ZOA CTLR CONCERNED WITH LOST COM PROC CHANGE FROM PRESENT FAA TO THE ICAO STANDARD.

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A PROCEDURAL SIT HAS NOW DEVELOPED AT ZOA WHICH ADVERSELY AFFECTS THE SAFETY OF ACFT FLYING THROUGHOUT MOST OF THE PACIFIC OCEAN. ZOA MGMNT HAS ORDERED OCEANIC CTLRS TO USE ICAO 'LOST COMS' PROCS RATHER THAN THE UNITED STATES FAR PROCS FOR LOST COMS WHICH HAVE BEEN USED FOR DECADES. ICAO 'LOST COMS' PROCS ARE VERY DANGEROUS IN THE OCEANIC ATC ENVIRONMENT. THEY INTRODUCE AN ELEMENT OF UNCERTAINTY AND CHAOS WITH WHICH CTLRS CANNOT POSSIBLY COPE. OCEANIC CTLRS LITERALLY CAN NO LONGER GUARANTEE THE SAFETY OF THE ACFT UNDER THEIR CTL. THE 'LOST COMS' PROCS WHICH UNITED STATES OCEANIC CTLRS HAVE ALWAYS USED REQUIRE ACFT WHICH LOSE COMS WITH CTLRS; TO PROCEED IN ACCORDANCE WITH THE LAST CLRNC RECEIVED. THIS KEEPS THE SIT STABLE; SAFE; AND CERTAIN. EVERYONE INVOLVED HAS RELIABLE EXPECTATIONS ABOUT WHAT WILL OCCUR AND WHEN IT WILL OCCUR. BUT THE SIT IS DRAMATICALLY DIFFERENT WITH ICAO PROCS WHICH ACFT AND OCEANIC CTLRS ARE NOW REQUIRED TO USE. ICAO PROBS TOTALLY IGNORE ACTUAL TFC SITS. THEY REQUIRE ACFT THAT LOSE COMS TO BLINDLY CHANGE ALTS AND SPDS IN ACCORDANCE WITH A FLT PLAN THAT WAS FILED ON THE GND BEFORE IT EVEN DEPARTED. THAT FLT PLAN ONLY REFLECTS THE OPERATOR'S DESIRED FLT PROFILE. IT DOES NOT AND CANNOT ANTICIPATE OTHER ACFT THAT MIGHT BE CRITICALLY CLOSE AT THE TIME ALT AND SPD CHANGES ARE PLANNED. THE IMPLEMENTATION OF THIS CHANGE HAS OCCURRED SUDDENLY BY FIAT. THE EQUIP; SOFTWARE; TRAINING; AND OPERATING PROCS USED IN OCEANIC ATC ARE NOT DESIGNED TO BE ABLE TO COPE WITH THIS CHANGE. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: ZOA SPECIALIST ADVISED THAT FAA LOST COM POLICIES IN INTL AIRSPACE ARE UNDER REVIEW. ICAO STANDARDS ARE DEFINED IN ICAO DOCUMENT ANNEX 2; CHAPTER 3; PARAGRAPH 3.6.5.2.2.A; AND NOTE 1. BUT BASICALLY; THE FAA CAN EXEMPT THEMSELVES BY DEFINING TO ALL ICAO MEMBERS WHAT IS REQUIRED WHEN UNDER THE CTL OF THE FAA. THE SPECIALIST ADVISED THAT THIS EXEMPTION IS PLANNED FOR APPROVAL AND IMPLEMENTATION IN APPROX 6 MONTHS.