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Old 02-11-2011, 01:30 PM
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Default Two questions about Lost Comm procs

Hi guys, was wondering if you could help me out with a couple of questions I have regarding the infamous issue of Loss Communications procedures.

1. Firstly, tell me if this is correct. The diagram says that if ATC assigned you 4000, you must climb higher if the MEA goes above 4000 (e.g. 6000). But after passing the route segment where the MEA is 6000, the MEA goes down to 4400. According to procedures, must you really leave 6000 for 4400 when in IMC in this case?



IFR Communications Failure Procedures

2. Also say that you are flying a jet and filed for 35,000 feet for a 2000nm trip across flat terrain (low MEA). But because you lost comm in IMC (and it is IMC all the way along your route) and were expected to climb only to 10000 after 10 minutes, does that mean that you are just gonna have to stay at 10000 until you are out of IMC or regain radio contact? And if you remain at 10000 feet you will burn too much fuel to reach your destination.. what should you do?

My feeling is that for my first question, the answer is just "Yes" although it seems funny to climb and descend along the MEA (which is likely there due to terrain). And for my second question, I guess ATC would never assign you an "expect altitude X after 10 minutes" if that altitude isn't anywhere near your flight planned altitude.



Thanks guys, appreciate your time!
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Old 02-11-2011, 03:17 PM
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Trying not to be obvious, but a quick review of the basics follows. If it's clear out (VFR) then land somewhere. Can't do that in this case. So IMC choose the highest of-

1. MEA. Not all that high in your hypothetical example (4-6000ft).
2. Expected altitude, which in this case is 30,000ft.
3. Assigned altitude (10,000ft)-> but this is superceded by the Expected altitude (30000ft).
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Old 02-11-2011, 05:41 PM
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Regarding question one, you do not descend to follow the MEA. You climb as needed so as not to ever be below MEA, but then you just stay there, even if the MEA drops down. You would descend only as needed to execute your arrival.

If you are going to run out of gas, exercise emergency PIC authority and climb. Believe me, ATC will be keeping EVERYONE out of your way but they depend on your following your expected routing. They are not stupid and know darn well that a a jet is not doing a transcon at 4000 or 10,000'. Maybe do a slow climb so they have time to react just in case.

You could exercise PIC authority and divert to a closer airport, but that would leave ATC guessing. Like I said, they will have cleared out traffic on your known route so best stick to that if possible.
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Old 02-11-2011, 09:03 PM
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Originally Posted by Cubdriver View Post
Trying not to be obvious, but a quick review of the basics follows. If it's clear out (VFR) then land somewhere. Can't do that in this case. So IMC choose the highest of-

1. MEA. Not all that high in your hypothetical example (4-6000ft).
2. Expected altitude, which in this case is 30,000ft.
3. Assigned altitude (10,000ft)-> but this is superceded by the Expected altitude (30000ft).
I think you grouped the altitudes given by mikearuba into a single answer that doesn't completely answer either of the questions independently. Answer #1 for the (4-6000ft) MEA applies to the first question he asked.

Your answers #2 and #3 reference the altitude examples that mikearuba gives in his question #2. If you re-read question #2, you will see that for his example, the altitude to expect was given as 10,000. He does not give us information about the altitude that is assigned by ATC.

How you reason that FL300 is the "expected" altitude is puzzling to me. mikearuba says the flight plan was filed for FL350, but that would make it a filed altitude, not an expected altitude.
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Old 02-11-2011, 09:55 PM
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Originally Posted by rickair7777 View Post
Regarding question one, you do not descend to follow the MEA. You climb as needed so as not to ever be below MEA, but then you just stay there, even if the MEA drops down.

If you are going to run out of gas, exercise emergency PIC authority and climb.
I disagree. The text of 91.185(c)(2) specifically mentions "the highest of the following altitudes or flight levels for the route segment being flown.

So in my opinion, yes you do descend to follow the MEA where appropriate. If you climb to comply with a rising MEA, you don't just stay at that altitude for the next route segment, if the MEA drops down. In mikearuba's example, the last assigned altitude was 4000 and there is no expected altitude information given. The MEA rises to 6000 in the next route segment, and then falls to 4400 beyond that. Once on the route segment where the MEA drops to 4400, according to the regulation, yes you should descend to follow the MEA because it is still higher than the assigned altitude.

