Assess my 7600 actions

Let'sgoflying!

Let'sgoflying!

Touchdown! Greaser!
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Dave Taylor
Friday afternoon I was going into Dallas Love, from the west - kind of a busy time there.
I was on an arrival and just before the Class B the radios went TU and I could not hear regional approach for nothing.
It was vmc, I was at 8000', I didn't want to eff up the entire Class B and Love's day, so I put on the traffic screen saw nothing to my left, descended that direction and dialed up 7600.
I landed at an uncontrolled field outside the bravo, got the radio problem fixed and went to dal with no problems.
(The fbo knew I was coming, gave me the number of approach and they said glad to hear from me etc etc.)

Suggestions welcome.
Also I have to ponder how it would have played out if I had completed the star, and made my own way to the destination runway ie (if it was imc.)
 
In all respects you did perfectly. And your pontification would have been proper, expected and perfectly done.

If VMC, stay VMC and land. Easy to mess that one up by overthinking it, you didn’t, bravo!!

If IMC… make your way to your (cleared, expected or filed) destination, and land.
 
I think you did it right. What is the question?
 
Let'sgoflying! said:
Friday afternoon I was going into Dallas Love, from the west - kind of a busy time there.
I was on an arrival and just before the Class B the radios went TU and I could not hear regional approach for nothing.
It was vmc, I was at 8000', I didn't want to eff up the entire Class B and Love's day, so I put on the traffic screen saw nothing to my left, descended that direction and dialed up 7600.
I landed at an uncontrolled field outside the bravo, got the radio problem fixed and went to dal with no problems.
(The fbo knew I was coming, gave me the number of approach and they said glad to hear from me etc etc.)

Suggestions welcome.
Also I have to ponder how it would have played out if I had completed the star, and made my own way to the destination runway ie (if it was imc.)
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Ya did zacktly what ya supposed to do, which is “…continue the flight under VFR and land as soon as practicable…” As far(pun intended) as if it was IMC I’d have to know more if “…made my own way…” would have been appropriate. It could have have been a case where FAR 91.185 would have taken you all the way to landing without having to invoke AIM 6-4-1
 
No suggestions. Perfect solution.

If you completed the STAR, you would have closed the airspace from the moment ATC knew you were lost com until you landed. My fallible crystal ball says the FAA would have investigated. You'd defend by saying 91.185 says to do it. The FAA would look for a reason it didn't apply or to blame you for the lost com.

To me, the first two sentences of AIM 4-6-1 always applies

It is virtually impossible to provide regulations and procedures applicable to all possible situations associated with two-way radio communications 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.​

Which leads me to a question: how did you have a com failure but retain nav capability? Only one radio? com antenna broke?
 
This felt very uncomfortable, simply b/c in every time before this, I stayed on the assigned route and altitudes and now I was shooting off in a wild direction without telling anyone! It’s a little disconcerting but I wanted to make sure I didn’t miss some better solution.
 
Greg Bockelman said:
Mark 1 eyeball. He was VMC.
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I know that. My question is about the system issue that would result in, for example, both com radios going dead but the VLOC or GPS continuing to plug along.

Besides, I've heard that the Mark 1 Eyeball is not an approved navigation source for following a STAR, even if you can identify every fix based on ground references.
 
Once the radios quit, I went Foreflight to diversion airport.
How radios quit is above my pay grade.
 
Assess my 7600 actions
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YOU 'DA MAN! [Zero sarcasm intended.]

You can fly my family anytime, Captain.
 
91.185 is past due for a rewrite to reflect the realities of GPS navigation. If cleared to an airport and lost comms in IMC, most of us would fly to an IAF and shoot an approach. The regs don't reflect that. I don't recall the last time my clearance limit wasn't an airport.
 
DoubleD said:
91.185 is past due for a rewrite to reflect the realities of GPS navigation. If cleared to an airport and lost comms in IMC, most of us would fly to an IAF and shoot an approach. The regs don't reflect that. I don't recall the last time my clearance limit wasn't an airport.
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They never should have changed "holding fix" to "clearance limit" (https://static1.squarespace.com/sta...f699bb30df228990/1463758269692/08+05+1985.pdf), it confuses the Chief Counsel to no end.

