I'm training for my CFII and had the same conversation with my instructor
over a similar situation.
In your scenario, the "hold for an hour" consideration is baloney. The
reg's state that you should commence the approach as soon as possible to
your "filed or amended (with ATC) estimated time en route." I would argue
that if the controller is giving you vectors for the approach, he knows
you're early. I would argue that this is essentually an ETA amendment for
all practical purposes, and therefore in alignment with 91.185.
The deal is this: unless you loose comms early on in the flight and no radar
services are available, they'll see you on radar and will provide separation
accordingly. If you lost your transponder as well, you've likely
experienced total electrical failure, and now 91.3(b) applies, meaning get
on the ground.
Don't circle over Evansville for an hour NORDO, they might shoot you down.
"Mike Ciholas" wrote in message
m...
I had a "discussion" with my instructor about lost comms in IMC after
a radar vector. To illustrate, consider this scenario (gratuitously
enhanced with specifics):
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.
What do you do?
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.
My instructor justified his answers based on the regs and while he
admitted his solution would effectively close an airport for an hour
with a no comm airplane circling on the ILS, he claimed it was "by the
book" and that's what you have to do.
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.
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 (unlike BJC!), so I would feel comfortable lining up
directly for the approach.
This is really an academic question because I pretty much doubt anyone
would convince me anything other than landing at my earliest and
safest opportunity would be the right course of action, rules or no
rules to the contrary. In fact, in any lost comm situation, I doubt I
would hold for any reason. 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.
Curious what the group reg gurus and ATC types think about this.
--
Mike Ciholas (812) 476-2721 x101
CIHOLAS Enterprises (812) 476-2881 fax
255 S. Garvin St, Suite B
Evansville, IN 47713 http://www.ciholas.com