Regardless of the wording of the regulation, I hope that mikearuba understands that as professional aviators we would each handle this situation differently. Fly over the Green Mountians of Vermont at the MEA, in IMC, (during the winter months)? No thank you. Hopefully for someone who experiences two-way radio communications failure in a similar situation, they recognize it as a potential in-flight emergency. Then emergency PIC authority comes into play. Want to climb to a higher altitude? Your call. Want to stay at 6000 even though the MEA goes down to 4400? Make it so.

We play by the rules the majority of the time and to the best of our abilities. But in an emergency situation, from 91.3(b) "...the pilot in comand may deviate from any rule of this part to the extent required to meet that emergency." Take 91.185 and toss it out the window!
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Old 02-11-2011, 10:42 PM
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Originally Posted by trent890 View Post
How you reason that FL300 is the "expected" altitude is puzzling to me. mikearuba says the flight plan was filed for FL350, but that would make it a filed altitude, not an expected altitude.

Ya, I'm a bit confused, too.

Many of these types of questions have two answers. The answer you give at type rides / interviews / etc., and what you'd really do.

Did the clearance issued by ground / clearance delivery / FSS / Center, or whoever actually issued the initial clearance, say anything like, "climb to 10,000, expect FL350 ten minutes after departure"?
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Old 02-11-2011, 11:36 PM
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Originally Posted by trent890 View Post
I disagree. The text of 91.185(c)(2) specifically mentions "the highest of the following altitudes or flight levels for the route segment being flown.


Regardless of the wording of the regulation, I hope that mikearuba understands that as professional aviators we would each handle this situation differently....But in an emergency situation, from 91.3(b) "...the pilot in comand may deviate from any rule of this part to the extent required to meet that emergency." Take 91.185 and toss it out the window!
I think that's the most important point I took from this... that's definitely the discretionary power that keeps pilots out of trouble!


Originally Posted by TonyWilliams View Post
Did the clearance issued by ground / clearance delivery / FSS / Center, or whoever actually issued the initial clearance, say anything like, "climb to 10,000, expect FL350 ten minutes after departure"?

Hi Tony, it's only a theoretical question assuming that ATC said "Citation jet.... climb to 5000, expect 10,000 ten mins after dep"
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Old 02-12-2011, 04:35 AM
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30000 was a typo, I meant 35000 or FL350. In this situation he has a normal clearance to fall back on with an expected altitude of FL350 for the cruise portion of the flight. I find the variation in responses from seasoned pilots on this thread interesting. I am not seasoned in IFR flight, but this kind of question is always asked at flight schools as though there is one right answer only. In real life the right answer is not always so easy and experience is what determines the solution.

Last edited by Cubdriver; 02-12-2011 at 05:22 AM. Reason: too early
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Old 02-12-2011, 10:27 AM
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Originally Posted by trent890 View Post
I disagree. The text of 91.185(c)(2) specifically mentions "the highest of the following altitudes or flight levels for the route segment being flown.

So in my opinion, yes you do descend to follow the MEA where appropriate. If you climb to comply with a rising MEA, you don't just stay at that altitude for the next route segment, if the MEA drops down. In mikearuba's example, the last assigned altitude was 4000 and there is no expected altitude information given. The MEA rises to 6000 in the next route segment, and then falls to 4400 beyond that. Once on the route segment where the MEA drops to 4400, according to the regulation, yes you should descend to follow the MEA because it is still higher than the assigned altitude.

Regardless of the wording of the regulation, I hope that mikearuba understands that as professional aviators we would each handle this situation differently. Fly over the Green Mountians of Vermont at the MEA, in IMC, (during the winter months)? No thank you. Hopefully for someone who experiences two-way radio communications failure in a similar situation, they recognize it as a potential in-flight emergency. Then emergency PIC authority comes into play. Want to climb to a higher altitude? Your call. Want to stay at 6000 even though the MEA goes down to 4400? Make it so.

We play by the rules the majority of the time and to the best of our abilities. But in an emergency situation, from 91.3(b) "...the pilot in comand may deviate from any rule of this part to the extent required to meet that emergency." Take 91.185 and toss it out the window!
This is probably technically correct, but I would still probably stay high to save fuel (unless I NEEDED to burn fuel). ATC will not mind if you stay high either.

Since this whole reg addresses an emergency in the first place, it is basically just a suggestion for the PIC.
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Old 02-16-2011, 12:41 AM
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Hi, it all resumes to the flight rules you are flying.

VMC - Land as soon as possible and contact ATC to inform the time and place you landed;
IMC - Must sqawk 7600 and follow filled flight plan until destination and perform the comm fail app procedure. Forget to follow MEA.

Best regards.
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