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theshawnch@reddit

Lost coms is not just one way. What happens if the sector goes ATC zero because of a fire on the facility, equipment failure, etc and nobody has comms?

You don’t want 20 pilots in a sector just throwing the book out the window and shooting the same approach “just because they can claim emergency privileges”.

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Virian@reddit

But isn’t the alternative that now those same 20 pilots are potentially all holding at the same fix?

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I mean I wasn’t really arguing for everyone holding indefinitely, but with holds at least many planes can be in the same hold at different altitudes, whereas the approach does not offer the same freedom.

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LeatherConsumer@reddit

If a sector goes ATC zero you will be able to tell because you'll be able to talk to other pilots. ATC zero does not mean the frequency is being jammed, it just means that ATC is gone for some reason. Nobody having comms is virtually impossible.

Realistically, if a sector goes ATC zero pilots will just talk to each other and coordinate appropriately like they would on CTAF. Even if they didn't and everyone was holding at the clearance limit, there would be a LOT of airplanes with the same clearance limit and the risk of a mid-air is pretty much the same.

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gbchaosmaster@reddit

Once had a guy in the pattern with a stuck mic blocking everybody at a busy training airport. Only lasted a few minutes but it was chaos. Most people were squawking 7600, a few had the sense to switch to guard, but it was a dicey situation. I just broke off and landed at the ramp until it was over.

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Donlok21@reddit

lol yeah I forgot about that. I got delayed cause of it

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flyingkea@reddit

Happened recently in Perth, Western Australia. Control tower was evacuated one night. I believe all the pilots just coordinated with each other, and landed safely. (No different to usual ops lol, we all fly to busy CTAFs in our high capacity jets)

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madness2live@reddit (OP)

You know - you actually make a good point I didn't even think about!!

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usmcmech@reddit

About 15 years ago Chicago TRACON went offline after a contractor set fire to the server room. Thank God it was a nice September VFR day, ADS-B, TCAS and other facilities were able to work things out.

So it's not just a crazy theory.

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Mithster18@reddit

When the 2012 Christchurch Earthquakes happened Airways had to be evacuated and the entire of NZ turned into uncontrolled airspace, with airNZ defaulting to be ATC.

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madness2live@reddit (OP)

So then I guess it really is a case by case basis. Would it be legally ok to say you can just excerise emergency PIC authority and shoot the approach BUT if its the scenario you're talking about - pilots would just have to talk to eachother and coordiante like they did at KBUR a few months back?

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geekmug@reddit

The book is not designed to deal with such a scenario. You hope that you can find another freq and/or resort to treating it like a CTAF in the worst case. If that happens in IMC, you are in a real emergency.

You won't have ATC to deconflict the altitudes or stack the arrivals. 20 aircraft crossing the same fix (airport) and reversing course or holding at an IAF is nightmare material. Even with 2 aircraft, 10 mile in trail is enough to make chaos.

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JT-Av8or@reddit

What is SCATANA is declared AND a solar coronal mass ejection happens, taking out all satellite navigation at the same time!?! I absolutely want a Cessna holding over my final approach corridor in that case 🤦‍♂️

For real though, don’t confuse the kid. In real life just 1) get VMC if possible and then stay out of IMC or 2) shoot the most obvious approach ASAP and clear the runway. Know the book answer and that’s what you tell the examiner and when I ask “very good, you studied, what would you go for real” I want to hear “shoot the most obvious approach and clear the runway.”

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Due-Letterhead6372@reddit

If a sector goes ATC zero then other facilities will pick up the slack, that is generally what happens. When PCT went ATC zero a couple weeks ago Washington Center picked up the slack until they got back up and running again.

In today's radar environment, filed ETA is rarely accurate. Its very common to get shortcuts, re-routes, or be stuck at a different altitude than planned resulting in different winds. ETA used to matter a lot in non-radar environments because it was one of the primary ways ATC would separate you. They would use position reports and ETAs to fixes to make sure only one airplane was occupying a chunk of airspace at a time.

When was the last time you updated your ETA enroute with ATC in real life? I have never done it personally.

