Lost Comms

Danos

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i And I Survive
If you lose comms in IMC the procedure is to hold if you arrive early and shoot the approach as close as possible to the EFC time and if there is no EFC given as close as possible to the ETA. I have never in the North East been cleared as filed. With the re-routing, vectors, and so on, my guess is that the ETA is out the window and I've never gotten an EFC time. What does this do to the hold procedure? Am I missing something?
 
If you lose comms in IMC the procedure is to hold if you arrive early and shoot the approach as close as possible to the EFC time and if there is no EFC given as close as possible to the ETA. I have never in the North East been cleared as filed. With the re-routing, vectors, and so on, my guess is that the ETA is out the window and I've never gotten an EFC time. What does this do to the hold procedure? Am I missing something?

Well there is what the reg says and what the real world would like you to do.

Yes the regulation is based on arriving at the airport when you stated according to your flight plan. You would use your last clearance limit and plan on being ont eh ground by the time in flight plan.

The reality is that ATC would like you, as a NORDO, out of their hair ASAP.

So if you were not able to eventually get into VMC and land somewhere else. Then what I would do would be to proceed to by clearance limit and land without holding.
 
The unofficial word is to ignore the regs and get on the ground as soon as you can....that's from the controller's point of view.

If a holding clearance does not contain an EFC, ask for one....it is essential.

Bob Gardner
 
Bob's absolutely right. Don't except a clearance short of your destination (whether it's a hold, or just a waypoint two hours away) without getting an EFC.

And always weigh the EFC against your fuel. ATC may have an idea of how much fuel you have, but I've heard (more than once) a conversation similar to this:

ATC: American XXYZ, enter holding at ABC as published, maintain 14000. Expect further clearance 45 minutes.
AAXXYZ: Unable 45 minutes of holding, we'd like to divert to NOP.

The IFR reserve is YOUR reserve against YOUR problems, not ATC's. Don't give any of it away without careful thought. Of course, if you know the weather is sucky, and that you can reasonably expect delays, you should put that into your planning before you add your reserve fuel.

That reminds me of another joke:

ATC: SWA1039, expedited descent please, cross ELP at 12000.
SWA: Unable ELP at 12000, we can give you 16000, SWA1039
ATC: SWA1039, don't you have speed brakes?
SWA: Affirmative, but they're for my mistakes, not yours, SWA1039.
 
The unofficial word is to ignore the regs and get on the ground as soon as you can....that's from the controller's point of view.

If a holding clearance does not contain an EFC, ask for one....it is essential.

Why is it essential?
 
Bob's absolutely right. Don't except a clearance short of your destination (whether it's a hold, or just a waypoint two hours away) without getting an EFC.

Why not?

That reminds me of another joke:

ATC: SWA1039, expedited descent please, cross ELP at 12000.
SWA: Unable ELP at 12000, we can give you 16000, SWA1039
ATC: SWA1039, don't you have speed brakes?
SWA: Affirmative, but they're for my mistakes, not yours, SWA1039.

FUNNY! But if the controller can't use SWA1039's speed brakes to correct his "mistake", he's going to have to use a tool of his own, probably a substantial off route vector.

Not so funny anymore.
 
It is an absolute no-no for a pilot to accept a holding clearance without an EFC unless the controller advises "no delay expected." This point is emphasized in instrument training publications and the AIM, which says specifically, "...it is the responsibility of the ATC controller to issue complete holding instructions (unless the pattern is charted), an EFC time and best estimate of any additional en route/terminal delay." This is also a popular question on IR practical tests, and the only acceptable answer is "no way I accept a hold without an EFC." Further, FAA Order 7110.65 (ATC Handbook, section 4-6-1c) requires the controller to issue an EFC as part of all holding instructions unless no delay is expected, in which case the controller is to advise the pilot accordingly.
 
