Let me see.......with 3 VHF comms, HF, ACARS, Satcom and a trusty mobile.......if we have a total communication failure we are really in the pooooooooo..............probably for reasons other than communication!
Had the same argument from a u/t not too long ago and spent some time encouraging him to learn the procedures and to understand the variations that could be expected (much to his chagrin). I could not help feeling smug when within a couple of weeks we had a comm failure! And with a 4-engined jet aircraft (albeit a small one).
In reality though, DFC is quite correct on this one - it's going to be a rare occurrence that an aircraft goes radio fail after having been given an EAT of delay not determined. And yes, as Spamcan points out, we controllers don't
expect pilots to do anything after a com failure and the revised procedures recognise this fact because they are largely designed around ATC watching an aircraft on radar after it squawks R/T fail and getting everything else out of the way. But rather than complaining that the UK, yet again, is different from the rest of the world, maybe you should be asking why EUROCONTROL developed a set of procedures that completely ignored an ICAO standard procedure (however unlikely it might be). Perhaps the answer is that, like so many things that EUROCONTROL does, if it doesn't affect EUROCONTROL then it is considered not to matter!