CFII Lost Comms Examples

CaptLabrador

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Concerning Lost Comms IFR procedures. I would like to have some good examples for discussing and explaining the various sub sections of 91.185.

Any CFII's want to provide examples that you use and the conclusions you expect to come to?

Much appreciated.
 
That will take about half an hour to type up, and I'm not doing that on my iPad. I'll get back to you on this tonight from home.
 
I had this going ORD AUS last month. About half way we lost all radios but as they were "dying" we able to relay to another aircraft that we were going to fly ILS 17R and land KAUS. We descended, shot the approach straight in (VMC), got the green light gun and landed. About the time we got on the ground the radios came back some, turns out condensation build up got into an IAPS Integrated Avionics Processing System.



Remember you have emergency authority in that situation (but be safe and practical) ..case closed...
 
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This is something my studies have, so far, been lacking on. I'm going to review 91.185 soon but am very curious to hear peoples real world experiences and thoughts on lost comm situations in IFR.

Also, any good references or mnemonics that people might have?
 
I have a tutorial on this very subject here. The drawing at the end is a good place to play "what if" scenarios.

Pilots get confused because older ones remember the procedures the FAA explained in the IFR Exam-O-Grams until the early 1980s. But then, the ATO (ATC part of FAA) changed the rule with an amendment and pilots, including many FAA examiners, didn't keep up. Newer pilots get tripped up on the term "Clearance limit". So I wrote ATO and asked them what exactly they meant by the changes in that amendment. They ignored me until I raised enough of a ruckus with follow-up emails and phone calls. Then they turned it over to the Chief Counsel's office where my query was tossed on the desk of a new-hire lawyer who had no pilot experience at all. Her first answer didn't even address my questions. Of course, they published her answer on their website under my name, but they didn't show the questions I asked, only their version. So, I wrote back and this time they did better, but not great. It was enough though to show that "Clearance limit" in the revised rule is the very same place "Holding fix" was in the older rule. With that established, you can apply the changes to the older rule, deleting the parts they intended, and make perfect sense of it all. I've documented the whole bloody affair in this slide show, complete with copies of the Exam-O-Grams and the "Lost Comm Amendment": http://www.avclicks.com/lost_comm/Lost_comm2/index.html. That should end any controversy over the matter in the future.

dtuuri
 
I have a tutorial on this very subject here. The drawing at the end is a good place to play "what if" scenarios.

Pilots get confused because older ones remember the procedures the FAA explained in the IFR Exam-O-Grams until the early 1980s. But then, the ATO (ATC part of FAA) changed the rule with an amendment and pilots, including many FAA examiners, didn't keep up. Newer pilots get tripped up on the term "Clearance limit". So I wrote ATO and asked them what exactly they meant by the changes in that amendment. They ignored me until I raised enough of a ruckus with follow-up emails and phone calls. Then they turned it over to the Chief Counsel's office where my query was tossed on the desk of a new-hire lawyer who had no pilot experience at all. Her first answer didn't even address my questions. Of course, they published her answer on their website under my name, but they didn't show the questions I asked, only their version. So, I wrote back and this time they did better, but not great. It was enough though to show that "Clearance limit" in the revised rule is the very same place "Holding fix" was in the older rule. With that established, you can apply the changes to the older rule, deleting the parts they intended, and make perfect sense of it all. I've documented the whole bloody affair in this slide show, complete with copies of the Exam-O-Grams and the "Lost Comm Amendment": http://www.avclicks.com/lost_comm/Lost_comm2/index.html. That should end any controversy over the matter in the future.

dtuuri

Huzzah! :rockon:
 
Newer pilots get tripped up on the term "Clearance limit".

I have to admit, this is probably me. I was always under the impression that the "clearance limit" was always a fix. Part of that was that I did most of my training with GPS, and so my belief was that for a radio failure in IMC, if VMC weren't encountered, I would be expected to hold at the appropriate altitude directly over the airport (ie the clearance limit GPS fix) until the ETA, and then begin an approach.

Then again, that line of thinking falls apart when you have a non-GNSS aircraft with the destination airport as the clearance limit, as in the general case they couldn't hold over it. On that point, I've heard people say you should file to an IAF rather than an airport in that case, but I've not heard of anyone actually doing it.
 
I'll give you an example used by an examiner I know. It covers pretty much all the bases.

You're filed IFR from Wilmington DE to Atlantic City NJ. Your filed route is OOD V184 ACY KACY at 3000. Your clearance is "radar vectors OOD, then as filed, maintain 2000, expect 3000 ten minutes after departure," and you are taking off on Runway 27. Tower tells you "turn left 180, cleared for takeoff." At 400 above the departure end of the runway, you start the turn to 180 and Tower tells you to contact Philadelphia Approach. You switch, call, and hear nothing. What do you do?

