"Jim Carter" wrote in message
. net...

Okay Steve, I didn't realize until just now that you are only talking
about enroute holds. I was applying your comments to all types of holds.
Will you agree that a hold at an initial approach fix will always
include and EFC time?


I'm talking about all holds in which no delay is expected. The example I
provided was an enroute hold but FAAO 7110.65 does not differentiate between
enroute holds where no delay is expected and holds at an IAF where no delay
is expected.