Q: IFR Lost Comms - You Make The Call

Not from "any random location" — you're obliged by the rule to fly the cleared/flight planned route. Presumably, that route description terminates at a location (fix) where you have the ability to safely continue your navigation to an IAF. Once at the IAF, you may descend as the enroute portion is ended there. For somebody loosely filing "direct" the entire way, I can see this causing the impression you mentioned of "any random location". For them, in our age of precision navigation, this must cause heartburn. Really though, their flight planning should have assured themselves that a track from any point of radio failure to the IAF was viable both obstruction and signal-wise. From ATC's center perspective, the geometry between a track to the airport and one to an IAF from beyond the terminal area would hardly be noticeable. Once inside the terminal area it would hardly be important — TRACON's going to protect all the approaches anyway.


I get it a lot of people don’t like this regulation as written, but English comprehension prohibits making an augment the reg says, or means, leave the last point in the route and go directly to an IAP. I also get the do what you want the controllers will clear the skies for you argument, but the FAA isn’t going to ever say that because there are situations where they can’t do that and the FAA is not going to be on the losing end of a lawsuit telling you do this this short of your emergency authority. If a mid air, the FAA will argue their controller’s actions assumed you would comply with the regulation and they aren’t at fault.

The applicable parts of the reg, plain English:

Each pilot who has two-way radio communications failure when operating under IFR shall comply with the rules of this section.

By the route assigned in the last ATC clearance received; 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.
 
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Everytime I have seen this discussed, actual working controllers stated that they clear all the airspace around you, and what helps is to get on the ground asap. That is, if it makes sense to fly directly to the IAP, do it. They can see you on radar and will clear out the area.

With electronic panels, that is another whammy to get on the ground ASAP. IMC with electrical failure is an emergency.
 
I get it a lot of people don’t like this regulation as written, but English comprehension prohibits making an augment the reg says, or means, leave the last point in the route and go directly to an IAP.
How else would you get there then? If the destination airport is the clearance limit and your plane isn't equipped to overfly it using RNAV and if lost comm rules apply equally to all IFR aircraft regardless of how they're equipped — the only way in common for all aircraft to get to the destination is via an SIAP. English is the wrong course of study, IMO, logic would better apply, wouldn't it?
 
How else would you get there then? If the destination airport is the clearance limit and your plane isn't equipped to overfly it using RNAV and if lost comm rules apply equally to all IFR aircraft regardless of how they're equipped — the only way in common for all aircraft to get to the destination is via an SIAP. English is the wrong course of study, IMO, logic would better apply, wouldn't it?
Duh, if you can’t get there, why did you accept the clearance? Talk about logic.
 
You are not in the 80s anymore, but the system was far more accommodating to getting there via VORs and using LOCs and NDBs than today.
For those of us who rent, even in 2023 we can't always get the equipment we want. Even with rental planes that have IFR GPS, not all of them have up-to-date databases.
 
For those of us who rent, even in 2023 we can't always get the equipment we want. Even with rental planes that have IFR GPS, not all of them have up-to-date databases.
Rentals with expired data bases and no VOR receivers accuracy checks. Perfect! You are really going to be unhappy in the next year as a bunch more VORs are shut down.

Honestly, it is a mind set. If you are flying rentals and they don’t update the RNAV data you should be asking if you really want to fly their aircraft in the clouds.

 
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Feeder route from a VOR filed as you last fix will get you there.
You SO inspire me to have the last word! :) Suppose this feeder route of which you speak has a dogleg. And you didn't include it in your route description, since you said it occurs after the last fix. Do you fly directly to the geographic center of the airport instead of via the charted feeder route to the IAF? According to my understanding of your English interpretation you would, but I would fly the feeder route to the IAF because it's more logical and I'm not hung up on a dogmatic meaning of "direct".
 
You SO inspire me to have the last word! :) Suppose this feeder route of which you speak has a dogleg. And you didn't include it in your route description, since you said it occurs after the last fix. Do you fly directly to the geographic center of the airport instead of via the charted feeder route to the IAF? According to my understanding of your English interpretation you would, but I would fly the feeder route to the IAF because it's more logical and I'm not hung up on a dogmatic meaning of "direct".
Is there some way to include an SIAP in your filed flght plan?

Seems simple to me; there is a way and you can start your descent to 2700 after LAL. https://aeronav.faa.gov/d-tpp/2310/00939IL10.PDF
 
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Rentals with expired data bases and no VOR receivers accuracy checks. Perfect! You are really going to be unhappy in the next year as a bunch more VORs are shut down.

Honestly, it is a mind set. If you are flying rentals and they don’t update the RNAV data you should be asking if you really want to fly their aircraft in the clouds.

They're lease-backs, and it seems to be up to the individual owners to decide whether they want to pay for a database subscription. The club itself does a good job on maintenance.
 
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