I was just taking a look at flying KSMO-KSAN. All the TEC routes end at MZB, but let's say I'm flying a slow piston. For reference, the route is SMO SMO125R V64 V363 DANAH V23 MZB. (SkyVector link)
(Assume KSAN is landing west and is IMC down to minimums, and my aircraft is /A.)
I imagine that I'd ordinarily get radar vectors from somewhere north of MZB. However, that got me thinking about what I'd do if I lost comms, let's say somewhere near OCN. I'd fly to MZB as the last fix on my route, but then what?
Given the conditions, the only approach I could possibly shoot into KSAN is the LOC RWY 27, but it doesn't look like there's any published way to get from MZB to an initial approach fix. There's an airway, V66, between MZB and RYAHH, but the plate specifically says, "Procedure NA for arrivals at RYAHH on V66 eastbound."
What would we do in this case? My guess would be this:
Referring to the MSA circle for a safe altitude, follow the MZB-084 radial to DOUGA at or above 5400.
Turn left heading 017 to join the PGY-017 radial outbound and follow it to RYAHH at or above 5400.
Execute a procedure turn west of RYAHH to reverse course and join the PGY-017 radial inbound.
My impression on lost communications is that if you ask ten different pilots what you would do, you'll get eleven opinions. If it happens in IMC, it's basically an emergency, so do whatever you need to do to get back onto the ground.
I think that your plan sounds reasonable. I also think that it is fine in that situation to climb up to the minimum safe altitude until over a published segment of the approach, and then fly it. There's no need to swirl around so much when an expeditious landing is most likely preferable.
I'm not a CFII, but am instrument rated, so I'll do my best to answer, but will gladly stand corrected if I've misstated any of this.
The FARs, specifically 91.185, leave little confusion on how to proceed in IFR with lost comms. First, if KSAN is IMC and down to minimums as you said, but you happen to be in VMC at your altitude on V23, stay in VMC and land somewhere else if possible. If you are in IMC then proceed as follows: squawk 7600 and then plan your altitude. On the airway, fly the highest of either the MEA, your assigned altitude or your expected altitude if it was given. Then for your route, follow in this order of priority: either your assigned route, a vector if given, your expected route, or your filed route. In your case, your assigned route has priority and has the clearance limit of KSAN. (Your clearance limit is not MZB) So, you are expected to go to KSAN directly from MZB. Sounds weird, but that's the route you were assigned and according to the FARs that is where you are expected to go. The FARs don't explain how you will get there off airway and as a /A. Once you're over KSAN at altitude then what, and how do you land there if it is IMC? According to the FARs, you need to decide if the clearance limit, KSAN, is a fix at which an approach begins. Of course not, no airport is a fix from which an approach begins, so according to the FARs you need to immediately proceed to a fix from which an approach begins after reaching KSAN. If you want to shoot the LOC Rwy 27, you have two choices: RYAHH or LYNDI. Since you're /A you only have RYAHH. Again, you'll be navigating there off airway and without GPS, so like you said, use the MZB MSA circle for the area you are in which is 5400 and then find your way to RYAHH. Your description of following the MZB-084 radial to DOUGA and out to RYAHH makes good sense, but you can get to RYAHH any best way you can, including going from MZB directly to RYAHH along V66. Remember, lost comms under IMC is an emergency, so I wouldn't worry about the fine print that the procedure is NA for arrivals on V66 eastbound. I'd rather do that than an uncharted procedure turn near the hills. Either way you choose to get to RYAHH and turned inbound, obviously then proceed down the approach descending at the listed altitudes for each leg. The FARs say to commence the approach from the IAF as close as possible to your ETA, but my understanding is that ATC would rather have you down ASAP and not be holding out there trying to time it while they reroute traffic around you. I personally wouldn't wait around in a hold - I'd get down ASAP with lost comms in IMC. Again, it's an emergency. You automatically have priority.
The FARs, specifically 91.185, leave little confusion on how to proceed in IFR with lost comms.
*twitches slightly*
You really think so?
The only time the tail end makes any sense is if you're graced with a navaid based at the field, in which case you can shoot the approach from there. Other than that, it's fairly ugly and more to the point and in cases where there is no IAF at the field, you should technically head to the airport first, then go to the IAF, even if you're cleared route of flight overflies an IAF. That's patently insane, especially /A where you have no mechanism to go direct to the airport after the last fix. There is zero chance I would do that in the airplane in real life. I would use emergency authority and fly to an IAF or feeder, with terrain and obstacle separation being absolutely guaranteed by MEAs the entire time and then if questioned as to the nature of the emergency, I'd say, "because the regulations make ZERO sense."
Just google "lost comms clearance limit" and see the hundreds of hits with massive discussions full of confused people. There's a GREAT post from _2009_ on the POA forum: http://www.pilotsofamerica.com/forum/sh ... hp?t=29460 where AFS states they're considering changing the AIM to clarify that you would NOT go to the airport if you were /A and then the IAF, but would instead go straight to the IAF from the last fix. This, sadly, never happened. 7 years later, the AIM basically reads the same.
I'm going to commit and say I was thinking just like Rod. Nicely written.
