A pilot is holding at a fix that is also the clearance limit after experiencing a two-way radio communications failure in IMC. The pilot has not received an Expect Further Clearance (EFC) time before the failure occurred. According to 14 CFR 91.185, when should the pilot leave the clearance limit to begin the approach?
- AOnly after receiving a new clearance limit and EFC time from ATC via any available means
- BImmediately upon reaching the clearance limit, regardless of the filed flight plan
- CAs close as possible to the estimated time of arrival (ETA) at the clearance limit as calculated from the filed or amended flight plan
- DThirty minutes after reaching the clearance limit, per the standard holding time allowance
Show answer & explanationAnswer & explanation
Correct answer: C. As close as possible to the estimated time of arrival (ETA) at the clearance limit as calculated from the filed or amended flight plan
Under 14 CFR 91.185(c)(3), if no EFC time has been received, the pilot must leave the clearance limit as close as possible to the ETA calculated from the filed or amended (with ATC) flight plan. This ensures the pilot proceeds to the approach at a predictable time that ATC can anticipate for separation purposes.
Why the other options are wrong
- A. Waiting indefinitely for a new EFC via any means is not required or expected under 91.185.
- B. Leaving immediately does not follow the specific timing rule when no EFC time was received.
- D. Thirty minutes is not the standard; this figure applies to different lost-comm or void-time scenarios, not this rule.
Lost Comm — Leaving the Clearance Limit
Under 14 CFR 91.185, when two-way radio communication is lost, a pilot holding at the clearance limit must leave at the EFC time if received, or as close as possible to the ETA from the filed/amended flight plan if no EFC was given.
- EFC time received: leave clearance limit at that time
- No EFC time: leave as close as possible to flight-plan ETA
- Applies specifically when clearance limit is not the destination
- Designed to give ATC predictable timing for separation
Memory trick: No EFC? Use your flight plan's ETA to decide.