Lost communications question IFR

[bunk]

FAR 91.185: IFR 2-way radio communications failure. Leaving clearance limit: "commence descent or descent and approach as close as possible to the ETA as calculated from the filed or amended estimated time enroute"

 

My question: should you start the approach so you reach the airport at the ETA in the flight plan or should you leave the fix at the ETA?

[flingwing206]

FAR 91.185: IFR 2-way radio communications failure. Leaving clearance limit: "commence descent or descent and approach as close as possible to the ETA as calculated from the filed or amended estimated time enroute"

 

My question: should you start the approach so you reach the airport at the ETA in the flight plan or should you leave the fix at the ETA?

If the clearance limit is the IAF of an approach, leave the CL at the ETA. If the CL is not the IAF for an approach, leave the CL at the estimated time to hit the IAF at the ETA.

 

Remember when you plan an IFR flight, you plan fuel accounting for the time taken with approaches, but you plan your ETA to an IAF.

[rotorgeh]

FAR 91.185: IFR 2-way radio communications failure. Leaving clearance limit: "commence descent or descent and approach as close as possible to the ETA as calculated from the filed or amended estimated time enroute"

 

My question: should you start the approach so you reach the airport at the ETA in the flight plan or should you leave the fix at the ETA?

 

>Part 91.121 (3) (ii) : states "commence descent or descent & approach as close as possible to the estimated time of arrival as calculated from the filed or amended (with ATC) estimated time en route."

I have actually had a complete com failure in Falcon 20 in IFR conditions while on IFR flight plan while arriving in Toledo Ohio. I did the above, started the descent on the ILS at the estimated time of my arrival on the flight plan. Considering an approach will only take a 3 minutes or less ATC will probably not complain. But starting the approach on the time of est. arrival will give ATC some kinda of idea when you are going to descend. After touching down I was buzzed by two F16's on both sides. After talking to AtC Tracon Super. He stated that the f-16's had been following me the last 100 miles or so. this was soon after 911 and everybody was still nervous about jet aircraft not talking to anyone. I was scolded by the super. that I had failed to squawk 7700 one minute prior to squawking 7600 and was not considered an emergency aircraft. I told the super. that was old school and that 7700, 7600 and 7500 are all considered emergency beacon codes now according to the current far/aim. In the past 7700 was emergency code and 7600 and 7500 were informational only. He stated that he would have to talk to the Faa Attorney's. I got called several hours later and was told that no further action would be taken and the working controller had asked tha a GOOD JOB be past along to me. I still filed my Nasa form anyway, but never heard anything again from the FAA. THe second time I lost full com failure to a stuck mike button on the yoke I was at fl 290 in vfr conditions. I stayed on flight planned route and was in visual conditions. I squawked 7700 then 7600. I looked down and was passing over a airport that my GPS told me had a large enough runway for the Falcon. I again squawked 7700 for a minute then back to 7600 and did slow circle for 5 minutes. I then started a slow circleing descent at a 1000 fpm while circleing the airport of intended landing. At traffic pattern I got the green light to land and did. After the phone call ATC was was once again pleased at my course of action to land in VFR conditions than continuing to my destination which was a busy class b airspace airport. I now no longer fly for the freight company and have no further problems like this. Try follow the written rules as close as you can, but remember safety is first and justify your actions....I always try live by the saying of that I would rather be tried by 12 than carried by 6....Good Luck and hope this helped......

[bunk]

I didn´t know about calculating the ETA to the IAF but it makes sense. Your answers helped, thanks guys!!

[Rob Lyman]

If the clearance limit is the IAF of an approach, leave the CL at the ETA. If the CL is not the IAF for an approach, leave the CL at the estimated time to hit the IAF at the ETA.

 

Remember when you plan an IFR flight, you plan fuel accounting for the time taken with approaches, but you plan your ETA to an IAF.

Actually, my CFII examiner emphatically told me that if you are "cleared to ABC airport via..." than your clearance limit IS the airport. You do NOT hold at any fix short of the airport. The intepretation passed down to examiners from the Orlando FSDO was that a clearance to an airport is not a clearance limit,so any holding until EFC required in 91.185 only applies to a clearance limit which is short of your destination.

