Clip4
Touchdown! Greaser!
Not from "any random location" — you're obliged by the rule to fly the cleared/flight planned route. Presumably, that route description terminates at a location (fix) where you have the ability to safely continue your navigation to an IAF. Once at the IAF, you may descend as the enroute portion is ended there. For somebody loosely filing "direct" the entire way, I can see this causing the impression you mentioned of "any random location". For them, in our age of precision navigation, this must cause heartburn. Really though, their flight planning should have assured themselves that a track from any point of radio failure to the IAF was viable both obstruction and signal-wise. From ATC's center perspective, the geometry between a track to the airport and one to an IAF from beyond the terminal area would hardly be noticeable. Once inside the terminal area it would hardly be important — TRACON's going to protect all the approaches anyway.
I get it a lot of people don’t like this regulation as written, but English comprehension prohibits making an augment the reg says, or means, leave the last point in the route and go directly to an IAP. I also get the do what you want the controllers will clear the skies for you argument, but the FAA isn’t going to ever say that because there are situations where they can’t do that and the FAA is not going to be on the losing end of a lawsuit telling you do this this short of your emergency authority. If a mid air, the FAA will argue their controller’s actions assumed you would comply with the regulation and they aren’t at fault.
The applicable parts of the reg, plain English:
Each pilot who has two-way radio communications failure when operating under IFR shall comply with the rules of this section.
By the route assigned in the last ATC clearance received; 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.
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