EDIT: In 1980, it used to be 91.127(c)(4) "Leave holding fix".
 
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dtuuri said:
They never should have changed "holding fix" to "clearance limit" (https://static1.squarespace.com/sta...f699bb30df228990/1463758269692/08+05+1985.pdf), it confuses the Chief Counsel to no end.

EDIT: In 1980, it used to be 91.127(c)(4) "Leave holding fix".
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Yeah. The Chief Counsel was trying to fit a square peg into a round hole. Changing Holding Fix to Clearance Limit wouldn't have caused so much controversy if 91.185 (c) (3) (ii) said 'If the clearance limit is a fix from which an approach does not begin..." like it was meant to have. You got mentioned in a decision of theirs. It was a letter you sent to the procedures folk, don't remember which office, that they forwarded to the Counsel. Do you still have that? Here's another link to the rule making. It changed 91.127. 91.185 was just a renumbering, the text remained the same.

Dynamic Regulatory System

drs.faa.gov drs.faa.gov
 
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luvflyin said:
You got mentioned in a decision of theirs. It was a letter you sent to the procedures folk, don't remember which office, that they forwarded to the Counsel. Do you still have that?
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I wrote to the office that made the change which was ATO (ATC) via the customer help website. ATO dumped the questions to Chief Counsel and it was handed down (passed the buck) to a newbie lawyer (Sabrina Jawed). When her first answer didn't respond to my questions I protested, so she did a slightly better job, but with a tone of "authority". She still didn't know what she was talking about, though, so I complained and was advised the matter was considered closed. Bureaucrats! :tongue:

Here's my actual initial question and a revision to one of them. Read it from the bottom up.

Also, here's the proposed FAA language.

And the final rule w/background.
 

Attachments

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  • Final_rule_with_background.pdf
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I'll just throw in the Opposing Bases podcast episodes of 278 and 283 from earlier this year regarding this topic, if you want to hear ATC folks' realistic expectations. People get themselves twisted in knots (pun intended :D) with FAR 91.185. Too bad plain language can't be used, like "If IMC get your ass on the ground as safely and as quickly as practicable without getting in the way, if possible."
 
dtuuri said:
I wrote to the office that made the change which was ATO (ATC) via the customer help website. ATO dumped the questions to Chief Counsel and it was handed down (passed the buck) to a newbie lawyer (Sabrina Jawed). When her first answer didn't respond to my questions I protested, so she did a slightly better job, but with a tone of "authority". She still didn't know what she was talking about, though, so I complained and was advised the matter was considered closed. Bureaucrats! :tongue:

Here's my actual initial question and a revision to one of them. Read it from the bottom up.

Also, here's the proposed FAA language.

And the final rule w/background.
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So ATO didn't want to talk about it, just shook their heads, passed the buck to chief counsel and walked away.:dunno::fingerwag: Is there a way to find that "Advance Notice of Proposed Rulemaking (ANPRM) No. 79-2 (44 FR 4572; January 22, 1979)." I'd like to see that.

 
luvflyin said:
So ATO didn't want to talk about it, just shook their heads, passed the buck to chief counsel and walked away.:dunno::fingerwag: Is there a way to find that "Advance Notice of Proposed Rulemaking (ANPRM) No. 79-2 (44 FR 4572; January 22, 1979)." I'd like to see that.
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From FederalRegister.gov:

It looks like you were searching for the citation 44 FR 4572.

The 1936-1994 official print volumes of the Federal Register have been digitalized and are available online in PDF format. We found the following published on January 22, 1979.

[attachment size were too large for the forum]
 
DJTorrente said:
From FederalRegister.gov:

It looks like you were searching for the citation 44 FR 4572.

The 1936-1994 official print volumes of the Federal Register have been digitalized and are available online in PDF format. We found the following published on January 22, 1979.

