The problem with lost com procedures

On the ground in Indianapolis, I called my dispatcher. The radar and radios had all failed, and when the radar was brought back online, only some of the radio frequencies were fully functional. The decisions made by the FAA (move to a slower arrival rate and partial ground stop to take into account fewer functional sectors) and the airline (use an internal plan for strategically diverting aircraft to minimize further congestion later in the day) meant that the several dozen diverted flights would be grounded for a while.

Over the next few weeks, there were more of these temporary outages. Without getting into the specifics, this is a great opportunity to review how pilots are expected to handle a lost communication situation.

The Aeronautical Information Manual (AIM) spells out the two-way communications failure procedures in Chapter 6, Section 4, Subsection 6-4-1(a) explains how the pilot is to determine the route and altitude to fly, as well as the timing of starting an approach. But the first sentence of 6-4-1(a) says it all: “It is virtually impossible to provide regulations and procedures applicable to all possible situations associated with two-way radio communications failure.”

The FAA wrote AIM 6-4-1 from the perspective of a single airplane losing coms, likely because of an equipment failure, bird strike, lightning strike, or some other malady. No real consideration was given to a problem on the ground affecting a large swath of airspace inhabited by dozens of aircraft flying at various speeds and altitudes. Further, no process is laid out by the powers that be to help us determine when we are, in fact, NORDO (no radio).

Any IFR pilot can tell stories about being in a dead zone over an antenna, or waiting for a controller change, or dealing with a controller who is working multiple frequencies. These everyday events rarely lead to any more than a few seconds of radio silence from the ground. But, how are pilots supposed to know when we have crossed the line into true NORDO or lost radar operations? And when do we initiate lost com procedures?

The procedures tell us to use the ETA on our flight plans to time an arrival or an approach. Altitudes are based on published minimum altitudes, but we as pilots may not be aware of all possible altitude constraints, and there is even an example provided where a pilot in a terminal area needs to climb, possibly after descending, which is counterintuitive and workload intensive.

Another major issue is that ATC almost never has an airplane fly the actual filed course all the way to the runway. Vectors, headings, shortcuts, and not-so-short-cuts are common. If a facility goes down, how do we proceed? What if multiple aircraft have the same ETA on their flight plan for the initial approach fix?

None of this considers issues with weather. Log into LiveATC.net for a busy Class B area on a bad weather day and you’ll hear controlled chaos that would make even the best auctioneer jealous. Now imagine if all of that went…quiet. Who does what? When? How?

My intention is not to sow fear. But the FAA and industry need to address the issue of how to cope with a ground failure. Other major metropolitan areas have similar congestion issues: central Florida and south Florida, northern and southern California, Dallas and Houston in Texas, the Baltimore/D.C. area, Chicago, and Denver and Salt Lake City, which both have terrain considerations.

The FAA is currently working with pilot unions, airlines, and others to craft a process for something that goes far beyond an airplane losing an antenna to a bird strike. They need to do it as soon as possible, and it needs to be something that pilots, in what will likely be one of the most stressful events of their lives, can do without digging around for a long document with instructions.