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thatguychuck15@reddit

Denver went ATC zero multiple times during the initial covid rush with nobody “picking up the slack”.

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Due-Letterhead6372@reddit

That's when you do the "communicate" thing and talk to other pilots on freq.

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imblegen@reddit

In addition, if it's lost comms on the atc end of things, pilots are still capable of communicating with each other by using the tower frequency or even guard as a CTAF at that point.

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Imaginary_Amoeba3461@reddit

It’s mostly limited to large airports but some STARS have specific lost comm instructions as well. Not super relevant but probably worth knowing at the CFII level.

SLC example: https://aeronav.faa.gov/d-tpp/2605/00365JAZZZ.PDF

LAX: https://aeronav.faa.gov/d-tpp/2605/00237ANJLL.PDF

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SrPoofPoof@reddit

Opposing Bases, a podcast by two controllers, talked about lost comms from an ATC perspective on episode 278. They basically say exactly what your CFII instructor is telling you. It’s a great listen to get the perspective on the guys actually working you when you’re lost comms.

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PH_Flyer08@reddit

Pro gamer move- instead of filing direct to the airport, file to the IAF of the most likely approach, then the airport. Then it more or less renders this debate moot.

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randombrain@reddit

No it doesn't.

It makes no difference at all what your route to the airport is. The airport itself is (nearly) always your actual clearance limit.

91.185 says to fly your entire route to the clearance limit and then (if necessary) hold over the clearance limit before continuing to an IAF. Any IAF. The one you filed in your route or any other one that makes sense to you.

In reality, yes, if you file and—this is important—are cleared via an IAF, we aren't stupid and we can figure out what you're doing if you descend and head in on the approach without holding at the clearance limit. But that is not what 91.185 says to do, so the debate is back at square one.

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PH_Flyer08@reddit

There’s the black and white of the FARs, and then there’s good judgment and PIC authority. I see absolutely no good reason to fly over the airport (after passing an IAF in this scenario) to then turn around and fly back to the same IAF again. I’m squawking 7600, shooting the approach,and landing. I’m minimizing my time and by extension my risk bumbling around in IMC with no comms, and I’m minimizing the time you’re having to worry about separating my NORDO airplane from other traffic. 91.185 doesn’t explicitly say this, but IMO this is a “land as soon as practical” scenario.

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randombrain@reddit

If there's a difference between the black and white and the good judgement then there's a debate.

Putting an IAF on your flight plan doesn't do anything to end the debate. It's not relevant to the CFR.

Also you're assuming that you're going to get the route you filed. That's not necessarily a good assumption.

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PH_Flyer08@reddit

In this case, yes, I’m assuming I got “cleared as filed” with the IAF included. We also in this scenario haven’t declared WHEN we went lost comm. If I got a “cleared direct ABC IAF, expect XYZ approach” or even “turn right 090, vectors for the RNAV” and THEN I lose comms… I am intercepting the approach course and landing.

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randombrain@reddit

Yes, that is good. That is precisely why we tell you the purpose of a vector, to update your expected routing.

We tell you which approach to expect so that you can start planning and briefing and programming it, but it is true that "expect XYZ approach" also updates your lost-comm procedure.

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madness2live@reddit (OP)

Great convo gents! So u/randombrain, since you're ATC I'll pick your brain...do you think flying over the airport after passing an IAF to then turn around (or possibly hold at the airport) and then fly back to the same IAF again SHOULD or should NOT be done?

From a controllers perspective - do you want us to do that, or fly straight to the IAF and shoot the approach?

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randombrain@reddit

From a controller's perspective I'll second what /u/geekmug said. Generally speaking we want you to be predictable AND we want you on the ground ASAP.

The problem is that the FAA considers 91.185 to be the most predictable course of action, so that's the official guidance. "ATC expects you to follow 91.185 exactly."

But 91.185 doesn't get you on the ground ASAP.

It's a case of the regs and official legal interpretations protecting for an absolute worst case non-radar scenario... which theoretically could happen but is very unlikely in the modern era.

