Steven P. McNicoll wrote:


Without an EFC I wouldn't enter the hold. It's a moot point anyway,
whatever caused my comm radios to go belly up will affect my nav radios the
same way and I won't be able to identify the holding fix.


Although that is certainly a likely result in a light aircraft, it may
not be in an aircraft with more sophisticated avionics busses.

91.185 is written with the premise that comm capability fails but nav
capability continues to exist.

Your scenerio is not a 91.185 situation; it's a major emergency if in IMC.