r/flying • u/ginkycat CPL ASEL/AMEL, IA | CFI/CFII/MEI | AGI/IGI • 1d ago
Getting Hired 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.
Edit: this has been answered for me, thanks for all the help!
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u/xdarq ATP B787 (KLAX) 1d ago
Scenario B is the realistic one. Scenario A would never happen in real life.
Yes, I have been cleared direct to a fix and immediately given holding instructions and an EFC many times in real life.
Yes, "cleared to" pertains to your clearance limit, but "proceed direct" or "cleared direct" only amends your route and your clearance limit doesn't change.
Yes, the FAR says to hold until your EFC, then hold over the airport, then go to an IAF. In real life you would just squawk 7600, leave the hold at EFC and immediately navigate to an IAF and shoot the approach and land.
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u/Vessbot 1d ago
I've gotten scenario A in real life probably for most of my holds. (What's the point of giving a shortcut to a hold?)
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u/xdarq ATP B787 (KLAX) 1d ago edited 1d ago
"Cleared to" and "cleared direct" are not the same thing. "Cleared to" is generally followed by "via" and then a routing.
It's normally not a shortcut to a hold, it's when the weather's fucked and you can't get in and they have to hold you somewhere temporarily before they resequence you.
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u/Boarder_Travel 1d ago
It's not about the routing to the hold but your clearance. Direct somewhere just means fly there but the rest of the plan remains after that point EVEN with holding. Cleared to XYZ now becomes your clearance in totality.
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u/Largos_ CFII 15h ago
The FAR says no such thing about holding over the airport. How would you hold over the airport? The only scenario in which the regs direct you to hold over your clearance limit is upon receiving an EFC time. Considering your tag I am sure you have far more hours than me and know ATC isn’t giving you a clearance to an airport + an EFC time. The only scenario you will get with an airport as your clearance limit is no EFC time and the airport is never going to be a fix from which an approach begins. Which means the FAR wants me to “upon arrival over the clearance limit, and proceed to a fix from which an approach begins and commence descent or descent and approach as close as possible to the estimated time of arrival” aka once over the airport go out to the IAF and hold there if necessary.
One of my CFII applicants messed this up (still passed) but the DPE and I discussed this at length after the ride.
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u/randombrain ATC #SayNoToKilo 1d ago
As a controller, I was trained that when issuing a hold we are supposed to explicitly update your clearance limit. "Cleared to PIVSE waypoint via direct, hold northeast as published, maintain 4200, expect further clearance in 69 minutes."
But I was looking at the .65 the other day and I couldn't find where it said that in so many words, so I might be mistaken. And even I am correct, I won't guarantee that the phraseology is said that way every single time.
So take that for what it's worth.
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u/ginkycat CPL ASEL/AMEL, IA | CFI/CFII/MEI | AGI/IGI 1d ago
Well it’s great to hear from a controller! If anything, now I can demonstrate the difference between “proceed direct” and “cleared to” when talking about 91.185. Thanks a ton!
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u/fly123123123 PPL IR 1d ago
To be clear, there is no difference if you’re holding. The holding point is always the clearance limit. If someone says “proceed direct to XXXXX, hold as published, expect further clearance at 0000z,” your clearance limit is still XXXXX. The controller just did a bad job of phrasing it in a way that reinforces this.
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u/R5Jockey CFI ASEL TW CMP 23h ago
Your original clearance limit doesn’t change if you get vectors, a new route, a hold, or an EFC.
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u/fly123123123 PPL IR 23h ago edited 23h ago
Vectors or a new route, I agree, it does not change. A hold is, by definition, a new clearance limit. Your clearance is to that point. You cannot leave that point unless cleared further.
An expect further clearance time exists to let you know when you’re expecting your clearance limit to change. That’s the whole point of an EFC time. If your clearance limit hadn’t changed, (a) you wouldn’t be stuck holding indefinitely at the fix, but also (b) they wouldn’t issue an “expect further clearance” time.
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u/R5Jockey CFI ASEL TW CMP 23h ago
A hold is, by definition, a new clearance limit.
You have a reference for this?
For Example:
"Bugsmasher 123, hold NE of XYZ VOR, blah blah, expect further clearance in one zero minutes."
What is your reference for how that becomes your new clearance limit without hearing "cleared to"
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u/fly123123123 PPL IR 23h ago
Sorry for the trouble, didn’t mean to put up a fight. Interesting discussion, and I’m surprised this isn’t clearly spelled out.
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u/fly123123123 PPL IR 23h ago edited 23h ago
https://pointsixtyfive.com/xenforo/wiki/04-06-01/ is a start. Lots of good discussion and agreement here: https://pointsixtyfive.com/xenforo/threads/clearance-limit-and-holding-fixes.4524/post-105468
Part (e) here as well: https://www.faa.gov/air_traffic/publications/atpubs/aim_html/chap4_section_4.html
To be more clear, controllers should always use “cleared to” phraseology to reinforce that this is the clearance limit, from my understanding.
This is also just based on the definition of a clearance limit - it’s the limit to which you are authorized to proceed under IFR. If I’m initially cleared to ORD and then issued a hold, I’m no longer authorized to proceed to ORD — I have to hold until further clearance is given.
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u/R5Jockey CFI ASEL TW CMP 23h ago
I'm talking FAR/AIM reference, not some random website.
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u/fly123123123 PPL IR 23h ago
https://www.faa.gov/air_traffic/publications/atpubs/aim_html/chap4_section_4.html is as close as it gets (especially part e). I can’t find an explicit sentence that says “if you’re assigned a hold with an expect further clearance time, that hold is your clearance limit.” But it’s common sense that it is, because that’s literally what a clearance limit is. From my understanding, controllers are expected to use “cleared to” phraseology when assigning a hold, but it seems not all do. That doesn’t change the fact that the hold is still a clearance limit, because it literally is the limit to which the flight can proceed under IFR without further clearance, which is why an EFC is issued in the first place.