First thing you do is confirm that you really are lost comm. That means:

· making a second call in case the controller was on the land line.
· checking the freq you've dialed in.
· checking your audio panel volume knob, headset plugs, etc
· listening to see if you hear anyone else
· try the #2 comm
· switch back to Tower and see if maybe the lights just went out at the Philly TRACON
· try 121.5
· listen to the ILG and/or OOD VOR audio signals (yes, they can talk over the VOR's)
· try your cell phone
· anything else you can think of to restore communication with the ground.
Only when all of those possibilities are exhausted do you consider yourself "lost comm" and start squawking 7600.

Next step is to look out the window. Per 91.185(b), if you are in visual conditions and can land visually, you are required to do so as soon as you can do that safely. So if you can see the Wilmington airport, you turn back to it, enter the downwind for 27, and watch the tower for lights.

Only now, if you have exhausted the possibilities for restoring comm and are not in visual conditions do you start into 91.185(c). At this point, you're probably level at 2000 heading 180 on a radar vector. Per paragraph (c)(1)(ii), you go "by the direct route from the point of radio failure to the fix, route, or airway specified in the vector clearance," i.e., turn direct OOD VOR. After that, you'll continue on your cleared route all the way to ACY.

What about altitude? Paragraph (c)(2) says you flight at the highest of the
· MEA
· Expected
· Assigned
Note that this trio makes the acronym MEA -- easy to remember?

At this point, perhaps three minutes after takeoff, the MEA comes off the L-chart, the expected is still 2000 since ten minutes have not yet elapsed, and the assigned is 2000 from your clearance, so you fly at 2000 for now. This will remain the same until you get to another MEA (say, at OOD) or ten minutes runs out. Let's say you reach OOD (14 nm from KILG) at 9 minutes. Now, the MEA drops to 1900, but your last assigned and the expected at this time remain 2000, so you stay at 2000. But one minute later, you'll hit the 10 minute mark, sending your expected up to 3000, and you'll climb to 3000 at that time, and stay there unless an MEA comes up that is higher (which on this route it doesn't).

However, let's say you've made contact with Philly, they've turned you direct OOD, assigned 3000, and amended your route "after OOD, cleared V166 LEEAH V229 ACY direct KACY". You lose comm immediately thereafter. The route part is easy, but altitude's a bit trickier. When you hit OOD and turn southeast on V166, the MEA drops to 1900. Your last assigned is now 3000 and you have no further expected altitude, so the highest of the three remains 3000 -- until you reach BRIEF intersection about halfway from OOD to LEEAH, where the MEA jumps to 7000. At that point, the highest of the three becomes 7000. Since there's no X-flag MCA there, you don't start the climb until you cross BRIEF, but when you do, you must maintain the standard minimum climb gradient of 200 feet per nautical mile, which you translate to a minimum climb rate in feet per minute using the table in the back of the Terminal Procedures book (or the Digital Terminal Procedures Supplement in your iPad/ForeFlight). That's where you stay until you reach LEEAH and turn northeast, and the MEA drops back down to 2000. Now the highest of the three is back down to 3000 (your last assigned), so after crossing LEEAH, you start a descent to 3000, which you will maintain all the way to ACY.

In the various situations above, you end up reaching the ACY VOR at 3000 feet. Now what?

Based on your preflight weather briefing and the equipment in your aircraft, you should already have decided which approach you are going to fly. If ACY VOR were an IAF, you could start an approach from there, and if that's the approach you wanted to fly, you'd comply with paragraph (c)(3)(i) by holding there until your filed ETE runs out, or commencing at once if your ETE has already elapsed. With no published hold there, you'd do what the AIM says about arriving at a fix at which you must hold with no holding instructions and no published hold -- make a standard right holding pattern on your arrival course (V184 or V229, depending on which scenario we use) at 3000 feet.

Since none of the approaches to KACY begin at ACY VOR (i.e., it's not an IAF), you are definitely going somewhere else immediately IAW paragraph (c)(3)(ii), and do so at 3000 feet. Let's say you've chosen the ILS 31 approach. There's a feeder route to the STEVV IAF from ACY VOR (3000/127 CRS/11.8nm), and a published hold there, so you'd turn outbound to that 127 course to STEVV and check your clock again. If your ETE has elapsed, you complete the reversal descending to 2000 and continue inbound on the ILS after crossing STEVV the second time. If not, you'd hold at STEVV as published until the time ran out, then leave 3000 and fly the approach.

