etc.

Most people can’t agree on what it says, much less what it should say.
 
I wonder if you were able to phone ATC if they'd let you continue to your destination IFR/VFR.

Seems like another good practical option if you started you flight less than an hour ago to just reverse course and return home. I can't imagine them getting mad at you for that.

It’s not. First calling from the air is damn impossible— have you ever tried calling anyone with a cell at altitude? Second, if you’re in IMC with a comm outage, ATC is clearing the airspace in front of you not behind. The rules are built with the expectation that you are going to continue to your filed destination. If you’re in VMC, then returning to your origin is certainly an option, but personally I’d land as soon as I could, get it all sorted with ATC then decide if I could continue to wherever VFR NORDO.
 
I both understand and don’t understand the directive to land. You have a busted radio and you need to land. But if it’s severe clear, couldn’t you squawk 7600 for a minute or two to indicate lost comms, then switch to 1200 and continue to your destination under VFR rules? Or to be legal, you must land before you take off again nordo VFR and fly home?
Why would you squawk 1200? Leave it on 7600 until you are on the ground. Should you encounter reasonable VMC, stay VMC and land as soon as practical & safe, but that does not mean you are now flying VFR rules. You are still on your IFR flight plan. Still IFR altitudes. And, they are still clearing everything around you. If you drop to a VFR altitude, that starts mixing you up with aircraft they may not be talking to.
 
that does not mean you are now flying VFR rules. You are still on your IFR flight plan. Still IFR altitudes.

But it does say to “continue the flight under VFR.” The R means rules. So it’s specifying the rules as visual flight rules.

It doesn’t say to continue in VMC.
 
Seems more dangerous to me, to have a flight switch from an IFR plan, where controllers can anticipate your intentions, even without comms.. Suddenly changing to unfiled VFR, descending in the blind, and ATC just has to wildly guess your intended alternate? Just my rookie opinion..
If it’s VFR you won’t be descending in the blind.
 
I didn't find anything particularly useful in the AIM regarding whether to stay with 7600 or switch to 1200 when proceeding to a nearby airport to land early VFR. Our ATC experts may choose to weigh in, but my thinking is ATC can tell you lost comms because you squawk 7600. ATC can tell you are in VMC because you switch to a VFR cruising altitude (even in Class A). ATC can tell you are going to now abort your assigned route and proceed to an available airport VFR to land early when you switch your code to 1200. If you stay on 7600, they won't be able to tell if your deviation is because you going to land somewhere VFR or if it's because you and them are on a different page about "Avenue F (AVEF)." I have only found the "squawk 1200" guidance in informal places so far but it makes sense to me.
 
Now, I get it, when you lose comms in IFR, you got MEA & AVE F.. no problem there..

But what about 91.185(b)... "If the failure occurs in VFR conditions, or if VFR conditions are encountered after the failure, each pilot shall continue the flight under VFR and land as soon as practicable"

My question is.. Suppose I lose comms in IFR, and abide by MEA & AVE F. But then I encounter VFR conditions.. Does this mean I now have to fly by VFR altitudes & rules, thus disregard my IFR route & altitude? What if my IFR route was in Class A, do I have to immediately descend out of Class A?

2nd question... "land as soon as practicable".. From prior explanations, in IFR conditions, I would fly my assigned route, all the way to my clearance limit (usually the destination), and then an approach... But if I encounter VFR before my clearance limit, do I now have to divert to a "soon as practicable" airport? Since "soon as practicable" might not be my clearance limit airport?
AIM 6-4-1 c. 2. Covers the Class A question and does a pretty good job of explaining practical vs possible.
2. VFR conditions. If the failure occurs in
VFR conditions, or if VFR conditions are encoun-
tered after the failure, each pilot must continue the
flight under VFR and land as soon as practicable.
NOTE−
This procedure also applies when two-way radio failure
occurs while operating in Class A airspace. The primary
objective of this provision in 14 CFR Section 91.185 is to
preclude extended IFR operation by these aircraft within
the ATC system. Pilots should recognize that operation
under these conditions may unnecessarily as well as
adversely affect other users of the airspace, since ATC may
be required to reroute or delay other users in order to
protect the failure aircraft. However, it is not intended that
the requirement to “land as soon as practicable” be
construed to mean “as soon as possible.” Pilots retain the
prerogative of exercising their best judgment and are not
required to land at an unauthorized airport, at an airport
unsuitable for the type of aircraft flown, or to land only
minutes short of their intended destination.
 
