lost comm clarification

[sqwkvfr]

sqwkvfr- You're both wrong. Here's an idea: read 91.185(C)(2).

Oh...and get a new instructor.

I should've been more specific...Example: you're flying on a route, in IMC. Your at 9000 (filed for and cleared to) on an eastbound course...You lose comms...you're in IMC...you come to a segment along your route (this has nothing to do with being cleared to a fix or the original question, BTW, sorry if I confused you) that has a 10K MEA. HE says fly at the MEA, I say fly at 11K.

What would it be?? 91.185(c)(2) says "minimum altitude for IFR operations."

It's gotta be one or the other....I really dont see how we'd both be wrong (if you'd like to expound on that statement, I'd be interested to hear it)....so which would it be?

 

[DrewBlows]

I should've been more specific...Example: you're flying on a route, in IMC. Your at 9000 (filed for and cleared to) on an eastbound course...You lose comms...you're in IMC...you come to a segment along your route (this has nothing to do with being cleared to a fix or the original question, BTW, sorry if I confused you) that has a 10K MEA. HE says fly at the MEA, I say fly at 11K.

What would it be?? 91.185(c)(2) says "minimum altitude for IFR operations."

It's gotta be one or the other....I really dont see how we'd both be wrong (if you'd like to expound on that statement, I'd be interested to hear it)....so which would it be?

Fly the highest of your assigned, expected, or minimum for your route. If you are lower than the MEA it is because you were assigned that altitude, so climb up to your filed altitude. (You did file an altitude above all MEA's didn't you?)

Note: The above statement doesn't apply when descending to the airport, you should descend using a normal profile (think coming down from FL310, it wouldn't work if you started your descent at the iaf). Make sure you observe the MSA and you will be fine. Throw it all out the window if you encounter VMC. If that's the case just find an airport and land.

 

[sqwkvfr]

(You did file an altitude above all MDA's didn't you?)

No, I didn't file above all --I hope you mean MEAs not MDAs-- MEAs....let's say for the sake of this discussion because I didn't wanna fly at the higher altitude for the entire route for O2/winds aloft/whatever reason.

In my example, I filed for an initial cruising altitude of 9k. ATC cleared me to 9K.

Now, if I'm in IMC, lost comms, and I come to a segment of the route with a 10K MEA, do I fly at the MEA on an eastbound heading or do I climb to 11K??

 

[HMR]

Lost comms: I've got a riddle grad instructor pilot telling me that you fly at the MEA no matter what the course in IMC.

91.185(C)(2): "Altitude. At the highest of the following altitudes or flight levels for the route segment being flown". 91.185(C)(2)(ii): "The minimum altitude for IFR operations". If the MEA is 10K and you're headed east I'd say your "route segment being flown" requires 11K. If the comms were working properly you'd be at 11K. You're making a bad situation (lost comms) worse by flying IMC at the wrong altitude for your direction of flight. I think your instructor is wrong.

I say, you fly at the lowest appropriate IFR altitude. (example: MEA is 10K and you're heading east...he says you fly at 10K I say that you fly at 11K)

I understand what you mean now that you clarified it in your other post and I agree.

 

[SSDD]

You guys are reading way too much into this and making it too complicated. The regs says to fly the "MEA", not the next higher altitude for the direction of flight. If the MEA is 9,300', or 10,300', then that's what you fly.

 

[HMR]

You guys are reading way too much into this and making it too complicated.

Wouldn't be the first time.

 

[sqwkvfr]

You guys are reading way too much into this and making it too complicated. The regs says to fly the "MEA", not the next higher altitude for the direction of flight. If the MEA is 9,300', or 10,300', then that's what you fly.

...and then what happens when you have a ATC comms failure or a stuck mike on frequency?? You could very well have two 7600s headed toward each other at the MEA.

This is exactly the problem that I've run into...I had a DE relate to me a story about an open mike in IMC near San Diego...which would put several aircraft in a lost comms situation. The FARs are NOT specific, the "instrument procedures handbook" isn't either.

I think it should be treated like JAFI said....when faced with a choice, do whatever's safer...and that would be flying at the appropriate minimum altitude for your course.

 

[Donsa320]

...and then what happens when you have a ATC comms failure or a stuck mike on frequency?? You could very well have two 7600s headed toward each other at the MEA.

