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4 Answers

Lost Comms IFR

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FAA Regulations

Scenario: You're in a C172 in complete IMC. You arrive at the destination 30 minutes early from your ETA and have no radios. Do you just descent and shoot an approach right away, or do you hold somewhere at altitude and wait? Clearance is this: C: KFLG R: PXR, V327, FLG A: 12,000 F: 123.7 T: 4241 I've heard various answers to this question (Maybe 91.185 is too vague?). Things such as; 1) hold at an IAF until the ETA, then shoot an approach. 2) hold at a charted hold from an approach plate (such as a missed approach hold) until the ETA, then shoot an approach. 3)  Just proceed immediately to an IAF, descend, and shoot the approach 30 min early.. So what do you think would be the legal answer? 91.185 seems clear, but I've heard multiple CFI-I's and DPE's give different answers...

4 Answers



  1. John D Collins on May 17, 2015

    What the regulation says is that your clearance limit is either an IAF or not an IAF, usually the destination airport. In your case, the clearance limit is KFLG, the airport. The regulation requires you to fly to your clearance limit KFLG and then to an IAF since the airport is not an IAF. If you are 30 minutes early, you should hold at the IAF at 12,000 feet and leave the hold to commence the approach at your expected arrival time. Since FLG and KFLG are essentially the identical location, the regulation would call for remaining at 12000 and proceeding to the IAF for your chosen approach. FLG is an IAF for the VOR-A, and you could hold there for that approach, For the ILS, FLG is on the airway and there is a feeder route to SHUTR which is an IAF for the ILS where you could also hold at 12000. At the ETA you would commence the chosen approach. That would comply with the regulation.

    If you ask a controller, they will tell you contrary to the regulation, they want the situation over as soon as possible and would prefer you commence the approach right away. Otherwise they have to block all departures and arrivals until you are on the ground, because they don’t know what you are actually going to do. If it were me, I would fly the approach without holding because I know they have radar and will be following me until I land. In the mean time, they won’t be permitting other aircraft to be making approaches. It would be a stressful enough of a situation and possibly an emergency anyway.

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  2. Kris Kortokrax on May 18, 2015

    Jon,

    Since you asked for the “legal” answer, take a look at the Olschock interpretation.

    http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/olshock%20-%20(2010)%20legal%20interpretation.pdf

    He asks essentially the same question as yours (there aren’t that many questions that haven’t been asked before). The FAA lawyers stated that you may not commence descent early merely because you arrived early. That’s the legal answer. Will the FAA pursue a violation? That’s a different question.

    Arriving 30 minutes early on a 52 minute, 104NM trip in a Cessna 172 would require at least a 166 K unplanned tailwind. Somebody’s preflight planning was a little off.

    There is another option that has not been considered. You did not indicate that we lost Nav capability also (if we did, we are in deeper doo-doo). We should still be monitoring the progress of the flight and become aware of our projected early arrival. The solution is obvious. Slow down. It saves fuel and gives you time to plan what you will do when you get there. If you have an iPad or other GPS capability, the job becomes easier.

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  3. jon sanderson on May 22, 2015

    Thanks John and Kris.

    Both of your responses seem to be in agreement. John, thanks for clarifying from the controller’s perspective as well. I have always considered a true lost comms scenario such as this to be a stressful enough situation that could easily go from 7600 to 7700, as such I would personally just descend and shoot the approach on arrival. I really can’t imagine a controller wanting to make an issue out of that.

    Kris, big thanks for the reference to the Olshock document. I’ll be spreading it around to my colleagues..

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  4. Dan S. on May 27, 2015

    John,
    Where does it talk about proceeding to the IAF and holding there, rather than holding at the clearance limit if it is an airport?

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