I can't give an official answer other than "91.185." But I agree that we probably want you down sooner rather than later.

Of course the real true answer to this question is: Buy a $200 handheld backup radio. Or at the very least call 1800WXBRIEF from your cell phone and press 9 for "I'm having an inflight emergency." That way you don't lose comms in the first place.

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geekmug@reddit

If you fly to the airport, then you have shutdown the airport until you are on the ground. ATC has no idea which way you are going to turn once you reach the airport, because you may not even know which runway was being used. Even if you did, very few (probably zero) approaches have an IAF at the airport, so you are about to make up some routing to get from there to a random IAF.

ATC has no way to know what your next move is going to be, so they have to protected for all of it. Imagine there is a 3+ mile bubble around you that they are keeping other aircraft out of, so nobody can arrive or leave that airport with you orbiting around it. So, I can all but guarantee you that every ATC will say their preference is for you to put your wandering missile of an aircraft on the ground ASAP, including landing somewhere else along your route.

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ebaydan777@reddit

hes correct. you are 91.3, you make the decision. BUT, I think during a checkride you explain it exactly as #1 and #2 states. Fly to the airport, then to the IAF and in. You then tell the DPE that hey, while those are the rules THIS is an emergency, im going to 91.3 and not confuse ATC and get this plane down by just going to the IAF directly...

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Pilot-Imperialis@reddit

Your CFII is correct. On the IR checkrides at our school the local DPEs want the students to say your answer as the legally correct answered, followed by in a real emergency they’d exercise their PIC authority under 91.3 to get the plane on the ground.

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madness2live@reddit (OP)

Question - does this same principle allow you to SKIP flying to your clearance limit (the airport) and just going straight for an IAF? Or should you still fly to the airport since its your limit, ditch the idea of holding until EFC/ETA, and just go straight for the approach?

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Pilot-Imperialis@reddit

In a real life loss comms scenario, squawk 7600, follow MEA and AVEF as normal, but if your clearance limit is the destination airport, fly to the most sensible IAF instead and shoot the approach. Don’t overlay the airport first. All you do is waste time and fuel.

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dbhyslop@reddit

Bonus points if you filed an IAF on the way

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geekmug@reddit

If you file anywhere busy, then you will get a full route clearance to put you on a preferred route. And then what? The only time this trick would help is a busy destination.

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madness2live@reddit (OP)

Exactly the info I was looking for... thank you brother!

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randombrain@reddit

This is the actual question. As I mentioned in my comment to /u/erik325i, the question of "hold over the airport or don't hold over the airport" is moot 100% of the time.

The answer to this question is that probably ATC wants you to skip flying to the clearance limit and get on the ground ASAP. But you might be going to one of the two remaining non-radar approach controls in the NAS (HLN or TWF).
Or you might have lost your transponder entirely and not know it.
Or ATC's radar might be completely broken (cough cough EWR cough).
Or ATC might be unable to provide services altogether, although as others have mentioned that means anything you do is likely to put you in conflict with someone else doing the same thing.

Bottom line is that there's no clear answer. Probably you should skip overflying the clearance limit and just get on the ground safely as soon as you can. But this is truly the PIC's decision to make based on the specifics of the situation, not something that can be determined ahead of time.

Come up with an answer and justify it.

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JT-Av8or@reddit

THIS IS THE WAY

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madness2live@reddit (OP)

Thank you!!

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packardrod44@reddit

I was specifically asked this question on my IR ride. I gave the book answer, but the DPE and I talked about a real life situation. That squawking 7600 OR 7700 and blasting in is well within your PIC authority and would be what ATC would expect. They will be blocking large swaths of airspace and keeping everyone away from you. In the end, you're a big problem they need to get rid of. If you do something unexpected that's when things get scary or unknown.

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WhiteoutDota@reddit

we are now an emergency aircraft and can deviate from any rules.

I absolutely hate when people say this. No, just because you're an emergency does NOT IN ANY WAY MEAN YOU CAN DEVIATE FROM ANY RULE. The regulation is clear: you can deviate from the rules of PART 91 to the extent necessary to meet the emergency. The FAA may question why you broke the rules and can absolutely deem you in violation of them if your reason for deviating from the rules was unreasonable.

