Andrey Serbinenko wrote:
I would wait until 10 min to climb to 4000, and climb initially only to

I have two doubts about that:

First, it seems to contradict item iii of the following reg:
FAR Sec. 91.185 - IFR operations: Two-way radio communications failure.
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(2) Altitude. At the highest of the following altitudes or flight levels for the route segment being flown:

(i) The altitude or flight level assigned in the last ATC clearance received;

(ii) The minimum altitude (converted, if appropriate, to minimum flight level as prescribed in .91.121(c)) for IFR operations; or

(iii) The altitude or flight level ATC has advised may be expected in a further clearance.
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It lists "expected" along with everything else, and doesn't mention anywhere
that you should wait for the EFC time to pass before using it.

Secondly, while being radar-vectored I have never had to wait for ten minutes:
three-four minutes maximum, which makes me think that staying low for that
long may not in fact be desirable. In particular, staying at 2000 feet while
maneuvering in southerly direction for too long can put me in close proximity
to TEB ILS rw 6 approach path.


I should mention that I am in Canada and the IFR regs are more or less
the same, but in the Canadian AIM there is an explicit statement in
reference to altitude in a comm failure situation: "the altitude or FL
that ATC has advised may be expected in a further clearance (the pilot
shall commence climb to this altitude/FL at the time/point specified by
ATC to expect further clearance/altitude change)."

The way you quoted the FAR above it certainly implies that you should
start climbing right away. This is a significant difference in the
lost comm procedures between Can/US.

John