You may hear some discussion about what to do if the last point in your flight plan route block is not the airport or a navaid on the airport. In the above case, it's pretty easy, since the ACY VOR is on the airport, so there's no question about whether to proceed to the airport from here or to consider ACY VOR your clearance limit and continue with paragraph (c)(3). However, let's say you'd filed to Republic Airport, Farmingdale NY (KFRG) which has no navaid on the field and has no approach beginning from overhead the field. Most folks would file with either JFK VOR or DPK VOR (depending on arrival direction) as the last point in the route of flight block. If you filed through JFK, what do you do when you reach the JFK VOR, especially if you don't have a GPS so you can't fly direct to KFRG from there? This question has been answered by the FAA's Flight Procedures Branch in the attached response.

The short answer is you should have filed from JFK VOR to either the FR OM or BBN NDB to which you could navigate as the last point in your route of flight, but if you didn’t, that’s where you’ll go from JFK VOR immediately upon reaching JFK VOR anyway, since those are fixes from which an approach begins, JFK VOR is not, and you can’t navigate direct KFRG (even if you flew a radial off JFK VOR, you wouldn’t know when you reached the airport). Once reaching FR or BBN, you would do just as you did on reaching STEVV in the KACY example. What the FAA does not want is for you to continue from JFK direct to KFRG and then out to some other fix to start the approach [and this should answer McManigle's question immediately above].

Obviously, with an IFR approach GPS, you could also proceed direct from JFK VOR to the IAF for an RNAV(GPS) approach.

Questions?

BTW, despite the marking on the attached file, I have the FAA's permission to distribute it.
 

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See my comments inline:
I'll give you an example used by an examiner I know. It covers pretty much all the bases.

You're filed IFR from Wilmington DE to Atlantic City NJ. Your filed route is OOD V184 ACY KACY at 3000. Your clearance is "radar vectors OOD, then as filed, maintain 2000, expect 3000 ten minutes after departure," and you are taking off on Runway 27. Tower tells you "turn left 180, cleared for takeoff." At 400 above the departure end of the runway, you start the turn to 180 and Tower tells you to contact Philadelphia Approach. You switch, call, and hear nothing. What do you do?

First thing you do is confirm that you really are lost comm. That means:

· making a second call in case the controller was on the land line.
· checking the freq you've dialed in.
· checking your audio panel volume knob, headset plugs, etc
· listening to see if you hear anyone else
· try the #2 comm
· switch back to Tower and see if maybe the lights just went out at the Philly TRACON
· try 121.5
· listen to the ILG and/or OOD VOR audio signals (yes, they can talk over the VOR's)
· try your cell phone
· anything else you can think of to restore communication with the ground.
Only when all of those possibilities are exhausted do you consider yourself "lost comm" and start squawking 7600.

Next step is to look out the window. Per 91.185(b), if you are in visual conditions and can land visually, you are required to do so as soon as you can do that safely. So if you can see the Wilmington airport, you turn back to it, enter the downwind for 27, and watch the tower for lights.

Only now, if you have exhausted the possibilities for restoring comm and are not in visual conditions do you start into 91.185(c). At this point, you're probably level at 2000 heading 180 on a radar vector. Per paragraph (c)(1)(ii), you go "by the direct route from the point of radio failure to the fix, route, or airway specified in the vector clearance," i.e., turn direct OOD VOR. After that, you'll continue on your cleared route all the way to ACY.

What about altitude? Paragraph (c)(2) says you flight at the highest of the
· MEA
· Expected
· Assigned
Note that this trio makes the acronym MEA -- easy to remember?

At this point, perhaps three minutes after takeoff, the MEA comes off the L-chart, the expected is still 2000 since ten minutes have not yet elapsed, and the assigned is 2000 from your clearance, so you fly at 2000 for now. This will remain the same until you get to another MEA (say, at OOD) or ten minutes runs out. Let's say you reach OOD (14 nm from KILG) at 9 minutes. Now, the MEA drops to 1900, but your last assigned and the expected at this time remain 2000, so you stay at 2000. But one minute later, you'll hit the 10 minute mark, sending your expected up to 3000, and you'll climb to 3000 at that time, and stay there unless an MEA comes up that is higher (which on this route it doesn't).

However, let's say you've made contact with Philly, they've turned you direct OOD, assigned 3000, and amended your route "after OOD, cleared V166 LEEAH V229 ACY direct KACY". You lose comm immediately thereafter. The route part is easy, but altitude's a bit trickier. When you hit OOD and turn southeast on V166, the MEA drops to 1900. Your last assigned is now 3000 and you have no further expected altitude, so the highest of the three remains 3000 -- until you reach BRIEF intersection about halfway from OOD to LEEAH, where the MEA jumps to 7000. At that point, the highest of the three becomes 7000. Since there's no X-flag MCA there, you don't start the climb until you cross BRIEF, but when you do, you must maintain the standard minimum climb gradient of 200 feet per nautical mile, which you translate to a minimum climb rate in feet per minute using the table in the back of the Terminal Procedures book (or the Digital Terminal Procedures Supplement in your iPad/ForeFlight).

Good so far except once in the en route structure climb performance needs only be 150'/nm to 5000', then 120'/nm to 10,000'. See slide #6 in my tutorial Hope and Change.

That's where you stay until you reach LEEAH and turn northeast, and the MEA drops back down to 2000. Now the highest of the three is back down to 3000 (your last assigned), so after crossing LEEAH, you start a descent to 3000, which you will maintain all the way to ACY.
In the various situations above, you end up reaching the ACY VOR at 3000 feet. Now what?

Based on your preflight weather briefing and the equipment in your aircraft, you should already have decided which approach you are going to fly. If ACY VOR were an IAF, you could start an approach from there, and if that's the approach you wanted to fly, you'd comply with paragraph (c)(3)(i) by holding there until your filed ETE runs out, or commencing at once if your ETE has already elapsed.

There's been no delay required since the mid-1980s when ATO changed the rule, although the place of descent is still the same: the IAF. Now you only need to delay descent if you've been given holding instructions first. The old paragraph describing descent time was deleted completely. See: Lost Communications According to FAA's Chief Counsel.

With no published hold there, you'd do what the AIM says about arriving at a fix at which you must hold with no holding instructions and no published hold -- make a standard right holding pattern on your arrival course (V184 or V229, depending on which scenario we use) at 3000 feet.
Since none of the approaches to KACY begin at ACY VOR (i.e., it's not an IAF), you are definitely going somewhere else immediately IAW paragraph (c)(3)(ii),

That paragraph doesn't apply unless you are held short of your destination. See the second Chief Counsel interpretation in the bibliography at the end of the above link.

and do so at 3000 feet. Let's say you've chosen the ILS 31 approach. There's a feeder route to the STEVV IAF from ACY VOR (3000/127 CRS/11.8nm), and a published hold there, so you'd turn outbound to that 127 course to STEVV and check your clock again. If your ETE has elapsed, you complete the reversal descending to 2000 and continue inbound on the ILS after crossing STEVV the second time. If not, you'd hold at STEVV as published until the time ran out, then leave 3000 and fly the approach.
Again, only if given holding instructions. No delay otherwise.

You may hear some discussion about what to do if the last point in your flight plan route block is not the airport or a navaid on the airport. In the above case, it's pretty easy, since the ACY VOR is on the airport, so there's no question about whether to proceed to the airport from here or to consider ACY VOR your clearance limit and continue with paragraph (c)(3).

According to the Chief Counsel, the clearance limit is the destination airport and means exactly the same place as it did prior to the terminology change in the lost comm amendment, ie, a holding fix short of the destination. There was no intention to require entering a hold at a place not approved for holding, ie, over the destination airport or at an impromptu spot known only by the pilot.
However, let's say you'd filed to Republic Airport, Farmingdale NY (KFRG) which has no navaid on the field and has no approach beginning from overhead the field. Most folks would file with either JFK VOR or DPK VOR (depending on arrival direction) as the last point in the route of flight block. If you filed through JFK, what do you do when you reach the JFK VOR, especially if you don't have a GPS so you can't fly direct to KFRG from there? This question has been answered by the FAA's Flight Procedures Branch in the attached response.
The short answer is you should have filed from JFK VOR to either the FR OM or BBN NDB to which you could navigate as the last point in your route of flight, but if you didn’t, that’s where you’ll go from JFK VOR immediately upon reaching JFK VOR anyway, since those are fixes from which an approach begins, JFK VOR is not, and you can’t navigate direct KFRG (even if you flew a radial off JFK VOR, you wouldn’t know when you reached the airport). Once reaching FR or BBN, you would do just as you did on reaching STEVV in the KACY example. What the FAA does not want is for you to continue from JFK direct to KFRG and then out to some other fix to start the approach [and this should answer McManigle's question immediately above].

Obviously, with an IFR approach GPS, you could also proceed direct from JFK VOR to the IAF for an RNAV(GPS) approach.

Questions?

BTW, despite the marking on the attached file, I have the FAA's permission to distribute it.