[attachment size were too large for the forum]
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Can you give me the link to that?
 
luvflyin said:
Whew! That was a long read. What AOPA was proposing was about reorganizing the format of the FAR's. Renumbering them. In their proposal, 91.127 would become 91.229. It quoted the Lost Com rule itself. But there was no discussion about changing it. Nothing about Airports being treated as Fixes.
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Heh. It seems like such a simple thing for people to understand if they would just go back and follow the history of the rule — especially the Chief Counsel's office, like you just have. I've argued the point here many times and yet people still get tripped up on "leave clearance limit" and want to overfly the airport. They still want to hold until ETA, too, even though the clearance limit is usually their destination airport since departure. And they don't want to remain at altitude until the end of their cleared routing reaches the initial approach fix for the approach procedure, either. All these things they "want" to do are not according to the history of 91.185 as amended by Amendment 91-189 about 40 years ago. So, they want to rewrite the rule to reflect their own misunderstandings. All that needs be done is UN-change "clearance limit" back to "holding fix".
 
What did it take to fix your coms?
 
A good radio tech and a credit card.
Not my plane so I have no details. I suspect a realignment of the electrons.
 
dtuuri said:
Heh. It seems like such a simple thing for people to understand if they would just go back and follow the history of the rule — especially the Chief Counsel's office, like you just have. I've argued the point here many times and yet people still get tripped up on "leave clearance limit" and want to overfly the airport. They still want to hold until ETA, too, even though the clearance limit is usually their destination airport since departure. And they don't want to remain at altitude until the end of their cleared routing reaches the initial approach fix for the approach procedure, either. All these things they "want" to do are not according to the history of 91.185 as amended by Amendment 91-189 about 40 years ago. So, they want to rewrite the rule to reflect their own misunderstandings. All that needs be done is UN-change "clearance limit" back to "holding fix".
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It would be unreasonable to expect pilots to to go back research the history of FAR's. I can see a logic behind replacing Holding Fix with Clearance Limit. That is you don't always reach the Fix before getting cleared beyond it, or even get holding instructions by then. See AIM 5-3-8. Was that the logic someone was using when deciding to use the term Clearance Limit instead of Holding Fix? I dunno but it seems likely to me. I see the solution to the chaos this has caused is a rewording of 91.185 (c) (3) (ii) from "When the clearance limit is not a fix from from which an approach begins..." to 'when the clearance limit is a fix from which an approach does not begin.' Look at (3) (i) for perspective. The change to 91.127, the text remained the same when renumbered 91.185, was only about a change in ATC procedure. They had done away with using both the terms EAC and EFC and used only EFC. EAC's were given when the Fix was on the approach chart. EFC's when it was not. So now they have to make a distinction between that. I'll leave this off with 'if your clearance limit is the airport, when you arrive at it, you should get off of the runway and don't depart again until you get your radios fixed.'
 
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luvflyin said:
...you don't always reach the Fix before getting cleared beyond it, or even get holding instructions by then.
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That was and still is covered. If there is no EFC you aren't supposed to hold, else when would you be expected to leave?
 
dtuuri said:
Heh. It seems like such a simple thing for people to understand if they would just go back and follow the history of the rule — especially the Chief Counsel's office, like you just have. I've argued the point here many times and yet people still get tripped up on "leave clearance limit" and want to overfly the airport. They still want to hold until ETA, too, even though the clearance limit is usually their destination airport since departure. And they don't want to remain at altitude until the end of their cleared routing reaches the initial approach fix for the approach procedure, either. All these things they "want" to do are not according to the history of 91.185 as amended by Amendment 91-189 about 40 years ago. So, they want to rewrite the rule to reflect their own misunderstandings. All that needs be done is UN-change "clearance limit" back to "holding fix".
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You provided an extensive discussion of this last year in another thread:

www.pilotsofamerica.com

Hold at fix due to frequency congestion

I filed IFR today to do an approach for currency. Because I was filing to my departure airport I added a nearby VOR as an enroute fix, just a few miles away: KUNV-PSB-KUNV. Previously when I've done this, I've contacted center and either (1) gotten vectors, or (2) been cleared for the approach...
www.pilotsofamerica.com www.pilotsofamerica.com

There, you provided some links to Federal Register pages, one of which is broken. Here are a couple of direct links to the Federal Register site:

The NPRM that was adopted is at page 49 FR 46749 (you may need to scroll down a bit):


The final rule is at page 50 FR 31587:


If those links get broken, I provided the page numbes above for use with the federalregister.gov search feature.
 
I know a guy that once threw up on his microphone in IMC. Lightspeed never thought of that. It immediately failed. Good news is that if you spend enough time in a hold, the microphone will start working again, or so I was told.
 
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