If a holding clearance does not contain an EFC, ask for one....it is essential.
Why is it essential?
What happens if you lose comms in the hold?
I leave the hold at the EFC.
What EFC? The whole question is what do you do if you're given a hold without one, and the answer is "don't accept such a hold, because an EFC is essential"...and your answer shows why.
 
What is the point of a hold if no delay is expected?
The AIM and ATC Handbook talk about a case where for whatever reason (e.g., traffic congestion in the next sector) you're being given a clearance to a holding fix short of your destination, but the controller expects you to be cleared to continue before you get to the fix. The controller must either issue an EFC or say, "No delay expected." In the "no delay" case, the controller is supposed to issue further instructions at least 5 minutes before you reach the clearance limit. If you lose comm before you get there, you just press on through without executing the hold. If you get there without further clearance, you execute the hold and query the controller for an EFC, but if you then lose comm, you immediately depart the hold down your previously cleared/expected further route.
 
It is an absolute no-no for a pilot to accept a holding clearance without an EFC unless the controller advises "no delay expected." This point is emphasized in instrument training publications and the AIM, which says specifically, "...it is the responsibility of the ATC controller to issue complete holding instructions (unless the pattern is charted), an EFC time and best estimate of any additional en route/terminal delay." This is also a popular question on IR practical tests, and the only acceptable answer is "no way I accept a hold without an EFC." Further, FAA Order 7110.65 (ATC Handbook, section 4-6-1c) requires the controller to issue an EFC as part of all holding instructions unless no delay is expected, in which case the controller is to advise the pilot accordingly.

I gotta say this "no delay expected" was not covered in my training, and isn't covered in any of the recent instrument training materials I've seen. What I'd like to see is more explicit guidance in the AIM or FAR that says "if you receive a holding clearance with "no delay expected" instead of an EFC you should query for an EFC as you approach the holding fix, or ignore the hold in the event of lost comm."

Here's the AIM portion:
Holding Instructions.
1. Whenever an aircraft has been cleared to a fix other than the destination airport and delay is expected, it is the responsibility of the ATC controller to issue complete holding instructions (unless the pattern is charted), an EFC time, and a best estimate of any additional en route/terminal delay.
2. If the holding pattern is charted and the controller doesn’t issue complete holding instructions, the pilot is expected to hold as depicted on the appropriate chart. When the pattern is charted, the controller may omit all holding instructions except the charted holding direction and the statement AS PUBLISHED, e.g., “HOLD EAST AS PUBLISHED.” Controllers shall always issue complete holding instructions when pilots request them.
NOTE -
Only those holding patterns depicted on U.S. government or commercially produced charts which meet FAA requirements should be used.
3. If no holding pattern is charted and holding instructions have not been issued, the pilot should ask ATC for holding instructions prior to reaching the fix. This procedure will eliminate the possibility of an aircraft entering a holding pattern other than that desired by ATC. If unable to obtain holding instructions prior to reaching the fix (due to frequency congestion, stuck microphone, etc.), hold in a standard pattern on the course on which you approached the fix and request further clearance as soon as possible. In this event, the altitude/flight level of the aircraft at the clearance limit will be protected so that separation will be provided as required.
4. When an aircraft is 3 minutes or less from a clearance limit and a clearance beyond the fix has not been received, the pilot is expected to start a speed reduction so that the aircraft will cross the fix, initially, at or below the maximum holding airspeed.
5. When no delay is expected, the controller should issue a clearance beyond the fix as soon as possible and, whenever possible, at least 5 minutes before the aircraft reaches the clearance limit.
6. Pilots should report to ATC the time and altitude/flight level at which the aircraft reaches the clearance limit and report leaving the clearance limit.

While the ATC bible may tell them that issuing a hold without an EFC is permissible, the FAR/AIM doesn't tell us pilots the same thing. I interpret this section to mean that ATC will give us an EFC and a warning if further delays are possible, and if no delays are expected, he's supposed to clear us onward in plenty of time so we don't waste effort slowing down.
 