That being said, shooting an approach in a lost comms scenario is NOT unreasonable, and is a very good idea. You do not know why the radio failure has occurred, for all you know there could be a fire in the cowling that has been melting wires and is soon to be a much greater emergency.

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jliptty@reddit

A couple notes from an old controller. The clearance limit is almost always an airport, unless you are cleared to a fix to hold, then that becomes the clearances limit. ATC expects you to do anything humanly imaginable when you squawk 7600, so just start the approach and get on the ground. But know the book answer.

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erik325i@reddit

Your entire debate is about holding at the clearance limit. 91.185 does not tell you to “Hold” at all. Simply “commence descent and approach as close as possible to EFC or ETA” or “leave the clearance limit at EFC or upon arrival at clearance limit”.

If you are lost coms and see that you’re running a few minutes fast, simply slow down to try arriving at the clearance limit on time.

Why does every CFII think that a lost comms aircraft is suddenly going to arrive so much ahead of schedule that requires a hold?

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randombrain@reddit

This is a good point. I thought I disagreed with it, but then I read it more carefully and you're correct.

Usually the debate is "go straight to an approach or proceed all the way to the airport first," i.e. "do what ATC probably wants but not necessarily, or follow the letter of 91.185."

/u/madness2live is asking about whether to hold over the airport or just go to the airport and then go to an IAF immediately.

The only time you would have to hold over the airport is if you had been given an EFC, because 91.185(c)(3)(ii) says to depart the airport at your EFC if one was given. That might necessitate holding. However, you're never going to get an EFC regarding your destination airport... it's your destination. You're not expected to need further clearance from it.

So the only answer is "depart the airport upon arriving over it."

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Ok-Door-4991@reddit

Textbook answer is always the right answer unless you are deviating and can justify it in the interest of safety. Do what you want just make sure you have justification for not doing the book, if you have 3 hours endurance, and decide not to wait 20 minutes for you EFC..

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voretaq7@reddit

He is saying for #2 (and I guess technically #1, but he did not explicitly say "do this also for #1") that AIM 6-4-1 allows us to ditch the idea of holding entirely, and just flying past the clearance limit and then direct to shooting the approach. By squawking 7600 in IMC, we are now an emergency aircraft and can deviate from any rules.

He’s not wrong, I would consider lost comms while IFR in IMC to be an emergency (an itty bitty one, but still an emergency because I can’t do shit for traffic separation and ATC can’t advise me of big chunks of metal flying in my general direction).

BUT the key is that you - the pilot - must behave in a predictable manner as a good little IFR blip squawking 7600, doing all the things 91.185 tells you to do unless there’s a really good fucking reason.

One such really good reason right there in the reg is if you find your way to VMC and can continue the flight under visual flight rules - it is preferable to everyone that you switch to an appropriate VFR cruising altitude and use see-and-avoid for traffic separation rather than continuing under IFR and going back into the clouds with no working radio.

Other really good reasons are “I lost my radios and now I’m losing instruments and lighting is getting dim, I think this is an electrical failure that’s about to take out all my nav gear.” and “Well shit, now I smell smoke...” - in those cases you do what you gotta do to find VMC or the nearest airport, and you trust that ATC is actually paying attention to your 7600 blip on the scope.

You think a examiner will be ok with me teaching both methods or should I just stick to textbook and not open a can of worms?

Teach what the regs say to do.

If the examiner asks probing questions explore them in a scenario-based decisionmaking exercise (“So you lost your radios and you’re proceeding per 91.185, and then this happens - How would you handle it? Do you think handling it this other way would be better? That appears to be in violation of 91.185, what gives you the authority to do it?” etc.)

This is also (IMHO) how you should approach it with students. Get them to the point where their default reaction is to say “Oh I’ll just do 91.185...” and then throw them the curveballs as aeronautical decisionmaking exercises. Make them reach the conclusion of how to handle the additional issues, so that when this happens to them in real life their brain is already primed to handle a second problem and not just slavishly follow 91.185 until the battery dies or panic and dive for the nearest airport / last reported pocket of VMC when ATC doesn’t expect that.

