FAA Instrument Flight Instructor (FII)IFR Procedures and ApproachesEasy
A pilot is holding at a VOR fix in IMC awaiting an approach clearance when two-way radio communication failure occurs. The holding fix was the pilot's clearance limit, and ATC had issued an expect-further-clearance (EFC) time of 1450 prior to the failure. According to 14 CFR 91.185, what action should the pilot take?
- ADepart the holding fix at the flight-plan filed ETA, disregarding the EFC time
- BRemain at the fix indefinitely, since only ATC can authorize departure from a clearance limit
- CDepart the holding fix at 1450, the EFC time, and commence the approach
- DSquawk 7600 and continue holding indefinitely until fuel remaining requires a landing
Show answer & explanationAnswer & explanation
Correct answer: C. Depart the holding fix at 1450, the EFC time, and commence the approach
14 CFR 91.185(c)(3) requires a pilot who loses two-way radio communication, when the clearance limit is a fix from which an approach begins, to leave that clearance limit at the EFC time if one was received. This ensures ATC can plan separation for the aircraft's approach.
Why the other options are wrong
- A. The filed ETA only applies if no EFC time was given; here one was received.
- B. 91.185 specifically authorizes departure without further clearance under lost-comm rules.
- D. Ignoring the EFC time contradicts the specific regulatory guidance for this scenario.
Lost Comm at Clearance Limit (91.185)
When two-way radio fails and the clearance limit is a fix from which an approach begins, the pilot departs the fix at the EFC time (or, if none, as close as possible to the filed ETA) to begin the approach.
- EFC time received: leave clearance limit at that time
- No EFC time: leave at filed/amended ETA
- Applies specifically when the clearance limit is an approach fix
Memory trick: 'EFC Equals First Chance' to leave the fix.