Scott wrote:

Can the approach be flown leagally by requesting alternate
missed approach instructions that don't require and ADF?


Now that's a great question. I suppose ATC can override anything really.

There is no situation where the plate says ADF required that GPS cannot
substitute. And yes ATC can come up with alternate missed instructions.


But then, what do you do in case of lost comm? You can't fly the
published missed.

Why not? Just go to the NDB and hold using the GPS. That's not even
difficult.