lost comm Q

[taseal]

lets say you have gotten your CRAFT, and it is 'cleared to opa locka via RV, climb and maintain 3,000, expect 6,000 after 10 mins' (we are comign from FXE lets say)

so you take off, they say 'fly heading 090' and BAM radios go out.

we are in IMC for the whole trip

what do I do?

fly as filed, after the last VOR I hit, fly to a IAF and shoot an app? (if you look on the chart, there is really no airway that'll take me o the IAF for OPF 9L ILS, i'd have to fly some radial to get to it)

here is the chart for it:

http://flightaware.com/resources/air...LS+RWY+09L/pdf

when we go there, we'll usually just file DHP and thats it

if this happened to me, what I would do is I would get on that 315 radial off DHP hold at IAF until ETA (I guess hold on 315 radial?), then I would go ahead and shoot the app. for alt, i would climb to 3,000 and go upto 6,000 after 10 mins (what alt should I be at while holding for my ETA to come up?)

[MidlifeFlyer]

We are assuming that you don't consider your loss of comm as an emergency, right?

You have a problem. The biggest is that, unless you have an IFR Appproach GPS, there is no approach that you can fly since (a) they have no IAF and (b) require radar.

But you're getting into territory where there is some room for serious disagreement. You say you were "cleared to opa locka." So whey are you waiting until ETA anywhere?

91.185(c)(3) talks about two kinds of clearance limits:

(i) one from where and approach begins. You don't have that since there's no IAF; and
(ii) one from where an approach doesn't begin. In that case you go to a fix from where an approach begins.

Oops.

But your clearance limit isn't a "fix." It's the airport. There is a very strong school of thought out there that that's where you go. Best way that you can.

I would do exactly what you suggest, but I wouldn't do an uncharted hold at DHP waiting for ETA.

This should be an interesting discussion. There is legitimate disagreement about this. Part of it is the reality that these were designed for a non-radar environment. That doesn't only mean the common "heck they can see you so just go to the airport." Non-radar also means that timing is king - reporting points where you give ETAs at each one along the way. No wonder the rules required holding until ETA - everyone's depending on your time calculations and if you didn't follow them, who knows who else might be in the airspace you want to occupy.

The other piece is that 91.185 simply doesn't account for all lost comm situations. Notice the questions like yours - all of the good ones deal with scenarios where the rule doesn't fit exactly.

[taseal]

Originally Posted by MidlifeFlyer

We are assuming that you don't consider your loss of comm as an emergency, right?

You have a problem. The biggest is that, unless you have an IFR Appproach GPS, there is no approach that you can fly since (a) they have no IAF and (b) require radar.

But you're getting into territory where there is some room for serious disagreement. You say you were "cleared to opa locka." So whey are you waiting until ETA anywhere?

91.185(c)(3) talks about two kinds of clearance limits:

(i) one from where and approach begins. You don't have that since there's no IAF; and
(ii) one from where an approach doesn't begin. In that case you go to a fix from where an approach begins.

Oops.

But your clearance limit isn't a "fix." It's the airport. There is a very strong school of thought out there that that's where you go. Best way that you can.

I would do exactly what you suggest, but I wouldn't do an uncharted hold at DHP waiting for ETA.

This should be an interesting discussion. There is legitimate disagreement about this. Part of it is the reality that these were designed for a non-radar environment. That doesn't only mean the common "heck they can see you so just go to the airport." Non-radar also means that timing is king - reporting points where you give ETAs at each one along the way. No wonder the rules required holding until ETA - everyone's depending on your time calculations and if you didn't follow them, who knows who else might be in the airspace you want to occupy.

The other piece is that 91.185 simply doesn't account for all lost comm situations. Notice the questions like yours - all of the good ones deal with scenarios where the rule doesn't fit exactly.

I see... but why wouldn't I hold at IAF (molts or that other one... OKRAS or somethign?) until ETA? I thought thats what I was supposed to do. at least that is what my notes say.

not too many responses btw.. interesting, did I post this in the wrong section or something? lol

[surreal1221]

How do you know MOLTS or OKRAS is an IAF? I see no IAF indicated anywhere on that chart.

I also note the note: Radar Required. Meaning that, well, you've gone lost comms, and well - can you receive radar vectors without having comms? Didn't think so.

I'd be looking at another approach to shoot, that actually has an IAF.

Such as the GPS 9, if (in your scenario) you have an IFR certified GPS.

[MidlifeFlyer]

Originally Posted by taseal

I see... but why wouldn't I hold at IAF (molts or that other one... OKRAS or somethign?) until ETA? I thought thats what I was supposed to do. at least that is what my notes say.

I know. That's what a lot of people's notes say. Point is the reg doesn't talk about IAF. It talks about "clearance limit." Most initial clearances start with "cleared to the XYZ airport" with limits imposed, if at all, sometime later in the flight.