[joker]

I agree with Rob Lyman's examiner.

 

Here's the history.

 

91.185 was written in the days before radar was readily available. In those days all clearances had to be given to 'navaids' rather than airports. These would be the 'clearance limits'. Clearance limits were issued to ensure that the tower, without radar coverage, could exactly predict the time that a NORDO aircraft would be using the IAF and be able to prepare for it by delaying that aircraft until the clear the airways and approaches ahead empty.

 

Nowadays as many airports are served by radar, then the IFR Clearance can be from airport to airport. With radar ATC can monitor the progress accurately, and so clearance limits are not necessary.

 

This is mentioned in the AIM.

 

4-4-3. Clearance Items a. Clearance Limit. The traffic clearance issued prior to departure will normally authorize flight to the airport of intended landing.

 

So infact when you are cleared to an airport, you don't have any use for 91.185(c )(3) as a clearance to an airport is not a 'clearance limit', it is a route clearance which happens to terminate at your destination. It would be crazy to get to your destination then leave it to go and follow (c )(3)! A 'clearance limit' suggests more flight after it.

 

Thus you must apply 91.185(c )(1) when your clearance is to an airport.

 

(1) Route.

(i) By the route assigned in the last ATC clearance received;

(ii) If being radar vectored, by the direct route from the point of radio failure to the fix, route, or airway specified in the vector clearance;

(iii) In the absence of an assigned route, by the route that ATC has advised may be expected in a further clearance; or

(iv) In the absence of an assigned route or a route that ATC has advised may be expected in a further clearance, by the route filed in the flight plan.

 

What about timing?

 

Well, again...get(c )(3) out of your head, and think of the airport as just another fix along the route, as you get in say an non-radar environment. Of course you would aim to get to each fix according to the timing schedule you have provided to the FAA (+/- 3 mins - remember the mandatory reports?!). As the only pertinent timing is your ETA, you should follow your routing and arrive at the 'end of the route segment you have been cleared for (in this case the airport)' at the ETA you specified (in this case the ETA of your whole flight).

 

It should be easy enough therefore to make speed adjustments to do this. You should not arrive early...but even if you did you are being monitored by radar so not the end of the world. Still go ahead and land, though you might cause a stir in the ATC as they try to spin aircraft ahead of you from your route and approach. But that's their problem. Afterall, they 'cleared' you for that routing. (Don't forget in a non-radar environment you wouldn't get the airport to airport clearance.)

 

Rotorgeh gives us a very good account of his personal experiences. (Thanks for that. It sounds like you conducted your self safely and thoughtfully.)

 

He explains that he started his approach at his ETA. Well, I don't know what his clearance was, but if it was to the airport that was not strictly necessary. However, it is acceptable as you still have protection on the approach.

 

You see, although ATC thought his ETA was at the airport (according to the reasoning I said above), it doesn't matter. When Rotorgeh started his approahc at the ETA, he was actually behind the ATCs expected schedule. Read on.

 

ATC consider the approaches (from IAF to RWY) as an extension of the airport. Also all IAFs are protected for 30 minutes until after the ETA. This also makes Flingwing's stated practice of stating your ETA to your IAF, rather than destination work too. Although doing this is not strictly necessary, you will still be protected at the IAF.

 

Likewise, if you did slow down to arrive at IAF and start approach at your ETA (as Rotorgeh did), then you are protected too.

 

What I'm saying is that the ETA is the 'magic' time. Regardless of whether you use ETA as your arrival at the IAF or whether you use ETA as your landing time, all of the regulations in 91.185(c ), when used correctly, are designed to ensure you are on the approach after that time - i.e. during the 30 minutes when the approaches are protected. Apart from of course, in the case of a clearance to an airport. With the clearance to the destination airport you have in a sense already been 'pre-cleared' for that approach, so it doesn't matter.

 

Radio failure in IFR is actually less of an ordeal than in VFR. They know eactly where and when I'm supposed to be. If I keep to the rules above, then everyone will be happy.

