***Link*** :: [Turri 2010](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2010/Turri_2010_Legal_Interpretation.pdf) ***Description*** :: Clarification of operating requirements associated with the loss of two-way radio communications ***Author*** :: [[FAA Office of the Chief Counsel]] #### Key Quotes * First, you question whether the holding fix and the clearance limit are the same place. The answer is, not necessarily. * Second, you question whether section [[FAR 91.185 Lost Comms|91.185]](c) applies if no holding instructions have been issued and, if so, how non-GPS aircraft comply. The answer to the first part of your second question is yes. #source #legal-interpretation