That would be a good time to ask for alternative lost comm procedures, such as returning to the departure point. You can see that if you lost comm soon after departing with a local VOR as a clearance limit, 91.185(c)(3)(ii) would require you to leave the hold and head to your destination at the EFC and if no EFC, required to skip the hold. Better to ask to make the departure airport the destination in the event of lost comms.
You can never argue with simple logic.
As pointed out by Palmpilot, that post has some problems. I edited it above in red to reflect my (correct, if I might be so bold) understanding.
As pointed out by Palmpilot, that post has some problems. I edited it above in red to reflect my (correct, if I might be so bold) understanding.
Once upon a time there was a complete paragraph detailing the time of descent at either EFC or ETA, whether or not holding instructions were received. That paragraph was deleted back in the 1980s in order to expedite landing the lost comm aircraft ASAP when holding wasn't actually necessary for traffic reasons. You only need to delay descent these days when holding instructions have been received. The irony is, pilots never kept up with the rules changes! They keep on trying to interpret the current rule in the OLD way. Then they gripe about how the rule makes them delay descent under such trying circumstances as lost comm and clamor for a rule change! What makes it crazy is they write to the Chief Counsel for help understanding the rule and the Chief Counsel, not being pilots themselves, reach out to Flight Standards or some other FAA alphabet group for guidance and they get the same misguided interpretation from the FAA's own so-called "experts". Now, the Chief Counsel has non-RNAV aircraft flying to the destination airport even before the IAF! Arrgh!
I once wrote the ATO alphabet group, which is the one responsible for deleting the "Descent" paragraph in the first place back in the '80s, to find out exactly what they meant. Apparently, the newbies in ATO didn't have a clue what their forebearers had in mind, so they kicked my questions to the Chief Counsel. Rinse and repeat. So, if I were trying to prep for a test I'd use my interpretation of the rules, which make perfect sense, and use emergency authority to justify the action if called into question by the DPE. If I was still a DPE and you did it my way, I'd probably fall to my knees and kiss your feet!
I concur with the above two explanations. Especially where non-radar. Could be that your hand-off to approach occurred after approach released a departure with a void time and they need to park you somewhere until it's on frequency.
You are right, and it was lazy of both me and the controller not to do that. In our (partial) defense, I was less than 30 min out, and just needed a way down through the cloud deck, which had closed up locally from the forecast scattered to nearly overcast during the 3 hours since I took off. The ceiling was higher than 3,000 ft AGL, with >10 SM viz below.
Exactly. I became a primary target only when my avionics stack went dark last fall. The only way you have left to communicate is through your lateral movements on the scope. Mine were intended to convey "look, I'm doing exactly what you expected."
Exactly. In your case, common sense dictated getting out of the system, rather than using up extra ATC attention for 3.5 hours; in mine, it dictated finishing my last 15–20 min in busy terminal airspace by the book to minimise uncertainty.
Let's say you're IFR, in VMC above the clouds (probably the most typical situation for an IFR cross-country flight). Conditions below the ceiling are VFR, and you see some reasonable gaps (not just little holes) you could descend through, a ways off to your right. What do you do? That's where the thinking part comes in.
and I think you illustrate a good point in the letter of the law vs. the spirit of the law.. in the situation he described you are VFR so you fly down through the reasonably sized hole and land
In that situation, remaining in VFR conditions if possible and landing is more than just a good idea, it's specifically required by the regulation.
In Canada, the corresponding reg includes a clarification that you're not expected to divert if you're close to your destination (again, use common sense).
Well, yeah, it does matter. Lost comms isn't an emergency, loss of all electrical is. Or other serious things that can cause lost comms, like ice buildup breaking off antennas for instance. 91.185 isn't for "emergencies". John Travolta had an emergency, not lost comms. He might have acted differently under simple lost comms. In that case, descent would begin at the IAF if VFR conditions were never encountered. Would you expect ATC to clear all aircraft from FL410 to the surface all the way from DC to Maine?
I believe that was my point.
Three "ticks" plus a star at night (if I'm catching your drift)?
ZTL is pretty savvy. I've had them use me in the air and also have called me on the ground (the airport manager number rings my phone) checking on pilots several times.