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madness2live@reddit (OP)

All good points - thanks man!

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Due-Letterhead6372@reddit

Was this post formatted by AI?

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Iliyan61@reddit

written by AI

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madness2live@reddit (OP)

No haha, I just broke it out in chunks to make it easier to read

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Due-Letterhead6372@reddit

Gotcha, lol. For what its worth, the real life answer told to me by controllers is they want you on the ground ASAP. Do not overfly the airport before starting your approach, do not enter a random hold, just go direct to an IAF and shoot the approach from there, they will figure out what you are doing and clear everybody out of your way.

I will note, nowhere in 91.185 does it say to hold if you arrive at your clearance limit before your ETA. If you arrive early, simply proceed to a fix from which an approach starts and fly the approach. I would consider that to be as close as practical to your ETA.

These regs were written before radar was ubiquitous, so they had to account for people being IFR in a non-radar environment. Now that radar is pretty much a given in the CONUS, you don't need to worry about things like having to arrive right at your ETA.

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meticulouslycarless@reddit

You are correct it doesn’t say to hold but I think we all imply that because it says proceed to the approach as close as possible to land at ETA.

I know I’m paraphrasing and I think that’s about what it says. Been a minute since i’ve read it

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madness2live@reddit (OP)

Sweet, thank you man! I figured we're allowed to just say "Screw it I'm shooting the approach" but was a little hesitant to teach that on the checkride.

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Due-Letterhead6372@reddit

When I took my IFR checkride I gave the DPE the book answer and he straight up said "That's cool, but don't do that in real life. Just fly the approach, ATC can see what you're doing."

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madness2live@reddit (OP)

That make sense, but someone below actually brought up an angle I hadn't thought of... what if your comms are working but the sector goes ATC Zero.

This happened before at KBUR on the news a little while back - but I think it was all VMC so all the southwest guys were just talking to eachother over the air.

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Due-Letterhead6372@reddit

Here is a copy paste of my reply to them:

If a sector goes ATC zero then other facilities will pick up the slack, that is generally what happens. When PCT went ATC zero a couple weeks ago Washington Center picked up the slack until they got back up and running again. Unless there is some catastrophic failure which wipes out large portions of the NAS, there will be a way for someone to control that airspace. There are lots of part time approach control where approach owns the airspace when they are open, then the center or another TRACON takes it over when they close for the night.

In today's radar environment, filed ETA is rarely accurate. Its very common to get shortcuts, re-routes, or be stuck at a different altitude than planned resulting in different winds. ETA used to matter a lot in non-radar environments because it was one of the primary ways ATC would separate you. They would use position reports and ETAs to fixes to make sure only one airplane was occupying a chunk of airspace at a time.

When was the last time you updated your ETA enroute with ATC in real life? I have never done it personally.

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Mazer1415@reddit

Lots of good stuff in this discussion. I’d just ask for clarification, is 7600 an emergency? If you’re upgrading your situation to an emergency then it’s 7700 regardless if your nordo. Plus, have you switched to 121.5 and attempted contact with ANY other sector?

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Daa_pilot_diver@reddit

It’s a slippery slope to say here is the legal answer, but here is what I’d actually do… It’s borderline a hazardous attitude of anti authority. I do however understand the implications of the post( I just wanted to add another layer.

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madness2live@reddit (OP)

Hey! I think maybe part of your comment didn't post... what would you do? What part is anti-authority?

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Daa_pilot_diver@reddit

It posted mostly fine, minus a closing parenthesis. The antiauthority part is that you are acknowledging the law is “this” but will deliberately ignore it/do something else. However, I understand the responsibility of the pilot, being the final authority as to the safe operation of the flight, and the ability to deviate from any law to the extent required by the emergency, etc.

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madness2live@reddit (OP)

Ahh gotcha. So its like a grey area - but no one is going to come knocking as long as everyone ends up safe.