While the ATC bible may tell them that issuing a hold without an EFC is permissible,
But only if they say, "no delay expected."
the FAR/AIM doesn't tell us pilots the same thing.
No, not explicitly.
I interpret this section to mean that ATC will give us an EFC and a warning if further delays are possible, and if no delays are expected, he's supposed to clear us onward in plenty of time so we don't waste effort slowing down.
That's the essentials.
 
But only if they say, "no delay expected."
No, not explicitly.
That's the essentials.

OK, then from a pilot perspective, the only real answer when given a hold without an EFC is to ask for one. That may give ATC a clue to issue you one, even if it's only 5 minutes or so.
 
Bob's absolutely right. Don't except a clearance short of your destination (whether it's a hold, or just a waypoint two hours away) without getting an EFC.


What happens if you lose comms in the hold?

I leave the hold at the EFC.

Ummm... What EFC? ;)

This Socratic thing is confusing people. :nono:

At least it's clear that we collectively seem to know the right answer:

What EFC?

LOL. There is no EFC.

But you didn't GET one, that's the whole reason and EFC is essential.
 
What EFC? The whole question is what do you do if you're given a hold without one, and the answer is "don't accept such a hold, because an EFC is essential"...and your answer shows why.

I don't think so. If no EFC was issued I wouldn't have entered a hold so the question, "What happens if you lose comms in the hold?", implies that an EFC was issued.
 
But you didn't GET one, that's the whole reason and EFC is essential.

If I didn't GET an EFC I didn't enter a HOLD. Read the freakin' reg. If you get an EFC and you arrive lost comm at the clearance limit prior to the EFC you have to hold until the EFC time. If you didn't get an EFC and you arrive lost comm at the clearance limit you just cruise on by.


(3) Leave clearance limit.


(ii) If the clearance limit is not a fix from which an approach begins, leave the clearance limit at the expect-further-clearance time if one has been received, or if none has been received, upon arrival over the clearance limit, and proceed to a fix from which an approach begins and commence descent or descent and approach as close as possible to the estimated time of arrival as calculated from the filed or amended (with ATC) estimated time en route.
 
While the ATC bible may tell them that issuing a hold without an EFC is permissible, the FAR/AIM doesn't tell us pilots the same thing.

Doesn't it? Do you read what you quote?


Holding Instructions.

1. Whenever an aircraft has been cleared to a fix other than the destination airport and delay is expected, it is the responsibility of the ATC controller to issue complete holding instructions (unless the pattern is charted), an EFC time, and a best estimate of any additional en route/terminal delay.
 
OK, then from a pilot perspective, the only real answer when given a hold without an EFC is to ask for one. That may give ATC a clue to issue you one, even if it's only 5 minutes or so.

And ATC responds, "No delay expected." Now what do you do?
 
Doesn't it? Do you read what you quote?


Holding Instructions.

1. Whenever an aircraft has been cleared to a fix other than the destination airport and delay is expected, it is the responsibility of the ATC controller to issue complete holding instructions (unless the pattern is charted), an EFC time, and a best estimate of any additional en route/terminal delay.

Yes, I do... It's my responsibility to comply with a clearance, and not to accept any clearance I cannot understand or comply with. If a controller clears me to anywhere other than the destination airport, I cannot comply without an EFC time, because then I have no way of knowing when I can depart my clearance limit if I'm lost comm.

From a pilot perspective it's simple. You want me to go somewhere other than the airport, you need to tell me when it's safe to keep going if I don't hear from you again.

It's a classic case of a procedure published to the controllers but not published to the pilots. I'd be thrilled and have no problem if there was published guidance for pilots that says "if cleared to a fix other than the destination airport and no EFC is given, if you lose communications before reaching the fix you may proceed from the fix following normal lost communications procedures." I'm not aware of any such guidance.
 