Besides, as surreal and I both suggested, what IAF? Where do you see an IAF on that approach chart?

[Schinpop]

From Dolphin, I'd fly the 345 radial to MOLTS and fly a standard proceedure turn at no less than 2100MSL, then fly the approach. I would not hold anywhere.

Reasoning: Coming in from DHP, you'll need a course reversal to get on the ILS with any accuracy, and I'd rather start that from MOLTS than OKANE. I would stay above the MSA since a course reversal is not published. I would not hold because this is a radar environment and they most likely can see you. The best bet is to get out of the way as soon as you can.

Probably not 100% according to the regs (close, though), but probably reasonable and safe. I wouldn't mind defending this to the FAA if I was really lost comm and hard IFR.

[surreal1221]

I really think these types of questions are to be evaluated from the following point of view:

What actions will break the minimum regulations? What actions will also allow me to get on the ground, safely while minimizing my time in the air?

I don't know about everyone else, but if this were to happen to me, I know exactly what I'd do after I got back on the ground.

A NASA report would be filled, detailing what I did, why I did it, emphasizing safety of flight and of the public on the ground.

Real quickly though, I'm not going to make up a procedure turn on my own, albeit, it probably wouldn't be a horrible decision. . .but I'm not going to make up a procedure just for the heck of it. Especially if a perfectly useful GPS 9 approach is available (if so equipped). I can just see the write up over at AvWeb concerning an accident where a pilot generated his/her own procedure turn for an ILS approach that was radar required, clipped a tower when all he/she had to do was fly a perfectly charted GPS approach that is equipped with IAF(s) instead.

[Stone Cold]

Originally Posted by surreal1221

I really think these types of questions are to be evaluated from the following point of view:

What actions will break the minimum regulations? What actions will also allow me to get on the ground, safely while minimizing my time in the air?

I don't know about everyone else, but if this were to happen to me, I know exactly what I'd do after I got back on the ground.

A NASA report would be filled, along with a written statement and report to the FAA detailing what I did, why I did it, emphasizing safety of flight and of the public on the ground. Whether they liked what I did or not, it's what I did.

Couple things as well. I'm not going to fly an approach that says radar required, not happening. It's radar required for a reason. I'm not going to make up a procedure turn on my own, albeit, it'd prolly be safe. . .but I'm not going to make up a procedure just for the heck of it. Especially if a perfectly useful GPS 9 approach is available.

Myself, personally, will NEVER send anything to the FAA without legal council and being asked for it. NASA report, absolutely, but voluntarily writing the FAA is something I don't see myself doing.

[surreal1221]

Agreed. . .I retract that statement. I forgot to mention I'd have AOPA legal on the phone first.

Now here is a question.

If you do indeed go NORDO, is that not classified as an emergency, and thus a phone call(or contact) to(or with) the Air Traffic Manager not required?

[Stone Cold]

Originally Posted by surreal1221

Agreed. . .I retract that statement. I forgot to mention I'd have AOPA legal on the phone first.

Now here is a question.

If you do indeed go NORDO, is that not classified as an emergency, and thus a phone call(or contact) to(or with) the Air Traffic Manager not required?

Did the pilot declare an emergency? In a NORDO situation, there's only one way to declare...put it in the squawk, from my understanding. ATC cannot declare for a pilot, correct?

Yes, I would give a courtesy call to the tower and thank them for the light gun signals that you will get, and for their help. That's about all I would say. If they need more info, we'll meet off the record (and away from recorders) until I have legal council, no matter what. YMMV, but I hate lawyers and the FAA has a lot of them. Might as well fight fire with fire to cover my proverbial rear!!!

[surreal1221]

You are correct, ATC can not declare for a pilot. And I can't for the life of me remember from my CTI education if a NORDO was considered an emergency by the FAA, with or without a pilot's declaration. Hence the gray area, that I won't even bother to go into as yes. . .it's better to fight fire with fire.

[Schinpop]

Originally Posted by surreal1221

Real quickly though, I'm not going to make up a procedure turn on my own, albeit, it probably wouldn't be a horrible decision. . .but I'm not going to make up a procedure just for the heck of it. Especially if a perfectly useful GPS 9 approach is available (if so equipped). I can just see the write up over at AvWeb concerning an accident where a pilot generated his/her own procedure turn for an ILS approach that was radar required, clipped a tower when all he/she had to do was fly a perfectly charted GPS approach that is equipped with IAF(s) instead.

I'm not sure why you keep falling back on GPS - the original supposition indicated the ILS. Sure, if you've got another piece of equipment, great. I was merely trying to solve the problem given. Also, I won't hit a tower on my made up course reversal because I'm guaranteed obstacle clearance as per the MSA. An alternative would be to try a direct intercept at OKANE, but I think it would be harder to be stabilized prior to MOLTS.

[surreal1221]

Ah yes, the OP did specify the ILS as the approach of choice.