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Daa_pilot_diver@reddit

Exactly

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Mega-Eclipse@reddit

CFII is telling me regardless of your clearance limit - don't bother holding and waiting until your EFC/ETA. Just fly to your limit, and then proceed direct to an IAF and shoot the approach under emergency PIC privileges. ATC can vector everyone else around you.

IF...That is the safest thing to do. That's the caveat. You don't just do whatever. You do the smartest, safest, most predictable thing.

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mtconnol@reddit

I teach this in three parts.

Book answer

Followed by, I would exert 91.3 and get in the ground in a smooth predictable way.

…unless ATC is busted or we are in a non radar environment. In which case it needs to be by the book.

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flyingron@reddit

Unless you're in a strange holding circumstance the clearance limit is the airport. I can't think of an approach where the IAF is the airport.

Frankly, I'd just do what you were expecting to do: fly the filed course to an IAF at the airport and land. Your landing will be when you "arrive at the clearance limit." Problem solved ;)

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Gabriel_Owners@reddit

You can lie about not using AI, but this post is very obviously AI.

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madness2live@reddit (OP)

Lol what?

If you use AI to write a question, thats pretty sad imo. Why would one use AI to format how to ask a question? Have we all lost our critical thinking skills and everyone just uses AI now?

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Gabriel_Owners@reddit

You tell me, you're the one using AI to make a reddit post.

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madness2live@reddit (OP)

Alright man, whatever you say - this is a pointless argument. Wishing you blue skies and tailwinds, God bless.

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rFlyingTower@reddit

This is a copy of the original post body for posterity:

Hey flying family – got another question for you... TLDR at the bottom

Prepping for CFII – and I thought I knew lost comm procedures like the back of my hand, but after some extensive digging, I’m not sure anymore… I want to ask – is the way my CFII is telling me to teach lost comms (specifically in regards to leaving a clearance limit) correct?

He is explaining it as a "textbook answer" and a "real life" answer, citing that the textbook regs are old and outdated.

Textbook answer:

According to 91.185, there are 2 different types of clearance limits:

A fix where an approach begins (an IAF)
A fix where an approach does NOT begin (i.e direct to an airport)

For #1 in lost comms, once we reach the IAF - we'll hold at the IAF until EFC/ETA and then shoot the approach.

For #2, we'll fly to our clearance limit (the airport), and hold over the airport until our EFC/ETA, and then proceed to an IAF and shoot the approach.

Real life answer:

ATC doesn't want you in IMC with lost comms anymore than you do. In addition, AIM 6-4-1 basically tells us "the FAA cannot determine procedures for every situation so as the pilot, be predictable given the situation and use emergency PIC authority as needed."

He is saying for #2 (and I guess technically #1, but he did not explicitly say "do this also for #1") that AIM 6-4-1 allows us to ditch the idea of holding entirely, and just flying past the clearance limit and then direct to shooting the approach. By squawking 7600 in IMC, we are now an emergency aircraft and can deviate from any rules.

He mentions both the textbook and real life answer are "correct". The main idea is you need to be PREDICTABLE:

If you hold over the airport: ATC can determine you're waiting and will soon shoot the approach
If you just ditch the hold, fly to your clearance limit, and then go straight for the IAF: ATC can determine "ok this guy doesn’t care – he’s shooting the approach and we’ll be done with him in a few mins”

He said even if you have arrive at the airport and have an EFC of 20+mins - you holding over the airport and waiting for your EFC is just a waste of time. ATC will not allow another plane to takeoff or shoot an approach while you're up there....so do everyone and favor and just get down.

With that being said... again - he said BOTH options are correct.

If you want to hold until EFC - go for it. (Textbook)
If you say screw it and just shoot the approach - also acceptable. (Real life)

Thoughts? You think a examiner will be ok with me teaching both methods or should I just stick to textbook and not open a can of worms?

-------------------------------------------------------------------------------------------------

TLDR:

CFII is telling me regardless of your clearance limit - don't bother holding and waiting until your EFC/ETA. Just fly to your limit, and then proceed direct to an IAF and shoot the approach under emergency PIC privileges. ATC can vector everyone else around you.

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