If the VFR conditions will get you to an practicable airport, that’s what 91.185 says to do. The unstated part is that you call and let someone know where you landed, although more than likely they’ll already know.
You are still on an IFR flight plan and have to cancel.
 
Keep in mind there's a big difference between this happening to you in a C-172 and it happening to a large airliner flying under Part 121. If I encountered VFR conditions and saw I could clearly go land at some small untowered airport, I'd squawk 1200, descend, and land NORDO. For an airliner, trying to deviate to another airport is a huge deal for that new airport for the reasons you suspected. It's easier for everyone for the airliner to continue to the original destination along the route ATC expects. An airline pilot told me that, but also pointed out that they have much more redundancy than we do to prevent lost comms anyway.
It's not going to happen to an airliner. Too much redundancy. But, let's say it did for sake of discussion. His/her Ops Specs has a list of authorized regular, refueling/provisional, and alternate airports. He/she should land at the nearest authorized regular airport, not at Weed Patch, Nebraska.
 
It's not going to happen to an airliner. Too much redundancy. But, let's say it did for sake of discussion. His/her Ops Specs has a list of authorized regular, refueling/provisional, and alternate airports. He/she should land at the nearest authorized regular airport, not at Weed Patch, Nebraska.
Would the runway at Weed Patch act like EMAS to safety stop an airliner? :eek:
 
Keep in mind there's a big difference between this happening to you in a C-172 and it happening to a large airliner flying under Part 121. If I encountered VFR conditions and saw I could clearly go land at some small untowered airport, I'd squawk 1200, descend, and land NORDO. For an airliner, trying to deviate to another airport is a huge deal for that new airport for the reasons you suspected. It's easier for everyone for the airliner to continue to the original destination along the route ATC expects. An airline pilot told me that, but also pointed out that they have much more redundancy than we do to prevent lost comms anyway.

If an airliner with at least two if not three VHF coms goes NORDO, he likely does not just have a communications problem but a total loss of electrical power and is in a flat out emergency situation. Heck he couldn’t squawk anything as his transponder is gone as well. So is all of his navs. A typical modern twin engine jet airliner will have most of the following: two engine driven generators, an APU generator, a RAT or ADG, plus a battery and inverters. The chances of losing all of this at once would likely only be due to some catastrophic event. Following a regulation regarding what code to squawk would not be an issue the crew would be concerned with. I also don’t think they’d really follow the planned route to their original destination. They’d be looking for a place to land and ASAP.
 
Seems more dangerous to me, to have a flight switch from an IFR plan, where controllers can anticipate your intentions, even without comms.. Suddenly changing to unfiled VFR, descending in the blind, and ATC just has to wildly guess your intended alternate? Just my rookie opinion..
You have to think it through logically, in a real world scenario. You file IFR and depart IFR for a flight from Tampa, FL to Chicago, IL. While you rae on your climb out you lose radios.. you follow the rules, but then 10 minutes later you are in the clear blue sky, total VFR conditions. What makes more sense.. land at the next VFR field you're safely able to do so, or fly all the way to Chicago without a radio? You are already squawking 7600.. ATC is aware and clearing the space. They'll see you flying towards an airport that's VFR and put two and two together

On the other hand, you fly to Chicago, now it's a who's who grab bag of what runway you're landing on, approach, etc.

The rule makes sense. If you can't see follow the route and altitudes.. if suddenly you're in the open just land. I bet more than half the people flying around VFR aren't talking to anyone anyway, so you're basically just one of them now
 
It's not going to happen to an airliner. Too much redundancy. But, let's say it did for sake of discussion. His/her Ops Specs has a list of authorized regular, refueling/provisional, and alternate airports. He/she should land at the nearest authorized regular airport, not at Weed Patch, Nebraska.
If the lost comm is on the ATC end, how are airline crews expected to handle it?
 
