Hold "as published"?

"Richard Thomas" wrote in message
...

Hi Steven,


Howzit goin'?



I wouldn't like to be on your aeroplane if you're not going to hold
anywhere
if you're 30 minutes early arriving at your destination with lost comms
etc... :-)


Why not?



If you are in IMC and loose communication then one should start any
available instrument approach into the destination airport at the ETA
within
the filed flight plan (ETD + Time Enroute). If you're early and its solid
IMC you hold. Simple as that.

The reason for this is Air Traffic is expecting you to arrive at the
airport
at that ETA so they will have cleared the airspace in its entirity,
expecting you to start any published instrument approach into the airport.
This is particularly relevant if your transponder has also failed... how
are Air Traffic supposed to know where you are?


I see a couple of problems with that. First, it's unlikely ATC has your
ETA. They'd only have it if you were cleared as filed and there had been no
route amendments since you departed. That's rarely the case.

Second, what bizarre failure causes me to lose both of my completely
independent transceivers, and my transponder, but leaves me fully confident
of the continued flawless operation of my other avionics?



If you arrive, lets say 30 minutes ahead of schedule, you have no comms
and
as its your very unlucky day your transponder has decided to go
unservicable. ATC have no idea where you are but as they will be
following
the FARs they'll be clearing the area for your planned ETA. If you are
now
30 minutes ahead of schedule (great tailwind) then they may still be
clearing the approaches... if you then start an ILS approach in solid
IMC,
there could be a possibility of ploughing straight into another aircraft
that they are getting onto the ground in anticipation of your arrival 30
minutes later...


So if I arrive 30 minutes early I should hold while arrival and departure
traffic fly through my holding pattern?

I'm familiar with what the FARs and the AIM say. What I say comes from 20
years experience as an air traffic controller, Center, TRACON, and tower.
You can believe what I tell you, or you can believe your fantasies, I don't
care which.