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2 Answers

Lost Comms IFR clearance limit

Asked by: 11490 views Instrument Rating

your clearance limit is your destination airport and you loose Comms after takeoff. You get to your clearance limit (airport) before your ETA what should you do. From what I understand you should hold until your ETA then proceed to IAF. So my question is where do you hold?

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2 Answers



  1. John D Collins on Aug 21, 2016

    91.185 says in part:

    (3) Leave clearance limit.
    (i) When the clearance limit is a fix from which an approach begins, commence descent or descent and approach as close as possible to the expect-further-clearance time if one has been received, or if one has not been received, as close as possible to the estimated time of arrival as calculated from the filed or amended (with ATC) estimated time en route.
    (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.

    Using the language of the regulation with some comments:

    Unless you have received an expect-further-clearance time, you would arrive at your clearance limit (the airport, which is not a fix from which an approach begins) and proceed to a fix from which the approach begins (an IAF on an approach at the airport). At the IAF you would commence the 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. If you needed to hold to delay commencing the approach to be as close as possible to the estimated time of arrival, you would hold at the IAF and at your last assigned altitude. You would commence the descent after holding sufficient time to align your approach with the eta.

    That is what the regulation calls for. I would not hold unless it was necessary for descending to an altitude called for in the approach. ATC is going to be holding the airspace open for you until you are on the ground and the sooner you get on the ground, the sooner the system can get back to normal. If the airport has radar coverage, ATC will be able to see you and if not ATC will not be allowing IFR operations at the airport, until the loss of communications is resolved.

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  2. Mark Kolber on Aug 22, 2016

    Notice the logical inconsistency inherent in the destination airport being the clearance limit. Exactly how does one fly to the airport without flying an approach? And once there, why would one leave? Yet a strict reading of the FAR might suggest going to the airport, landing, taking off again, and going to a position from which you can fly an approach all over again.

    That’s not to point out any silliness in the rule. It is to suggest that the rule, created in an earlier time, without widespread radar monitoring and when clearance limits short of the destination airport were more common since separation was based largely on pilot position reports, does not cover all situations. If you read the discussion of the rule in AIM 6-4-1, three things become very clear.

    One is that the rule does not cover every situation.

    Two, the rule’s description of how to get to the destination airport contemplates a clearance limit other than the destination airport.

    Finally and most importantly, there is an essential element of reasonable pilot discretion based on the precise situation (John’s final paragraph above). As the AIM puts it in the very first sentence of its discussion of comm failure:

    During two-way radio communications failure, when confronted by a situation not covered in the regulation, pilots are expected to exercise good judgment in whatever action they elect to take.

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