If the lost comm is on the ATC end, how are airline crews expected to handle it?
Great example. Vegas had an example like that, and recently somewhere in South America
 
If the lost comm is on the ATC end, how are airline crews expected to handle it?
The frequency you're on becomes a CTAF and they work it out. Here's a story. Los Angeles Tower's radio's go nips up. A PSA pilot takes the reigns and starts organizing things. Western why don't you turn base over there behind United and Delta you...and Braniff you... and blah blah. They all go cool and do it. Then PSA goes slats, flaps, shoulder straps, three in the green and does a Crowbar One Arrival in front of them all. I got this from a Controller that was there that day. Most of it is probably somewhat true.
 
The frequency you're on becomes a CTAF and they work it out. Here's a story. Los Angeles Tower's radio's go nips up. A PSA pilot takes the reigns and starts organizing things. Western why don't you turn base over there behind United and Delta you...and Braniff you... and blah blah. They all go cool and do it. Then PSA goes slats, flaps, shoulder straps, three in the green and does a Crowbar One Arrival in front of them all. I got this from a Controller that was there that day. Most of it is probably somewhat true.
Or…find another frequency that works. Baltimore approach went off the air when I was being vectored for the ILS. I called tower, they coordinated, and cleared me for the approach.
 
JAX went dark due to COVID last year. ATL was handing off to MIA and asking the Airline guys their ETA to fixes inside of MIA Center airspace. I couldn't even open my IFR plan and went down VFR. It was eerie quiet in the JAX area. Just some guy every 5 min on Guard asking why it was so quiet.
 
The frequency you're on becomes a CTAF and they work it out. Here's a story. Los Angeles Tower's radio's go nips up. A PSA pilot takes the reigns and starts organizing things. Western why don't you turn base over there behind United and Delta you...and Braniff you... and blah blah. They all go cool and do it. Then PSA goes slats, flaps, shoulder straps, three in the green and does a Crowbar One Arrival in front of them all. I got this from a Controller that was there that day. Most of it is probably somewhat true.
That had to be the real PSA.
 
That had to be the real PSA.
"Cancel my ATP, I'll fly PSA."

It's unbelievable how they violated clearance of cloud regs to get into KBUR "VFR." This was when they were flying Lockheed Electras that could be operated on a VFR flight plan.

Saw it personally several times in my early light airplane days.

When they became a jet airline, they also became much more responsible. Alas, San Diego, Sept 25, 1978
 
If the lost comm is on the ATC end, how are airline crews expected to handle it?

It happened at our facility once for about half an hour. Power got accidentally cut to the computers, for a fraction of a second, and everything (radios, radar, and land lines) had to reboot and recertify. Fortunately it was about 12:30 AM and there weren't that many airplanes in the airspace-almost all airliners. Most went back to their last frequency (hopefully another facility), contacted the approach control of their intended landing airport, or called their company operations and got it sorted out. Luckily, commercial phones still operated and the people on duty did a great job under the circumstances to try to resolve it in an orderly fashion.
 
That had to be the real PSA.
Yup. It was back in the 80’s. There is something just not right with there being this new PSA out there. That call should have been retired just like star athletes jersey numbers get retired when they do.
 
It's not going to happen to an airliner. Too much redundancy. But, let's say it did for sake of discussion. His/her Ops Specs has a list of authorized regular, refueling/provisional, and alternate airports. He/she should land at the nearest authorized regular airport, not at Weed Patch, Nebraska.

The OpsSpecs also most likely prohibit VFR on a revenue flight.
 
The OpsSpecs also most likely prohibit VFR on a revenue flight.
And while OpSpecs aren’t part of “this Part” that I can deviate from in an emergency, I’ll still prefer to be alive for the inquest than dead legal if that choice needs to be made.
 
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