The date of your attached file is superceded by the Chief Counsel's interpretation I cited earlier. Thankfully, I might add.

dtuuri
 
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See my comments inline:
Thank you for the corrections, especially the Chief Counsel letters regarding when to commence the approach and the IPH regarding climb gradients. However, per the guidance from Flight Standards, I'll stick to what they recommend as far as how to file and where to go after reaching the last point on your route of flight -- and that's not direct to the airport unless that's where the approach begins, and the Chief Counsel's letter supports that.
A pilot plans and files his/her route of flight based on the navigation equipment onboard the aircraft and used during the flight. If an aircraft is not equipped for GPS navigation, the pilot should plan the flight using ground-based navaids.
If you can't fly direct to the airport using ground-based navaids, you must file something you can fly in your route of flight (i.e., not direct from the last route fix to the airport unless there's a navaid you can use on the airport), and you'll use the published approach (not direct) to get from that IAF or feeder fix) to the airport.
 
Here's a practical example where I could use some help as to what you would ACTUALLY do, not what the regs would say...

You're flying KSMO to KCRQ. Being familiar with TEC routes, you dutifully file the published TEC route for pistons, which is SMO SMO125R V64 V363 DANAH V23 OCN. Your planned enroute time is 49 mins.

Shortly after takeoff, miracle of miracles, you get "direct SLI direct OCN" knocking 10 full minutes off the enroute time.

At some point enroute, you lose comms. Since you didn't submit an update ETA to ATC while enroute, your filed ETE is still in play. And let's assume it's 400 overcast, btw, so no landing VFR enroute.

Clearly, the regs say that you hold for the extra 10 mins. PRACTICALLY speaking, I haven't been able to find a single controller who expects a pilot to hold in a radar environment after losing comms. Every controller I've asked about this says they'll clear a path and they want me on the ground as soon as possible.

So, if this happens to me, I plan on ignoring the ETE and minimizing how long I remain lost comms in the system, with a fairly high degree of confidence that the controllers are watching and just itching for me to get out of their hair, and that they've cleared the way.

All that can happen by holding is that more people get delayed, since the path will already be cleared. If you arrive early and hold, don't think that they're sending planes in ahead of you or below you thinking, "well, he's here 10 minutes earlier than his ETE would call for, so he's going to hold, so I can put planes ahead of him in the sequence for the next 8 to 9 minutes." NEVER going to happen.

Practically speaking, what is the argument (safety wise) for holding rather than just getting down and out of the system, OTHER than "it's what the regs say to do" ?
 
Here's a practical example where I could use some help as to what you would ACTUALLY do, not what the regs would say...

You're flying KSMO to KCRQ. Being familiar TEC routes, you file the published TEC route for pistons, which is SMO SMO125R V64 V363 DANAH V23 OCN. Your planned enroute time is 49 mins.

Shortly after takeoff, miracle of miracles, you get "direct SLI direct OCN" knocking 10 full minutes off the enroute time.

At some point enroute, you lose comms. Since you didn't submit an update ETA to ATC while enroute, your filed ETE is still in play. And let's assume it's 400 overcast, btw, so no landing VFR enroute.

Clearly, the regs say that you hold for the extra 10 mins.
Per the legal interpretation buried in dtuuri's presentation linked above, and contrary to what I posted, you do not hold for the extra 10 minutes, but rather commence your approach upon arrival at the IAF. To make it easier to read, here is a direct link to that interpretation letter.
 
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You also have a the far less common scenario of losing comms during a radar approach or being vectored for one. If weather (IMC final) dictates you'll get quite a lengthy set of instructions to copy on arrival. Example:

"If no transmissions are received for 1 minute in the pattern or 5 (PAR) / 15 (ASR) seconds on final approach, attempt contact on XYZ tower and proceed VFR. If unable, maintain (altitude), proceed direct to (radial DME /fix) and execute the (type IAP/ runway)...acknowledge."

If no lost commo instructions issued then climb to either ATC assigned altitude or the MSA, which ever is higher and execute the IAP for the landing runway.
 

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I would also like to say that it has been a very, very long time since I've heard of a real "lost comm" situation where the pilot is truly unable to communicate with anyone on the ground, so this is largely an academic discussion popular with DPE's and aviation web boards, but of little practical value. Nearly every supposed "lost comm" situation I've heard of in the last 30 years or so has been something the pilot could have rectified in the cockpit. The few remaining were things like the night the lights went out at Oakland Center, in which case the regulations designed for a single lost comm aircraft went pretty much out the window. In that particular case, Oakland's frequencies pretty much became CTAF's where the aircraft all worked it out among themselves until the underlying TRACON's came up on Oakland's freqs or the aircraft descended as they normally would into what they knew was TRACON airspace and switched to the TRACON freqs they knew on their own.
 
I think I got my head around it. It's taken a while for me to realize that 91.185(c)(3) doesn't apply if you're clearance limit is an airport. It's a shame that they don't make it more clear that (c)(3) is NOT going to apply in 99% of the cases.

Good, so I can stick with my original plan, then and feel even better that it's not against the regs.
 
