Leaving the Clearance Limit (Lost Comms)
Lost Communications scenario in IFR conditions. We are already familiar with the Route and Altitude rules, so let's skip to the end.
Leaving the clearance limit. Based upon FAR 91.185, and without a lengthy citing of the FAR/AIM, here is what I believe to be a correct interpretation of the rule.
If you received an EFC time (this would also include holding instructions), hold until the EFC time, then proceed to the IAF and commence descent and approach as close as possible to your ETA.
If you did not receive an EFC, proceed to the IAF and commence descent and approach as close as possible to your ETA.
Here's where the answers tend to get muddy when asked about Lost Comms. The most common answer among pilots is, if you are early, you would hold until getting close to your ETA, then commence descent and approach close to the ETA. However, that doesn't make sense for a couple reasons.
1) As "close as possible to the ETA" definitely includes the possibility of being early
2) "Making up a hold" in no way assures obstruction clearance. The hold needs to be published for that to be garaunteed (or assigned by ATC)
3) It prolongs your NORDO flight in the National Airspace System, simply further complicating ATC's job of providing separation
So here's the question: Why does everyone say that, if early, they will hold?
It is understood that an EFC implies holding, and instructions would have been issued for that. But in the absence of an EFC, I see no logical explanation for holding at all, even if you are early.
Thoughts?