Photon

I've been teaching a lot of instrument students during my days as a flight instructor, and at some point we always get to the lost coms scenario discussion.

Basically 91.185 gives you your procedures to follow (we're talking no VFR conditions in sight here) for route, altitude and when to leave clearance limit.

Now, by talking to a lot of different ATC controllers, most of them will tell me that if I would ever lose coms in IMC close to the departure airport, they would rather see me just return and land asap, than follow 91.185, but i digress.

Onto the matter at hand here (lost coms scenarios):

1. Your clearance limit is your destination airport, for some reason your ETA was out of wack, and you arrive over your clearance limit 20 minutes before your ETA time.
Now by 91.185, you should now proceed to a fix from where an approach begins, and then descent as close as possible to your ETA.
Would you agree that the regulations in this instance tell you to hold at the IAF for an approach for an additional 20 minutes?

2. Say you're a jet operating under part 91 (don't know if these rules are different in regards to 135/121), and your enroute altitude is FL 410, you lose coms early in the flight, with only that altitude assigned to you.
Are you expected to arrive over the clearance limit (your destination airport) at FL 410, and then descend in a holding pattern over the IAF or somesuch?


Would be awesome if anyone has any reference material for different lost coms scenarios, especially those in regards to clearance limit and descending for the approach/airport !

- Photon