...this is largely an academic discussion popular with DPE's and aviation web boards, but of little practical value. .

Ron, I agree that it's almost a completely academic discussion.
I don't think it's "academic" at all. IMO, it's the cornerstone of the entire IFR system: It's the pilot's job to plan a flight that can be accomplished without reliance on ATC. ATC needs to know where the pilot is going to go if they suddenly can't see or hear the pilot anymore. If it weren't for 91.185, what purpose would a flight plan serve? Just call 'em up and tell 'em where you want to go and steer the headings they give you, right? Lost comms is likely no more rare than, say, an in-flight fire or engine failure. We train for those and don't blow it off as "academic". Doing so for radio failure, I think, doesn't serve our students' interests well.

dtuuri
 
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Great read, and (thankfully) I have yet to deal with a real lost communications scenario like described here. On my side of the scope, discussions like these have also been (thankfully) academic in nature. I'm not trying to dispel what dtuuri is saying, because it's important that all parties - pilots and ATC - know what to do. I'm just grateful I haven't seen it, and that no one I know has either.
 
Great read, and (thankfully) I have yet to deal with a real lost communications scenario like described here. On my side of the scope, discussions like these have also been (thankfully) academic in nature. I'm not trying to dispel what dtuuri is saying, because it's important that all parties - pilots and ATC - know what to do. I'm just grateful I haven't seen it, and that no one I know has either.
Talk to the folks at ZOA -- they know all about lost comm, but it was they, not the aircraft, who lost the comms. :wink2:
http://www.avweb.com/news/system/183216-1.html?redirected=1
Although that was 19 years ago, and everyone who was on the scope that night may be retired by now.
 
Yikes. I've talked with the vets at ZAU when I was in training. They told me horror stories of equipment crashes because the weather readout on the radar overloaded the computer. Worst one was during ORD and MDW holding, weather, and a full on radar outage. Kinda crazy. The worst thing I've seen was losing our electronic flight strips, the vets and I actually tried to find a way to keep the system broken (we liked strips), but the younger guys basically went right down the crapper. I kinda felt bad for them.

But I'd rather take all that in a heartbeat over losing all my frequencies. I wouldn't be surprised if a few controllers had to take some trauma leave from the experience.


Sent from my iPad using Tapatalk
 
So I used the example Ron gave me and it was a great discussion. But yes there is what the regs say to do which is how I taught the forum then there is what you really do. Don't hold just get to the approach and shoot it. Again :cheers:
 
I like lost comm scenario discussions. It points out, often, how rote we all learn stuff. You ask what altitude to fly if lost comms and everyone spits back, 'the highest of filed, cleared, expected...blah blah'.

BUT, put them in a situation and the conversation really takes off, often with no right answers.

I'd ask my students, "okay, you're in PBI on 10L. Cleared to take off runway heading to 1,500. You climb into the soup and lose comms...now what?"

A great discussion always ensues as there isn't really a right answer. Turn? Turn when? Climb? You were given an expect alt after 10 min in the clearance. Where ya gonna turn to?

Lots of stuff to think about as you head out to sea at 1,500 feet in the soup with an abnormal...


Another good one is IAD, take off runway 30 and get the turn to 250 with a climb to 3,000'. Now lose comms in the soup. You're heading towards higher terrain and better climb before your 10 min is up...or at least turn. Fun stuff.
 
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I like lost comm scenario discussions. It points out, often, how rote we all learn stuff. You ask what altitude to fly if lost comms and everyone spits back, 'the highest of filed, cleared, expected...blah blah'.

BUT, put them in a situation and the conversation really takes off, often with no right answers.

I'd ask my students, "okay, you're in PBI on 10L. Cleared to take off runway heading to 1,500. You climb into the soup and lose comms...now what?"

A great discussion always ensues as there isn't really a right answer. Turn? Turn when? Climb? You were given an expect alt after 10 min in the clearance. Where ya gonna turn to?

Lots of stuff to think about as you head out to sea at 1,500 feet in the soup with an abnormal...


Another good one is IAD, take off runway 30 and get the turn to 250 with a climb to 3,000'. Now lose comms in the soup. You're heading towards higher terrain and better climb before your 10 min is up...or at least turn. Fun stuff.
Actually, there are "book" answers to all your questions in 91.185(c).
 
Actually, there are "book" answers to all your questions in 91.185(c).

Heh. I was going to post the same comment, but rather than chance an argument I watched the figure skaters on NBC. If a pilot doesn't know what to do at any point in the flight with comm failure--he or she isn't much of a pilot. It's all about a mind-set for planning and executing a flight without reliance on ATC for your well-being. Those folks, and they probably don't want to hear this, are there to prevent pilots from doing what they want. Sorry, ATC guys and gals, I love what you do for me all the same. It's true though. I even devoted a whole tutorial to that idea here: http://www.avclicks.com/Flash2/ATC_Stands_for/index.html .

dtuuri
 
By stating there are "book" answers to every lost comms situation you are denying the discussion. Further you are way over stating the scope of the FARs.

