snip

And fourth, the regs leave a lot of stuff unspecified. If you go by the
regs in the current situation, you end up over KVNY at 11,000 feet, at
which point you're supposed to initiate your descent. But there's no
published hold at KVNY (to say nothing of the fact that KVNY is not an
IAF for any approach to KVNY) so you have no choice but to improvise at
that point.

If you don't believe that if your clearance limit is the airport and
that you can pick any approach and IAF and execute it when lost coms,
then you can try this:

from "Instrument Flying Handbook"
FAA H 8083 15
page 10-11

http://www.faa.gov/library/manuals/a...-8083-15-2.pdf

"Holding Instructions
If you arrive at your clearance limit before receiving clearance
beyond the fix, ATC expects you to maintain the last assigned
altitude and begin holding in accordance with the depicted
holding pattern. If no holding pattern is depicted, you are
expected to begin holding in a standard holding pattern on
the course upon which you approached the fix. You should
immediately request further clearance."