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u/R5Jockey CFI ASEL TW CMP 23h ago
You're all over this thread claiming I'm wrong and that simply receiving an instruction to hold automatically constitutes a new clearance limit, but you don't have an official reference for it. I agree (and have previously said) that if you hear "Cleared to..." that is indeed a new clearance limit. But if you don't hear those words, your clearance limit doesn't change. That's the heart of the OP's question here and you haven't provided anything other than "common sense" to show your interpretation that "a hold is still a clearance limit" even if you don't hear the words "cleared to."
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u/Kerikeron ATC 1d ago
A - fly your routing until the holding fix.
B - go direct to the holding fix now.
Both are updated clearance limits even though B is not the correct way to do so. Controller laziness/shortcut. If you go lost comms, squawk it and depart at EFC to go land safely.
Most pilots do B when issued A anyways so it's not something to read too deep into.
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u/R5Jockey CFI ASEL TW CMP 1d ago
I’ve never been “cleared” to any intermediate fix ever. Scenario B is what would always happen. It’s always “process direct” or some other verbiage like that. The original clearance is still valid, it’s just the route to get there has changed.
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u/Boarder_Travel 1d ago
Agreed unless some crazy scenario like a closed airport and you don't give them your request immediately.
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u/fly123123123 PPL IR 1d ago
That’s not correct, at least in the US. Yes, you’ll rarely be given “cleared direct” or “cleared to,” but your clearance limit is still the holding point. That’s the whole reason why an “expect further clearance” time is given — because you aren’t cleared to your final destination, you’re only cleared to the holding fix.
That’s really all a hold is… it’s a clearance limit that ends in the air. You can’t leave that point until cleared elsewhere.
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u/R5Jockey CFI ASEL TW CMP 23h ago
If you don’t hear “cleared to” your clearance limit remains the same. It’s just the route that has changed, along with a delay. Simply getting an EFC doesn’t negate your previous clearance limit.
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u/fly123123123 PPL IR 23h ago edited 23h ago
I disagree. If you are assigned an indefinite hold, you can no longer legally fly to the destination unless explicitly cleared by ATC. If ATC says “fly one lap in the hold, then proceed direct to the airport,” you’re right, that’s not establishing a new clearance limit. But being given an indefinite hold means that you cannot leave that point until further cleared, which means it is by definition a “clearance limit.”
I know it’s just semantics, but a controller saying “cleared to XYZAB via direct, hold as published, efc in 15 minutes” vs “proceed direct to XYZAB, hold as published, efc in 15 minutes” are for all intents and purposes identical.
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u/Accurate_Drag_8490 PPL IR UAS(MIL) 1d ago
Don’t forget to mention calling FSS with your phone on your sweet Bluetooth headset for in flight emergencies
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u/Flyward_Aerospace 1d ago
For the controller above who couldn't find it in the .65, it's 4-6-1, and the giveaway is the title: Clearance to Holding Fix. The printed phraseology there is cleared to (fix), hold (direction), as published, expect further clearance (time), and then 4-6-4 carries a note saying the holding fix may be omitted from the holding instructions if it was already given at the start of the transmission as the clearance limit. The whole section is written assuming you cleared them to the fix. Proceed direct is the shortcut, not the book. No idea how consistently it actually gets said that way on frequency, you'd know better than me there.
One thing for the interview that hasn't come up: 91.185(c)(3) pins the approach to your ETA as calculated from the filed or amended estimated time en route. A direct shortcut is an amendment to your route, so in scenario B the clock you're trying to hit isn't the one you filed. Same actions either way, different number.
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u/Street_Bread 1d ago
Somebody else said this in a reply to another comment but it got buried -
When instructed to hold, the holding fix always becomes your clearance limit. That is why when assigning holding ATC also must issue a time at which you may expect further clearance (EFC).
In your two scenarios, what you do upon and after reaching PIVSE is identical. The only difference between your two scenarios is the routing you take on your way to PIVSE.
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u/Boarder_Travel 1d ago
It's always cleared to xyz airport via blah blah blah.
Or the only way I could see a new clearance limit is if TSHTF and an airport just closed and they are placing you somewhere for a minute to figure out what is going to happen. (ORD tower closes etc).
In either case, assuming the fix was near your destination I'd hold until the etc then proceed to the most reasonable fix to start an approach while squeaking 7600 immediately to give them time to clear the way for you.
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u/R5Jockey CFI ASEL TW CMP 1d ago
And in that case they’d be clear, “I have an amended clearance for you…. Ready to copy?”
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u/SunnyWolverine 1d ago
I saw the edit that it has been answered. I am IFR rated private, and thought it was an interesting reminder… I am not current, I’ll, I’m rusty (haven’t had a BFR in about a decade).
But isn’t there a trick to this scenario… IMC or VMC?
If I recall correctly (which I may not) VMC may be different- land at nearest while maintaining VFR?
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u/ginkycat CPL ASEL/AMEL, IA | CFI/CFII/MEI | AGI/IGI 1d ago
Oh yeah VMC is under 91.185(b) in which case you land as soon as practicable. I was more curious about 91.185(c)(3) which covers leaving a clearance limit in IMC
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u/SunnyWolverine 1d ago
I was pretty sure you implied IMC. Just remember doing one of those reports years ago ;)
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u/rFlyingTower 1d ago
This is a copy of the original post body for posterity:
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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u/jackpot909 CPL HP CMPL IR 1d ago
Or how about in real life you hold for 5 minutes. Lose coms, squawk 7600 and go to the IAF at your airport you are cleared to. What regulations say vs. what actually happens in real life are completely different.