IFR Lost Comms: “Proceed Direct” vs. “Cleared To” with an EFC Time
I’m a CFII reviewing §91.185 for an interview I have next week and I’d like to clarify a specific lost-comms scenario:
Let’s say I’m flying IFR from KAUN to KSAC. My original clearance limit is KSAC.
Enroute, ATC issues one of two instructions:
Scenario A: “Cleared to PIVSE, hold as published, expect further clearance in five minutes.”
Scenario B: “Proceed direct PIVSE, hold as published, expect further clearance in five minutes.”
PIVSE is not a fix from which an instrument approach begins, and I lose communications in IMC immediately after receiving the instruction.
My understanding is that in Scenario A, PIVSE becomes my amended clearance limit. Under §91.185(c)(3)(ii), I’d leave PIVSE at the EFC time, proceed to a fix from which an approach begins, and commence the approach as close as possible to my filed or amended ETA.
But in Scenario B, does my original clearance limit remain KSAC because ATC only amended my routing?
If so, would I be expected to hold at PIVSE until the EFC time, continue to KSAC, and then proceed to an appropriate approach fix?
More fundamentally, is Scenario B even a clearance ATC would realistically issue? Can an EFC time accompany a “proceed direct” instruction without amending the clearance limit?
I’d especially appreciate input from controllers or CFII/DPEs familiar with how this is handled in practice versus the literal wording of §91.185.
Thanks in advance for the help! I’ve tried to ask pilots I went to flight school with and this has been a bit of a stumper.
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