I didn't mean to imply that we had a show of hands at the controller's
conference. Many controllers have confided to me in e-mails and private
conversations that while no one can say that Don is wrong in his by-the-book
approach (how could he be?), there are work-arounds that make things easier
for them.

I can't cite chapter and verse, but the FAA considers lost comms to be an
emergency, and no one second-guesses a pilot who says s/he has/had an
emergency.

Re flying in the flight levels, how did fuel enter into the discussion? I
readily acknowledge that military aircraft do not have inflight phones....my
experience is with corporate jets and turboprops.

Bob Gardner

"Jim Baker" wrote in message
...
Bob....Your first paragraph is maybe not puerile, but certainly
nonsensical. If the controllers at these annual meetings are unanimous,
which I think is hyperbole merely to make your point, then how could Don
disagree since, as you say, he is attending as a controller? You say his
opinions are not shared by all his compatriots, but some do?
Hmmmmm...where's the unanimity in that? I'm merely poking at you here
Bob, no offense. I agree it's important to have a NORDO aircraft on the
ground as soon as possible, but that doesn't mean at any cost. I contend,
the entire DoD flying community contends, and the official guidance of the
FAA contends that ASAP doesn't mean at any cost disregarding established
procedure. I don't see how a responsible pilot can ignore procedure when
there is no emergency. It's bad judgment.

I find your second paragraph about not all of his compatriots sharing
Don's "by the book" approach to be disheartening and dangerous. It
dismays me that we stress, as instructors, procedure tempered with
judgment to our students as the way to safely fly aircraft and yet there's
outright advocacy for disregarding procedure by some pilots and
controllers when there's no emergency. To disregard procedure with no
"good" reason to do so other than convenience is, to me, bad judgment on
the pilots part because it endangers others lives. If your point about
sterilized airspace is correct and there's no danger, fine, but then what
do you teach pilots about other procedures? If a group of pilots and
controllers, but not all of us, agree a procedure can be safely ignored,
it's bogus, then those pilots can pick and choose when to ignore it based
on their reading of the non-emergency scenario? If these controllers and
pilots are so sure that this situation can be handled in another way,
safely, then why don't some of them try to get things changed to reflect
their vision of reality and practicality? Change the procedure. I
support that.

I have to disagree with your changing procedure because you're flying in
the flight levels. I've flown up there since 1973 and I've always had the
fuel to fly the planned route to my destination. None of the jets I flew
had an air-ground phone (B-52, B-1B and B-727).

Best regards,

Jim


"Bob Gardner" wrote in message
news
I attend the controller's "Communicating for Safety" conference each year,
so I talk to a lot of controllers from around the country. They are
unanimous in saying that their primary interest is in getting the NORDO
aircraft on the ground as soon as possible.

I see Don Brown at these meetings, as well, and we have some interesting
conversations. Don is not a pilot, as most of us know, and his "by the
book" approach is not shared by all of his compatriots.

If I were to lose comms in IFR I would fly airways to my destination,
using MEAs all the way, and shoot an approach at the other end (that's a
good argument for filing airways and then asking for "direct" on first
contact with Center). Having flown jets in the flight levels, I would not
follow the same procedure because of fuel considerations...I would stay
high until a moderate descent rate would get me to an IAF at the
appropriate altitude. However, every jet I have ever been in has had an
air-ground telephone and I suspect it would be used if VHF comms were
lost.

Your contention that ATC might somehow forget to sterilize the airspace
is puerile. If they don't apply the sterilization until after they have
confirmed that comms have been lost, how could they forget?

Bob Gardner



"Jim Baker" wrote in message
...
I'm not sure what you mean by your comments Bob. Do you mean that they
said fly to your destination "AS PLANNED", what Brown says in his
articles, or fly to the destination that you're enroute to and let down
enroute and land? Don't know for sure, but I'm guessing you mean that
the controllers were urging the later. I sure diagree with following
that advice. Of course we're talking about NORDO in IMC, an extremely
unlikely event, but worth, of course, the discussion. How any pilot
could follow that advice is beyond me. Who here is willing to bet that
the controller(s) is/are sterilizing the airspace and not expecting you
to follow procedure? Who here is willing to bet they won't hit another
aircraft? Who here is willing to bet that a supervisor or a grouchy
controller isn't going to file against them for violating the regs? At
the hearing, who here thinks all those controllers that we hear about
urging us to violate the regs in this unlikely occurrence are going to
show up in defense of the pilot who violated a regulation and put an
airliner at risk, at least in somebodys mind?

In answer to Dave, in a general sense not using an IAP for any
particular airport, I'd rely on the weather forcast I got on departure,
updated weather if I had it, and pick an approach for the appropriate
runway. If there's a holding pattern depicted for the rwy IAP, enter at
the altitude you've chosen consistent with NORDO procedures and descend
in that holding pattern to make good the time described for NORDO
procedures in the AIM. (Pretty general here since I don't have an AIM in
front of me). If there's no holding pattern depicted, I'd fly to the IAF
at the altitude I had picked (see above) and set up a standard holding
pattern and descent in that pattern to make good the time at the airport
or the IAF. Will this inconveniece people? Maybe. But the
alternative, again in this unlikely scenario, is potentially so unsafe
that I wonder why anyone would even consider it.

Jim


"Bob Gardner" wrote in message
...
Conventional wisdom, according to every controller I have ever
discussed this with, is to forget about the regs, fly to the
destination as planned and shoot an approach. Their reasoning is that
once you are identified as NORDO, either by transponder or by failing
to communicate, they will sterilize the airspace around the destination
until you are on the ground. They do not want to keep other planes
hanging while you comply with the regs.

You will not find this in writing in any official pub.

Bob Gardner

wrote in message
oups.com...

I was just reading Don Brown's latest (6/22) on avweb:
http://www.avweb.com/news/columns/189944-1.html

This column is about NORDO IFR procedures. I like Don's columns and
find their nitpickiness to be consistent with safe flying, if a little
bit annoying.

But in this column, two things stuck out at me as odd.

First:

Flight plan was: HKY..BZM.V20.SUG.V185.SOT.V136.VXV..TYS
VXV is an IAF for TYS.

Don's interpretation of the AIM is that since the pilot was almost
certainly cleared to TYS, then that's his clearance limit. The regs
say
fly to your clearance limit, and initiate your approach at the ETA.
That means a pilot would fly to VXV (his IAF), fly to the airport
(?!),
fly back to VXV, then do full approach.

It seems a tad ridiculous, no?


Second:

Descent. We all know the rules about staying at the highest of our
last clearance, the MEA, or an altitude given in an EFC. If we filed
for 15000 and the airport is at, say, sea level, there's a lot of
altitude to lose. When and where is the right time to do this? I'm
embarassed to say I never really thought about it much before.
Usually,
controllers descend us gradually. Or if we're VFR we descend ourselves
gradually. But the rules make it clear you're to keep the altitude up
until ... when? When you start the approach? Come down in a hold?
where?

He bring's this up also questioning this, and mentioning the AIM
paragraph that says these proecedures don't always fit; use your own
judgement, etc.

Still, I'd like to know what I was going to do in this situation. What
would you do?

-- dave j
-- jacobowitz73 --at-- yahoo --dot-- com