This is exactly the problem that I've run into...I had a DE relate to me a story about an open mike in IMC near San Diego...which would put several aircraft in a lost comms situation. The FARs are NOT specific, the "instrument procedures handbook" isn't either.

I think it should be treated like JAFI said....when faced with a choice, do whatever's safer...and that would be flying at the appropriate minimum altitude for your course.

And, what makes you think there will be no one at 11,000 ft in your example above? I can guarantee you ATC will only be protecting the MEA and your original assigned altitude. You probably have some simplistic single route situation in mind but there can be diverging and converging airways and terminal routes as well as random vectors and GPS directs, etc, all going on above you. Your direction of flight has nothing to do with leaving the MEA to comply with the quadrangle separation. It is not provided for in the rule. Thankfully the transport category airplanes have TCAS to protect themselves from you. I pity the poor slobs around you that don't have TCAS!

~DC

 

[HMR]

Donsa- I'm not clear on what your answer to the situation is. What would you do? When anyone with 30,000+hrs(!) speaks, I'm all ears.

Please give the applicable references in the FAR's.

Thank You.

 

[HMR]

The regs says to fly the "MEA", not the next higher altitude for the direction of flight. If the MEA is 9,300', or 10,300', then that's what you fly.

The regs don't say to fly the "MEA". What if we lose comm when we're off-airway? 91.185(C)(2)(ii) says "The minimum altitude for IFR operations". Does that mean MEA, MVA, MSA, MORA, MOCA, cappuccino...?

If there's a loss of separation caused by a pilot flying the wrong altitude w/lost comm he better have a good reason for it when the Feds come a'knockin.

You have a lot more time in the air than I do. I appreciate your input.

 

[SSDD]

sqwkvfr,

You can play what if's all day long. What if you have five airplane converging on the same point at the appropriate IFR altitude? What if you have one NORDO airplane climbing and another descending? What if....?

 

[Donsa320]

Donsa- I'm not clear on what your answer to the situation is. What would you do? When anyone with 30,000+hrs(!) speaks, I'm all ears.

Please give the applicable references in the FAR's.

Thank You.

I thought I was rather clear in my original response. In lost communications if you cannot maintain VFR and land, then the only altitudes you are entitled to be at in IFR conditions are the one you were cleared to maintain, any higher altitude you were told to expect at a certain time if you are filed into the flight levels and any minimum enroute altitude that is higher than what you were cleared to maintain and then only for the route segment that requires it.
Nowhere is the direction of flight a consideration.
Those basic rules have not changed in the 53 years that I've had an instrument rating.
You can read the FARs for yourself but remember, the ATC guys do NOT know the FARs....they have their ATC Handbook which pilots, of course, never see.

I suggest that you have this discussion with several ATC Safety Reps. You will probably get a variety of answers there also.
From what I've found , they (ATC) will clear as much traffic out as they can and keep their fingers crossed. And it takes time.

BTW in all my hours I've only lost communications twice. Once in Korea and once in Norway. And that was long ago with tube radios.

~DC

 

[Fly_Chick]

A question came up during an IFR flight tonight. I asked my student what he would do if he lost comms. His reply was to

"continue the flight VFR, squawk 1200 and land as soon as practicable"

This was new to me as I always thought to squawk 7600. He pointed out to me the reg says "each pilot shall continue the flight under VFR and land as soon as practicable" and his interpretation was to squawk 1200 since he was under VFR.

I did not initially agree with this... then started thinking... you can still be VFR with a specific squawk code. 7600 is the code for VFR or IFR lost comms. Have others heard of squawking 1200 in lost comms (VFR or IFR)?

What are the other opinions on this?

 

[flytheblue]

I would squawk 7600 whether Im in VFR or IFR conditions or the flight was originally VFR or IFR. What if you are landing at a controlled airport? How are you going to let ATC know you are lost comm? (assuming that you dont have a total electrical failure of course).

 

[JAFI]

I see the transponder as a "Communication" device. You transmit a discrete code, altitude (if you have mode C) and the radar system calculates ground speed and your position. The 1200 code is universal for "normal" VFR. If you are VFR and talking to ATC, they will give you a specific code to identify you from all the other VFR (1200) traffic. If we throw in Lost Comms then stay with the 7600 (discrete code) to identify you as Lost Comm and something other than "normal" traffic.

Have your student understand that the code is not just a standard IFR - VFR code but a communication to ATC who you are and maybe what is happening to you....

JAFI