Ill give you a quick example. FARs state if being radar vectored you are to turn at the point of lost comms. However, where is that? I guarantee a discussion could be held over JUST THAT. Is it the first time you call with no response? Second? Third? Wait for them to call you? Maybe you can receive but not transmit. Is that lost comms?

Anyway, discussion is good. Closing discussion with a curse statement of "it's all covered in the FARs' is not good or true. If the top five best pilots in the world all departed the same airport and had lost comms (failure) at the same point I guarantee all five would have different ground tracks and altitude profiles. Does that sound bookish or open to interpretation...or at least worthy of discussion?
 
By stating there are "book" answers to every lost comms situation you are denying the discussion. Further you are way over stating the scope of the FARs.

Ill give you a quick example. FARs state if being radar vectored you are to turn at the point of lost comms. However, where is that? I guarantee a discussion could be held over JUST THAT. Is it the first time you call with no response? Second? Third? Wait for them to call you? Maybe you can receive but not transmit. Is that lost comms?

Anyway, discussion is good. Closing discussion with a curse statement of "it's all covered in the FARs' is not good or true. If the top five best pilots in the world all departed the same airport and had lost comms (failure) at the same point I guarantee all five would have different ground tracks and altitude profiles. Does that sound bookish or open to interpretation...or at least worthy of discussion?
I/we tried to straighten you out last July: http://www.pilotsofamerica.com/forum/showthread.php?t=61015&highlight=lost

Why you think this rule is any different than any other that requires the pilot to use good judgment, like estimating cloud clearance or when to invoke emergency authority, etc., I don't know. The rule is clear enough and whether you complied with it or not will be determined by what a reasonable and prudent pilot would have done under similar circumstances. "Reasonable and prudent" also being in accordance with the rule and not a common misinterpretation of the rule. Regulations weren't written with moving map precision y'know.

dtuuri
 
By stating there are "book" answers to every lost comms situation you are denying the discussion. Further you are way over stating the scope of the FARs.
I didn't say that. What I said was there are book answers to the questions you posed in your post.

Ill give you a quick example. FARs state if being radar vectored you are to turn at the point of lost comms. However, where is that?
It's where you determine that you have lost comm as opposed to just screwing up your switchology or the like.

I guarantee a discussion could be held over JUST THAT.
I have no doubt you are correct that such a discussion could be held, but it wouldn't take me long to explain the book answers to the discussers.

Is it the first time you call with no response? Second? Third? Wait for them to call you? Maybe you can receive but not transmit. Is that lost comms?
It's lost comm when you determine that you have lost 2-way communications with ATC and cannot regain them by actions in the cockpit. That's pretty straightforward.

Anyway, discussion is good. Closing discussion with a curse statement of "it's all covered in the FARs' is not good or true. If the top five best pilots in the world all departed the same airport and had lost comms (failure) at the same point I guarantee all five would have different ground tracks and altitude profiles. Does that sound bookish or open to interpretation...or at least worthy of discussion?
If that were true, then either at least four of them don't know 91.185 as well as they should, or some/all of them have chosen to do something other than what it says in 91.185. In every case short of going missed at the destination, there is a "book" answer to cover -- whether you choose to deviate from the book for valid safety reasons is another discussion entirely.
 
Well, there's legal and there's safe. We all want to be both legal and safe. We all want to avoid illegal and not safe. That leaves illegal / safe and legal / not safe as possible areas.

For the visual natured imagine a graph with legal/illegal on the left and safe/not safe on the bottom. Upper right is legal and safe and bottom left is illegal and not safe.

So your lost comms happen on a vector just after climbing into a layer at 3,000 AGL. Safe illegal may be to descend back into VMC and land.

Book doesn't cover that one and that makes for a discussion. The OP asked for topics of discussion. My position is lost comms is an excellent topic for just that. Chest thumping aside and telling people 'it's in the book' does a dis-service, IMO. I think the possibilities are so endless that a simple reg in 'the book' can't possibly address every situation and pilots are going to have to use their judgement when the radios stop working.
 
BTW, technically, the reg doesn't say, "when the pilot discovers". It says at the point of lost comms. If the radio breaks 5 miles from the field and the pilot doesn't notice till 12 miles it could be argued you're in violation already.

I wouldn't argue that, but I know many here read FARs quite literally and endless arguments go for pages over less.
 