Yes, I do... It's my responsibility to comply with a clearance, and not to accept any clearance I cannot understand or comply with. If a controller clears me to anywhere other than the destination airport, I cannot comply without an EFC time, because then I have no way of knowing when I can depart my clearance limit if I'm lost comm.

The way to know is to become familiar with FAR 91.185 IFR Operations: Two-way radio communications failure.

From a pilot perspective it's simple. You want me to go somewhere other than the airport, you need to tell me when it's safe to keep going if I don't hear from you again.
The regulation and AIM do that.

It's a classic case of a procedure published to the controllers but not published to the pilots. I'd be thrilled and have no problem if there was published guidance for pilots that says "if cleared to a fix other than the destination airport and no EFC is given, if you lose communications before reaching the fix you may proceed from the fix following normal lost communications procedures." I'm not aware of any such guidance.
You've made that clear, but such guidance has been made readily available to pilots.
 
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What is the point of a hold if no delay is expected?

It's a tool of nonradar separation, called a "paper stop". Let's say two enroute aircraft at 6000 feet are estimated to cross paths at a VOR eight minutes apart. Minimum separation is ten minutes, so some action must be taken. The later aircraft is issued a hold at a fix six miles from the VOR, its "push", the distance it would fly in ten minutes, now ends at the holding fix so the conflict at the VOR has been eliminated. Since the first aircraft is expected to pass the VOR six minutes before the second aircraft reaches the holding fix no delay is expected and no EFC is issued. When the first aircraft reports passing the VOR the second aircraft is cleared beyond the holding fix.
 
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OK, then from a pilot perspective, the only real answer when given a hold without an EFC is to ask for one.
...unless ATC said "no delay expected" as part of the holding instruction. In that case, effectively, your EFC is when you get there. If you lose comm before you get there, you blow off the hold and press on down the line. If you lose comm in the hold, you depart the hold immediately upon realizing you've lost comm.
 
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I don't think so. If no EFC was issued I wouldn't have entered a hold
Then you'd be likely to generate a PD report. If the controller says, "no delay expected" (the only legal alternative to issuing an EFC), but doesn't issue further clearance before you get there, you still enter the hold, but effectively, your EFC is when you arrive at the hold, and if you lose comm, you depart upon realizing it. I would, however, point out that an EFC is authorization to depart the hold at EFC only if you lose comm. EFC's have no meaning or purpose beyond lost comm. Thus, you do not automatically depart the hold at your EFC if you can still talk with ATC.
...so the question, "What happens if you lose comms in the hold?", implies that an EFC was issued.
Not necessarily. "No delay expected" doesn't mean you can blast on past the fix -- you still have to enter the hold if you get there without further instructions and still have comm.
 
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After reading this and a few others threads with a supposed ATC expert, we need a new forum... "Aviation Related Spin Zone."

I nominate Ron as moderator. :)
 
Then you'd be likely to generate a PD report. If the controller says, "no delay expected" (the only legal alternative to issuing an EFC), but doesn't issue further clearance before you get there, you still enter the hold, but effectively, your EFC is when you arrive at the hold, and if you lose comm, you depart upon realizing it. I would, however, point out that an EFC is authorization to depart the hold at EFC only if you lose comm. EFC's have no meaning or purpose beyond lost comm. Thus, you do not automatically depart the hold at your EFC if you can still talk with ATC.

WRONG. If I've been issued a clearance limit short of my destination and told that no delay is expected I don't get within five minutes of that clearance limit without querying ATC. ATC will then either clear me beyond the holding fix or give me an EFC. If ATC doesn't respond to my query it's because I've lost comm so I cruise on by the holding fix.

Not necessarily. "No delay expected" doesn't mean you can blast on past the fix -- you still have to enter the hold if you get there without further instructions and still have comm.
If I get there without further instructions it's only because I don't still have comm.
 
Per our resident Controller/CFII, ATC MUST issue an EFC any time a hold is assigned.
 
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