A forum post circulating in pilot communities raises substantive questions about how lost communications procedures under 14 CFR 91.185 are being taught at the instrument instructor level, with one CFII candidate's mentor advocating a dual-track approach that blends regulatory compliance with what he characterizes as practical, real-world deviation. The post deserves careful examination because the "real life" framework being taught contains meaningful legal and operational inaccuracies that could propagate through the instructor pipeline into student populations.
The regulatory framework of 91.185 is not ambiguous. The rule distinguishes between two clearance limit scenarios: a fix that is an IAF, where the pilot holds until the EFC or ETA and then commences the approach, and a fix that is not an IAF, such as direct-to-airport clearances, where the pilot departs the clearance limit at the EFC time or upon arrival if no EFC was issued, then proceeds to an IAF and flies the approach. The entire architecture of this regulation is built around one principle — predictability — which the CFII correctly identifies but then partially abandons. ATC can anticipate pilot behavior in lost comm situations precisely because 91.185 creates a behavioral standard all instrument-rated pilots are expected to follow. When individual pilots deviate from that standard, even with good intentions, they introduce variability into a system designed around certainty.
The CFII's "real life" framing contains a significant factual error that warrants direct correction: squawking 7600 does not make a pilot an emergency aircraft. Transponder code 7600 signals lost communications; code 7700 signals a declared emergency. These are legally and operationally distinct. Emergency PIC authority under 91.3 exists to address genuine safety-of-flight emergencies and does allow deviation from regulations, but invoking it simply to skip a holding requirement at a clearance limit — in the absence of a fuel emergency, mechanical failure, or other immediate safety threat — is a misapplication of the doctrine. A CFII candidate who teaches this equivalence on a checkride or to future students risks propagating a procedural error that could create real confusion in the ATC environment, particularly at busy terminal facilities where controllers rely on predictable lost-comm behavior to sequence other traffic.
For professional and corporate pilots operating under Parts 91, 91K, and 135 in actual IMC, the stakes of this distinction are not academic. High-density IFR environments — Class B and C surface areas, instrument approach corridors at major hubs — depend on controllers being able to predict exactly what a lost-comm aircraft will do and when. The CFII's argument that holding for 20-plus minutes wastes everyone's time has intuitive appeal, but it misunderstands the purpose of EFC times: controllers issue them as part of traffic sequencing, and an aircraft that departs its clearance limit unpredictably can conflict with other IFR departures, approaches, or missed approaches that the controller has already sequenced assuming the lost-comm aircraft will hold as required. The argument also ignores that a pilot who simply skips the hold and goes direct to the IAF may not be "more predictable" — controllers in the radar room will be watching the 7600 squawk and expecting 91.185 behavior, not an improvised approach.
The broader trend this post reflects is worth noting: aviation instruction increasingly grapples with the tension between rigid regulatory teaching and pragmatic airmanship, particularly as instrument training evolves under a diverse pool of instructors with varying operational backgrounds. The solution is not to present legally questionable workarounds as equally valid alternatives to codified procedures, especially at the CFII level where the instructor's role is to produce instrument instructors who will in turn shape thousands of student pilots. On an FAA practical test, an examiner will evaluate whether the applicant can teach 91.185 accurately and completely; introducing unsolicited "real life" alternatives that rest on a mischaracterized use of emergency authority and a conflation of transponder codes is unlikely to serve the candidate well. The prudent course for this CFII candidate is to master and teach the regulation as written, reserve the philosophical discussion of PIC judgment for appropriate advanced contexts, and recognize that the most predictable pilot in lost comm is the one who follows the rule every time.