(Mike Ciholas) wrote in message om...
Depart BJC (Boulder, CO) for a flight to EVV (Evansville, IN). You
expect the flight to take 4:30. You depart at 1200Z. Once airborne,
you get established on a clearance route and you realize that the
tailwinds are much stronger than forecast. After 3 hours have passed,
you find the GPS saying EVV is only another 30 minutes enroute (thus
the flight now should take 3:30 instead of 4:30). You get the ATIS,
using ILS RWY 22, relatively low IMC conditions at EVV. ATC then
gives you a radar vector to bias your flight path north for the
approach. At this moment, you loose comms. All attempts to establish
comms are in vain. The weather is also low IMC in every direction.

My instructors answer was this: when lost comms is noticed and no
attemp to establish alternate comms works, then proceed to the outer
marker of the ILS22 approach (VICCI) and hold as diagrammed until your
flight planned expected arrival time, then shoot the approach. In
this particular case, this would be holding for about 1 hour due to
faster than expected tailwinds (you arrive an hour earlier than
planned).

My answer was this: vector yourself around to the final approach
course of ILS22 about 1-2 miles outside VICCI and directly shoot the
approach with no holding. My thinking was to do what I expected the
controller to do if I had comms and to get on the ground in the
simplest and most direct way possible.

I think you're both wrong , but you're more right than your
instructor.

Your instructor's answer is correct according to 91.185, but
that doesn't mean it is what you have to do. 91.3 authorizes
you to deviate from "any rule of this part" to the extent necessary
to meet an emergency.

IOW, it is totally "by the book" to use your best judgement to
minimize the potential impact of the situation first on yourself
and your aircraft, then on the NAS.

That might actually lead to a third answer neither of you gave
(see below).

I thought that was silly and said that if presented with the above
situation, I would disregard the book in favor of what I perceived to
be the best response to the situation, namely get on the ground in the
simplest and most straightforward way so I don't clog up airspace as a
no comm airplane. I also was not going to do holds for an hour, in
IMC, with some sort of failure which may grow to encompass more than
the radios. I also did not believe the "book" says to do this.

YOu are entirely correct with the latter part of your answer. If
I lose both comms, which have in common only the plane's electrical
system, I am not going to make the assumption that everything else
in the plane is just ducky. I am going to treat the situation as
an emergency and consider myself authorized to use my best judgement
to meet it under 91.3. I don't know what's going wrong and it's
my business to get my plane on the ground and troubleshoot there.
FWIW, "lost comm" is listed in the controller's handbook 7110.65
under "emergency procedures". I don't believe anyone will argue
with your decision to treat the situation as an emergency and
exercise emergency authority.

However, I don't think it's necessarily the best thing to play
ATC and "vector yourself". Even in flatlands, there are often
radio towers and MVAs can vary steeply with position. Other
things being equal, I think it would be best to adhere to "the
book" 91.175 which says basically thou shalt start an approach
two ways: 1) via radar vectors to the FAC
2) from the IAF, via the full approach procedure

In a potentially deteriorating situation, I don't want to be
"betting my life" on my awareness of every obstacle and my exact
knowledge of my position. I think in general, it's easier and safer
to follow the "chain of beads" developed by TERPS people who had all
the time they wanted to scrutinize terrain and obstacles in the area
and develop procedures to avoid them.

I don't say "that's what you should do" prescriptively, because
it's clearly not always the safest most sensible thing to do. If you're
pointed at the FAC at a 90 degree angle and you're pretty confident
of the terrain and your position, it seems sensible to just turn
to a 30 degree intercept if that'll be outside the marker and
go on in. Ditto if you're able to intercept the FAC outside the
marker and below the glideslope. OTOH, if you're being vectored
on downwind, I'd be mighty leary of "doityerself vectors". At our
home airport in the flatlands, there's an area of 2100 ft towers
just a bit to the east of the area where ATC vectors aircraft for
approach at 2000 ft. The towers don't show on the typical handheld
or panel GPS; if ATC had the game plan to swing you wide around them
for traffic or to turn you in before you got there, but you weren't
"in" on the plan and didn't notice them on your VFR sectional
in the furball or didn't turn quite soon enough -- Oh, Well.

Last point. Low IMC all around. Where's the nearest weather
where you could land VFR? If you're flying a plane without
redundant electrical systems, and the answer is "I don't know"
or "I don't have fuel to get there, even at maximum range airspeed"
IMHO your flight planning needed catsup. And btw, a number of twins
with two generators or alternators still have single-point failure
scenarios in the electrical system.

In a plane equipped with two comms and two antennae, I think the
most likely reason to lose both is that the electrical system is
going.

If you have any reason to suspect a flaky electrical system, the
safest thing to do may be to head to a locale where you can land
under VFR, perhaps after a low-precision cloudbreak maneuver,
rather than to commence a demanding precision approach with
course guidance which may leave you at any time. Of course (pun
intended) if you have a handheld GPS set up to provide backup, you
might want to try it, proceding below LOC minima only if you're
happy and stabilized and everything adds up (descent rate for the
glideslope consistant w/ groundspeed etc). But ask yourself
these two questions first: 1) where is the nearest VMC?
2) can I get there?
and bear the answers in mind at all times.

Some of the saddest accidents I've heard about are those where
someone arrives somewhere in low IMC, shoots multiple approaches
unsuccessfully, maybe diverts elsewhere which is also low and
shoots multiple approaches. The reasons vary: maybe the wx was
too low, maybe the pilot's skill wasn't up to the challenge,
maybe there were equipment problems in the plane. Whatever the
reason, these are IMO accidents which should never have happened,
because the pilot should have known the answer to question 1) and
broken it off while the answer to 2) was still 'yes'.

My answer could also be technically wrong since I didn't fly to the
IAF and perform the procedure turn. But terrain avoidance is not a
big issue in EVV

Cumulo granite is not an issue but cumulo steel might be.

In fact, in any lost comm situation, I doubt I
would hold for any reason.

I think that might be going too far. It might benefit you to
fly a full procedure, including a holding pattern to lose altitude
if necessary. It might also benefit you to hold for a bit with
nice long legs, while you troubleshoot a bit and decide whether you
want to attempt a precision approach vs. head elsewhere.

My thinking about ATC response is that
they cannot assume any behavior of a lost comm aircraft, there could
be more wrong than just the lost comms (such as the pilot is
incapacitated and a passenger is flying, thus no behavior is
predictable). So I would think they would vector everyone else away
and hope the plane gets on the ground as soon as possible.

Given radar contact, I think you're correct. I don't think ATC
will be expecting a NORDO plane to hold for an hour until its ETA;
I know they will be hoping you land ASAP. Do keep in mind though
in the boonies, there are still plenty of approaches which are
done under non-radar procedures and sometimes NORAC (no radio contact)
once the plane commences the approach. I didn't go into that above
because your scenario specified radar approach control, but I've been
#3 of 4 for an approach to an obscure little rural airport and
clearly if #4 lost radios and decided to head for the FAC and go
on in while I was on the approach, it could be a Bad Thing.

Probably more answer than you wanted?
Sydney