On 03/11/07 11:41, Ron Garret wrote:

[ snip ]


First, the regs explicitly sanction "making up your own stuff" (as you
put it) in emergency situations, which lost comm in IMC can easily give
rise to.

Well, *anything* can lead to an emergency situation. However, there are
regulations written specifically for the case of lost communications.
If you deem that lost communications is an emergency, and use that to
justify doing whatever you want, you're in violation of the regs.


Second, a lot of the regs were written before the advent of moving-map
GPS. Many procedures that make sense if you're navigating on a VOR make
less sense if you always know at a glance exactly where you are.

Third, going by the book makes you do some overtly stupid things. The
classic example is going NORDO while flying from AVX to FUL. Going by
the book requires you to fly to SLI, reverse course, return to the exact
spot you just came from (which is over water BTW), and reverse course
again.

I haven't looked at this particular approach, but I'll assume you're
referring to the fact that your clearance limit is the airport, and
that the regs require you to go to the clearance limit first?

First of all, this is what the regulations tell you to do, and this is
what you must do. Period. The fact that some controllers tell you that
they would rather you do something different is irrelevant. They will
not be defending you in a certificate action case.

Incidentally, when I file an IFR flight plan, I select a fix which I can
use to initiate my approach, and put a note in the remarks section which
states:

"In the event of lost communications, XYZ shall be treated as my
clearance limit."

This way, I don't have to do the back and forth - and it's legal (and
expected by ATC).

This procedure is manifestly more dangerous than just flying the
approach straight in (because it involves more maneuvering, more time in
the air, more time over water). Moreover, under normal conditions the
approach is ALWAYS flown straight in (via vectors) and under NORDO
conditions the controllers expect you to fly the approach straight in (I
know because I asked them) notwithstanding that this technically
violates the regs.

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.

Not really. According to the regs, you go to your clearance limit, then to
a point where you can begin your approach. Once you're on a published leg
of the approach, you fly it's altitudes. This means you can begin your
descent once you're on the IAP. If you need to hold at the fix to lose
altitude, you do that.


rg



--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA