In article ,
Mark Hansen wrote:

I haven't looked at this particular approach, but I'll assume you're
referring to the fact that your clearance limit is the airport, and
that the regs require you to go to the clearance limit first?

Correct.

First of all, this is what the regulations tell you to do, and this is
what you must do. Period.

I'm not asking what is the required course of action. I am asking what
is the wisest course of action.

The fact that some controllers tell you that
they would rather you do something different is irrelevant. They will
not be defending you in a certificate action case.

Quite so, but keeping my ticket is not my only consideration. There is
also the safety of the flight to consider. Following the regs requires
more time in the air, more maneuvering, more fuel consumption, and
unnecessary traversal of extremely crowded airspace in IMC. All this
entails additional risk. If I'm faced with a choice of risking my
ticket or risking my safety I'll take the former.

Incidentally, when I file an IFR flight plan, I select a fix which I can
use to initiate my approach, and put a note in the remarks section which
states:

"In the event of lost communications, XYZ shall be treated as my
clearance limit."

This way, I don't have to do the back and forth - and it's legal (and
expected by ATC).

That seems like a sensible idea. I think I'll try that.

This procedure is manifestly more dangerous than just flying the
approach straight in (because it involves more maneuvering, more time in
the air, more time over water). Moreover, under normal conditions the
approach is ALWAYS flown straight in (via vectors) and under NORDO
conditions the controllers expect you to fly the approach straight in (I
know because I asked them) notwithstanding that this technically
violates the regs.

And fourth, the regs leave a lot of stuff unspecified. If you go by the
regs in the current situation, you end up over KVNY at 11,000 feet, at
which point you're supposed to initiate your descent. But there's no
published hold at KVNY (to say nothing of the fact that KVNY is not an
IAF for any approach to KVNY) so you have no choice but to improvise at
that point.

Not really. According to the regs, you go to your clearance limit, then to
a point where you can begin your approach. Once you're on a published leg
of the approach, you fly it's altitudes. This means you can begin your
descent once you're on the IAP. If you need to hold at the fix to lose
altitude, you do that.

And what if there is no published hold (as is the case in the current
situation)?

rg