Communication Failure Procedure

[goranb]

I'm having a discussion with a colleague of mine about Comm Fail Procedure. I'm referring to ICAO (Jeppesen Emergency pg 6-7) and EUR (Jepp. Emerg. E-21 & EE-21). In particular, we are discussing the case where destination is bellow Cat I so flight is dispatched for a Cat II (or III) approach. Such destination would probably have enough "problems" without a flight with a com failure. However we couldn’t find any reference in Jepp for such a situation.
If anybody here has an opinion or reference, I would very much like to hear it (or a link if this has been discussed already).

[maxalt]

Hi goranb, this is an interesting issue and one I've discussed at length with colleagues also.

My view is that you are still required to carry out the standard comms failure arrival (go to holding fix at cruise level, descend at ETA/EAT, land(hopefully) within 30 mins).

While I accept your worry about 'problems' for the CATIII airport I'm even more worried for the possibility of not getting in from the approach. For two reasons.

First, the full Comms Fail procedure is likely to burn a lot more fuel than your usual straight in...leaving you short when your options are narrowing.

Second, not all airports give Loss of Comms procedures for Diversion after Go Around! In fact most don't. On asking ATC at my home base about this they said it was once published but has been withdrawn as being too unlikely a scenario to cater for.

My understanding is that you Go Around and divert (direct if possible, due your likely fuel state) to your alternate, then either carry out the same letdown procedure again (FUEL!) or else go hell for leather straight in!

Sqawking 7600 would be of great importance here!

It seems to me that the comms procedures (General Rules) are written in often vague and lose terms that in no way give hard and fast instructions for every scenario. Normally that would be slightly inconvenient, but in the current security environment I'm really concerned you could get shot down if you stray too far from what 'they' think you should be doing.

I know one thing...if I lost Comms I'd have my Interception Procedures page displayed right next to the Comms Fail one!

[goranb]

maxalt

Fuel shoal not be a problem since dispatching with additional 2000kg (unless weight restricted). It's for delays associated with the AWO.
I think the issue is more about legality - proving your case after landing with CAA, FAA... I must point out that UK (and German too) procedure is different from ICAO one. UK requires that you continue and finish your flight as IFR in a procedure you described. ICAO in, as you say, vague and lose terms, lets you use "if in VMC" part.
I would in 99% cases continue to fly IFR, descent in racetrack/hold and land within 30min. My problem is that 1%. Let's say I'm going to LHR for a 300m RVR Cat II and lose my radio in climb after departure. If I continue ATC would have to clear LAM holding from FL340 to 70 and the word "mess" comes to mind. Than maybe RVR went down bellow 300m so I’ll have to fly to alternate, producing more mess. Not to mention possibility of being intercepted and taken to a safe airport far away from any city and buildings. Or I can use "in VMC" provisions of ICAO proc. and land back in my dep airport. Of course 7600 is must and Ident to draw attention before changing course of action (not mag course).
I'd love to hear what you think of this

goranb

[maxalt]

Fuel shoal not be a problem since dispatching with additional 2000kg (unless weight restricted). It's for delays associated with the AWO.

Lucky you!

On the issue of IFR/VFR, my company only files IFR flight plans. We do not operate VFR under 'normal' circumstances.

Obviously we sometimes declare 'visual' and go for a VFR circuit when weather permits.

But going 'VFR' in comms fail scenario is a different kettle of fish.

Some colleagues (mostly ex ATC guys!) insist they'd 'find a hole and go visual'...others feel this is too risky.
I agree.

I guess it comes down to circumstances on the day, and your own professional standards.