Air carrier pilot reported the current FAA guidance regarding lost communications procedures does not provide any timelines for when to initiate the procedure. Reporter suggested creating a template that provides such guidance.

Date: 2025-05 · Aircraft: Commercial Fixed Wing

Anomalies: atc-issue-all-types|deviation-discrepancy-procedural-published-material-policy|no-specific-anomaly-occurred-unwanted-situation

Synopsis

Air carrier pilot reported the current FAA guidance regarding lost communications procedures does not provide any timelines for when to initiate the procedure. Reporter suggested creating a template that provides such guidance.

Narrative

In light of the issues with EWR and the TRACON losing comms and radar capability; I'm wondering if there can be some coordination between companies and the FAA at either the national level or the local level. As I write this; there have been no fewer than 3 known equipment failures in the EWR approach area in the last week to 10 days. I took the time to review lost communication procedures; and I noticed one major flaw: there is no timeline given for determining when one is to be considered in a NORDO situation. This leaves every pilot/plane/flight/crew to their own devices when it comes to determining when 'lost comm' has occurred. What is considered an appropriate time? 1 minute? 90 seconds? 5 minutes? Any of these times can be considered an eternity at 250 knots below 10;000 or when over 250 above 10. Like any pilot; I've had gaps due to controller shift changes; controllers working multiple frequencies; or dead zones near an antenna. But the reality is that the AIM (Aeronautical Information Manual) gives little to no help in determining how long we should wait before initiating lost comm procedures. Is there any way to work with the FAA to craft an agreement on when it is considered an appropriate time to initiate lost comm procedures; especially into EWR and the NYC area? Leaving every flight to work 'by guess and by golly' does not sound like a reasonable business plan; and some common template would be helpful.

Source: NASA Aviation Safety Reporting System (public domain). Reports are voluntary submissions and are not verified by NASA.