Unfortunately that approach of choice is radar required, and lacks an IAF.

Hence my determination to seek another type of approach.

While I will fly a plane without GPS if needed, I will make damn sure I'm fully aware of potential approaches into my destination, and equipment requirements. If I'm flying a non-GPS equiped aircraft into an airport that has an ILS approach that lacks an IAF, I'll be looking for the nearest airport that does have such (be it VOR, ILS, LOC with an IAF, even if it must be a Circle-To-Land.

Especially if it's solid IMC.

[TFaudree_ERAU]

Originally Posted by surreal1221

You are correct, ATC can not declare for a pilot.

Really? Why did I have the trucks follow me in to the ramp when I had a tach sensor go bad in the Cirrus (causing RPM indications between 2000 and 3200), after I specifically said "NEGATIVE, I AM NOT DECLARING AN EMERGENCY, I just need to return to land." There are three people that can declare an emergency for a flight; the crew, a dispatcher and a controller.

Originally Posted by surreal1221

And I can't for the life of me remember from my CTI education if a NORDO was considered an emergency by the FAA, with or without a pilot's declaration. Hence the gray area, that I won't even bother to go into as yes. . .it's better to fight fire with fire.

I don't care what the 7110.65 says. If I'm a pilot, its an emergency. If I'm a controller, its an emergency. The AIM covers two way radio failure in Chapter 6, titled Emergency Procedures.

[taseal]

thx guys...

you are right, there is no IAF. good point. but I didn't even think about the GPS stuff because I'm not equipped with one (hell, I don't even know how to shoot one if there is anything diff)

could you tell me where it says about the CL holding til ETA and all? I want to show my inst that there is nothing about IAF in there. is it in the regs, or AIM CH6?

so what are my options here in deep IMC without breaking any regs? can't shoot GPS because i'm not equipped. can't really do that app mainly because its RV.

what if the distance was alot longer and controller gave you a clerance upto like halfway? (kinda hard to explain)

bear with me, I'm almost done with inst

lets say you take off from KFXE and you are going to KVRB

you filed V3 there lets say...

you get your CRAFT and it says 'via radar vectors'

you take off and they send you 270 and tell you to join up V267, while you are on your way (or we can say you joined up V267) you lose comms. what now? we we were told to join up V267, but nothing after that... would I turn around and fly to V3 to fly my filed plan?

check out the routes at www.skyvector.com so you can see what i'm talking about

[ScottG]

Originally Posted by TFaudree_ERAU

There are three people that can declare an emergency for a flight; the crew, a dispatcher and a controller.

I believe the owner (goes with dispatcher) can declare as well, assuming they are not the one in the plane.

[MidlifeFlyer]

Originally Posted by taseal

could you tell me where it says about the CL holding til ETA and all? I want to show my inst that there is nothing about IAF in there. is it in the regs, or AIM CH6?

If you're studying this stuff, you absolutely need to read the Part 91 IFR regs. IMO IFR is 90% about rules and procedures and only 10% about flying.

The reg on lost comms is 91.185, entitled, appropriately enough, " IFR operations: Two-way radio communications failure."

[MidlifeFlyer]

Originally Posted by surreal1221

If you do indeed go NORDO, is that not classified as an emergency, and thus a phone call(or contact) to(or with) the Air Traffic Manager not required?

AFAIK, NORDO is not =automatically= classified as an emergency. But even if it were, remember that emergency authority only lets you "deviate from any rule of this part to the extent required to meet that emergency."

Supposing good airplane, clearly understood route, how much deviation is really needed to meet "ooh! there's no one to talk to!"

I'm really not minimizing the serious nature of lost comm in actual, especially since lost comm rarely happens all by itself. It may be the early signs of a more serious problem.

And remember that when you do deviate because of an emergency, you only need to make a report "upon the request of the Administrator."

[taseal]

Originally Posted by MidlifeFlyer

If you're studying this stuff, you absolutely need to read the Part 91 IFR regs. IMO IFR is 90% about rules and procedures and only 10% about flying.

The reg on lost comms is 91.185, entitled, appropriately enough, " IFR operations: Two-way radio communications failure."

thanks mark!

[MidlifeFlyer]

Originally Posted by taseal

thanks mark!

You are welcome. But remember - I said at the beginning that there is not universal agreement on the "you don't have to wait if you were cleared to the airport" view of the language. You really didn't see much of that here, but I've seen some pretty hard-hitting arguments over it.

lets say you take off from KFXE and you are going to KVRB

you filed V3 there lets say...

you get your CRAFT and it says 'via radar vectors'

you take off and they send you 270 and tell you to join up V267, while you are on your way (or we can say you joined up V267) you lose comms. what now? we we were told to join up V267, but nothing after that... would I turn around and fly to V3 to fly my filed plan?

Now that you are looking at the rule and not just your notes about it, how would you answer your question?

What was your filed plan?