To add, if KSAN was IMC at filing I'd have picked a nice VFR alternate (or as a weekly GA pilot stayed home if none was available) and I'd be thinking hard about going there. If I was overhead KSAN at say 5000 and wx was turbulent IMC, at ETA I might just head to my alternate. Radio failure followed by electrical failure followed by... And a bouncy non-precision IMC approach to KSAN at mins in my Cherokee Archer just doesn't sound like fun. Wish I had an SR22...
The one thing that is annoying from a lost comms perspective is that you get saddled with TEC routes that serve an AREA, not an airport (this is true in the NE, too), and often terminate in a fix that is NOT an IAF or feeder. Getting to an IAF or feeder can be a challenge (such as the SAN example).
The FARs, specifically 91.185, leave little confusion on how to proceed in IFR with lost comms.
*twitches slightly*
You really think so?
The only time the tail end makes any sense is if you're graced with a navaid based at the field, in which case you can shoot the approach from there. Other than that, it's fairly ugly and more to the point, you should technically head to the airport first, then go to the IAF, even if you're cleared route of flight overflies an IAF. That's patently insane. There is zero chance I would do that in the airplane in real life. I would use emergency authority and fly it from an IAF or feeder, with terrain and obstacle separation being absolutely guaranteed by MEAs the entire time and then if questioned as to the nature of the emergency, I'd say, "because the regulations make ZERO sense."
Just google "lost comms clearance limit" and see the hundreds of hits with massive discussions full of confused people. There's a GREAT post from _2009_ on the POA forum: http://www.pilotsofamerica.com/forum/sh ... hp?t=29460 where AFS states they're considering changing the AIM to clarify that you would NOT go to the airport if you were /A and then the IAF, but would instead go straight to the IAF from the last fix. This, sadly, never happened. 7 years later, the AIM basically reads the same.
Agreed. See also this section of the AIM:
6-4-1. Two-way Radio Communications Failure
a. It is virtually impossible to provide regulations and procedures applicable to all possible situations associated with two-way radio communications failure. During two-way radio communications failure, when confronted by a situation not covered in the regulation, pilots are expected to exercise good judgment in whatever action they elect to take. Should the situation so dictate they should not be reluctant to use the emergency action contained in 14 CFR Section 91.3(b).
b. Whether two-way communications failure constitutes an emergency depends on the circumstances, and in any event, it is a determination made by the pilot. 14 CFR Section 91.3(b) authorizes a pilot to deviate from any rule in Subparts A and B to the extent required to meet an emergency.
I thought about the option of flying MZB-084 to RYAHH and then the approach from there, but the combination of fine print and terrain on the plate dissuaded me. I guessed that the procedure is NA for arrivals eastbound because they don't want you overshooting RYAHH and then having potential terrain issues east of the fix. That's why I came up with the plan of flying MZB-DOUGA-RYAHH and turning back inbound, since it would keep me west of RYAHH.
Once (offline, of course) I actually tried MZB-084 to DOUGA and turning inbound in the B732. It didn't end well. This was due in part to the fact that I can't fly the 732 worth a damn, but also the workload around DOUGA and VYDDA was overwhelming. A more experienced pilot than I could probably have gotten it done, but I had no hope of staying ahead of the turns and the NAV radios.
It seems pretty clear that there are a lot of workable options, and of course ATC is going to have eyes on you and get other traffic out of your way. I was just trying to work out what course of action would follow the Principle of Least Astonishment - staying as near as possible to the published approach seemed right. It's pretty shocking that the FAR still expects you to fly from the last fix to the clearance limit when that's not possible in many cases, although the provision for allowing pilots to deviate from the regs in emergencies would seem to cover it.
The FARs, specifically 91.185, leave little confusion on how to proceed in IFR with lost comms.
*twitches slightly*
You really think so?
The only time the tail end makes any sense is if you're graced with a navaid based at the field, in which case you can shoot the approach from there. Other than that, it's fairly ugly and more to the point and in cases where there is no IAF at the field, you should technically head to the airport first, then go to the IAF, even if you're cleared route of flight overflies an IAF. That's patently insane, especially /A where you have no mechanism to go direct to the airport after the last fix. There is zero chance I would do that in the airplane in real life. I would use emergency authority and fly to an IAF or feeder, with terrain and obstacle separation being absolutely guaranteed by MEAs the entire time and then if questioned as to the nature of the emergency, I'd say, "because the regulations make ZERO sense."
Ha. Yes "little confusion" is a poor choice of words. How about . . . the FARs are crystal clear on how to proceed in IFR with lost comms . . . and as you said they are "patently insane" - particularly if you are flying /A. I'm with you in that there is zero chance I would do that in real life - IMC off airway as a /A - no way.
Interestingly, I was asked this same question by the DE during my instrument oral exam. The scenario he proposed had my last fix as an IAF, but I still had to tell him I'd fly off airway to the airport and back to the same fix to begin the approach. Later I discussed it with a group of CFII's at the flight school and not one of them would follow that reg and go off airway IMC in real life . . . and we were proposing flying /G (note: we have a lot of mountains around here). The consensus was to use your PIC and emergency authority to fly and land as safely as possible. Better to argue the details later above ground.
This was due in part to the fact that I can't fly the 732 worth a damn, but also the workload around DOUGA and VYDDA was overwhelming. A more experienced pilot than I could probably have gotten it done, but I had no hope of staying ahead of the turns and the NAV radios.