 

In summary then:

 

If your clearance says, "Cleared to ABC airport..." or "Cleared to KABC (as in the ICAO identifier)..." you would be most correct to simply fly your route to land at ETA. (If you do slow up and start approach at ETA, then no real problem...that approach is yours for 30 minutes anyway!)

 

Of course, if your clearance is to a clearance limit (i.e. to a point between your departure and your destination) then you should follow 91.185(c )(3)

 

Do note though: Although prior to your departure you received a clearance to an airport, that is often superceeded by in-flight clearances. Remember those words...'last assigned'!

 

Well, I hope this fills in the missing link.

 

Joker

[flingwing206]

Actually, my CFII examiner emphatically told me that if you are "cleared to ABC airport via..." than your clearance limit IS the airport. You do NOT hold at any fix short of the airport. The intepretation passed down to examiners from the Orlando FSDO was that a clearance to an airport is not a clearance limit,so any holding until EFC required in 91.185 only applies to a clearance limit which is short of your destination.

Couldn't agree more - your clearance limit it whatever ATC said you were "cleared to..." When I said "..not the IAF...", I was considering an earlier route segment, not a later one (such as the airport).

[Gomer Pylot]

ATC controllers, at least the ones I know, are basically lazy, and prefer whatever makes the least work for them. If you're NORDO, they want you out of their hair as quickly as possible. They can see you on radar, even if you're just a primary target, and they prefer that you get to your destination and land and quickly as you can. Holding just makes more work, because they have to monitor you and react when you leave the holding pattern. More work, maybe a 'deal' for them. They hate 'deals'. Get to your destination, fly an approach, and land, as quickly as you can. Even better, get to VMC and land even quicker. If you're not flying, they don't have to worry about you, and they will appreciate that.

 

We get lots of clearances to a clearance limit, coming inbound from offshore, because once you clear the beach, you're basically nonradar, and very quickly NORDO, as far as ATC is concerned. Katrina and Rita took out most of the remotes in the Gulf, and the FAA still hasn't gotten around to fixing them. The oil companies had voice and data circuits back up within a few days, but there are still onshore VORs OTS, and everything offshore is still down. With a clearance limit, you have to play the game, but if we get a clearance to an airport or heliport, we don't hold.

[HH60Pilot]

Clearance limits were issued to ensure that the tower, without radar coverage, could exactly predict the time that a NORAD aircraft would be using the IAF and be able to prepare for it by delaying that aircraft until the clear the airways and approaches ahead empty.

 

Joker,

 

The brevity code for an aircraft without a radio is NORDO (NO RaDiO). The term NORAD stands for North American Aerospace Defence Command, which I used to be part of many, many moons ago.

 

Doug

[joker]

Doug,

 

Thanks! I guess i knew what NORAD stands for. I'll put it down to a combination of 1) typo, 2) mind on more important matters when typing.

 

In any case, the text is changed.

 

More importantly, I would rather know if people agree or found useful what I wrote.

 

On a personal note, I found the 'Cleared to ABC airport' somewhat confusing during my training. This was because I tried to apply 91.185(c ) to that clearance. However, there was always a 'niggle' in my mind that something didn't quite make sense.

 

It was only through some extensive research that I found the explanations I have put above. The whole 'IFR Comms Failure' system makes sense to me using this explanation. (That an clearance to an airport is simply a route clearance where the last fix is also your destination.) That is why I shared them here. Although I haven't found 'official sources' for all that I say, I am still in the 'reasearch' process so I can back up my explanation with official sources. It seems that the FAA and other references are reserved on this subject.

 

Joker

[HH60Pilot]

Joker,

 

It's been a few years since I've routinely flown IFR, but the way that I remember the rules are that if you are in holding along your route of flight and have been giving an EFC time and go NORDO while in holding, then you depart the holding at the EFC time and continue along your route of flight. When filing an IFR flight plan, the last point listed on the route of flight is the IAF for the approach that you are going to shoot and the ETE given is to that point. This is why ATC will expect you to commence your approach at that time. If you arrive at the IAF early, then enter published holding until the proper time and then commence your approach.