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Well, there's legal and there's safe. We all want to be both legal and safe. We all want to avoid illegal and not safe. That leaves illegal / safe and legal / not safe as possible areas.

For the visual natured imagine a graph with legal/illegal on the left and safe/not safe on the bottom. Upper right is legal and safe and bottom left is illegal and not safe.

So your lost comms happen on a vector just after climbing into a layer at 3,000 AGL. Safe illegal may be to descend back into VMC and land.

Book doesn't cover that one and that makes for a discussion.
I agree that it makes for a discussion on the philosophy of safe flying, but not on whether or not 91.185 covers your described situation, which contrary to your highlighted statement, it does (you are not in a position to descend and land under VFR, so paragraph (b) does not apply and (c) does).

The OP asked for topics of discussion. My position is lost comms is an excellent topic for just that. Chest thumping aside and telling people 'it's in the book' does a dis-service,
Nevertheless, it is incorrect to say that any situation short of executing a missed at your destination is not covered in that regulation. That's the point I am trying to make, despite your repeated insistence to the contrary.

That said, I agree that doing exactly what it says to do in 91.185(c) may not always be the best idea from a safety perspective, and fortunately, 91.3(b) allows us to deviate from 91.185(c) if we feel safety is compromised by following it. When and how you would do that is indeed a good topic for discussion, but that doesn't change the issue of understanding what 91.185 says to do, which is what I thought the original question was.
Concerning Lost Comms IFR procedures. I would like to have some good examples for discussing and explaining the various sub sections of 91.185.
 
Ron,

This is a side discussion related to fundamental philosophies we each have. You, an accomplished CFI I readily admit, are deeply devoted to the FARs. You know them backwards and forwards and seemingly have complete faith in them to govern and cover all aspects of aviation within this country. That's cool and I envy your level of knowledge of them.

I am a member of the 99% who know the regs as they apply to our particular operations well enough to keep our selves safe and compliant. We know that regulations are based (supposedly) on common sense to keep planes from hitting each other or hitting people or property on the ground.

An analogy would be to civil law. I am a citizen who tries his best to do what feels right and you are a lawyer with indepth knowledge.

With that said, my analogy before is correct in my world. Safe / Illegal is a place I could very well find myself and I would gladly take that over Unsafe / Legal. It's difficult to think of a scenario where that applies but I know it exists and I will every time choose Safe / Illegal over Unsafe / Legal.

The IFR departure does come close. Maybe ratchet it up a bit. Flight from PBI to JFK. Overcast the whole way. Based in PBI with maintenance there. PBI weather is 3,000 overcast for miles. You can see the base goes forever. Cleared to JFK via PalmBeach4 which is straight out to 3,000 , vectors onto the DP and then on course.

You take of and notice you enter the layer at 2,700 feet or so. At 3,000 you're IMC. You continue and notice you've lost comms. You're heading 095 and going out to sea. You're 15 miles from PBI...a good 10 miles out to sea.

I'm not about to fault the pilot who drops back into VMC rather that clag away IMC for the next 1,200 miles and jack up New York's airspace. That, IMO, is Safe / Illegal.

You say the regs cover it. I agree...by the book you clag away. But I promise descending DESPITE the regs is a valid response in this situation. I know it's not supported by regs and that's why I labeled it "safe / illegal".

BTW, the whole safe / not safe, legal / not legal matrix was brought up to me by a fed. That fed would agree with me here.

But the main point of mine is that these exercises make for great discussions...which the OP explicitly asked for. But for a discussion to happen it takes two sides willing to listen to ideas and withholding the temptation to say, 'You're wrong'.
 
You say the regs cover it. I agree...by the book you clag away.
Good -- you have the correct answer to the OP's question.
But I promise descending DESPITE the regs is a valid response in this situation.
Whether that is a "valid response" or not depends on what the question was. If it's the OP's question...
Concerning Lost Comms IFR procedures. I would like to have some good examples for discussing and explaining the various sub sections of 91.185.
...then it is not a "valid response"). If, however, the question was "What would you do in that situation if it ever presented itself?" then it would be a "valid response".

The problem here is that you seem unwilling or unable to distinguish between those two questions, and on an IR practical test, correctly answering the question actually asked is critical to passing/failing the test. I've been answering the OP's question while you seem determined to answer a question that the OP never asked, and confusing my answer to the OP's question as being my response to some other question which wasn't part of the discussion until you jumped in and tried to make it so.
 
Well maybe we have a difference of opinion of what the OP wants.

I read it and figured he wanted topics of discussion concerning lost comms and how it applies to FARs. You interpret the OP as wanting FAR based scenarios on lost comms. Personnaly I think my way yields the better conversation as it applies to real world and touches on a subject all of us have little real life experience with.
 
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