 

Doug

[Rob Lyman]

Joker,

 

It's been a few years since I've routinely flown IFR, but the way that I remember the rules are that if you are in holding along your route of flight and have been giving an EFC time and go NORDO while in holding, then you depart the holding at the EFC time and continue along your route of flight. When filing an IFR flight plan, the last point listed on the route of flight is the IAF for the approach that you are going to shoot and the ETE given is to that point. This is why ATC will expect you to commence your approach at that time. If you arrive at the IAF early, then enter published holding until the proper time and then commence your approach.

 

Doug

This is not always true or required. I would not put an IAF in my route of flight because I do not know what approach I have to shoot when I get there (ie the wind may change or a different active runway may be in use). Also, the ETE is to your destination, not to your last fix on your route segment (or IAF). The last point on your route segment could legally be 40 - 80 nm away on an airway.

 

I have been instrument rated in fixed wing and helicopters for awhile now, but got my CFII airplane just this past May. I still remember quite clearly the oral briefing where I had to explain along the entire route what we should do should we go NORDO at each segment along the way. When I gave the explanation above regarding 91.185 the examiner asked how I knew this. I admitted I had a tip she would ask and was ofered the "correct" answer by someone in my training. She then got on her soap box anyway and explained how she and the other Orlando FSDO FAA Check Pilots & DPEs had been asked to pass that along and that SHE personally had been asked to present this to the other examiners.

 

While this explanation still falls under the word-of-mouth category, it is the most official explanation I have encountered in my 21 years of flying.

 

BTW HH60Pilot, it looks like I'll be trading in my old wings of gold from the Navy for some wings of silver. from the Army National Guard. Bye bye Seahawk, hello Blackhawk.

[joker]

All,

 

Again, I agree with Rob.

 

1. Naming IAF as last fix in route section is not necessary, sometimes not wise. - The conditions might change while you are enroute. Then you go NORDO and now you are stuffed...you either have to break flight plan to get to a new IAF, or you force yourself into a 'circling approach while NORDO in IMC'. Also, sometimes you will file a STAR as your last 'thing'. Or it might be a Transition fix. You might be flying to an airport with no IAP (composite flight plan).

 

2. ETE is to the destination. - Although above I said it would work if your ETE was to your IAF and you were NORDO, I reiterate doing this is not strictly correct.

 

I think that these practices are common in US due to the hazy understanding of that 'AIRPORT-AIRPORT' clearance. (Don't get me started on the AIRPORT-DIRECT-AIRPORT flight plan!)

 

Anyway, there is so much training emphasis on 91.185 ©(3) that people try to apply that section (holding theories, ETA theories, IAFs as last fixes) to everything. People, forget 91.185©(3) if you are cleared to the airport.

 

 

Joker

[Gomer Pylot]

There isn't necessarily an IAF for your destination. For HOU, for instance, there is only one approach that has an IAF, and it's for an approach, to a runway, that is almost never used. I know, because once on a checkride the checkpilot told me I had to file to an IAF, for the purposes of the checkride. I finally found it, and he had done this to force me to fly that approach. This was in the sim, and that's the only way we could have flown that approach, because it is never used, especially in IMC. Being told to do it for a checkride by a checkpilot is the only time I would ever file an IAF. It's useful in nonradar, and we did it in the Army in the early 70s, but it's not done these days. I file to my destination, as directly as possible, and take whatever routing I get. In radar, I'm always cleared to an airport or heliport, never to a fix. The only time I ever get a clearance limit short of my destination is inbound to the beach from offshore, where I'll be non-radar, and center owns the offshore airspace and approach owns the airspace at the destination, and they can't coordinate a handoff until I'm approaching the beach. There are designated clearance limits for this, and we file them per LOAs.

 

If you're holding enroute and go NORDO while holding, then of course you hold until your EFC (which is why it's important to get an EFC), but that's about the only time I can think of off the top of my head when you would worry about a time. In radar, just land ASAP if you find VMC, or get to your destination and fly the approach that makes the most sense. If you can receive, you should get the approach in use from ATIS, and fly that.