***Link*** :: [Van West 2018]() ***Description*** :: Clarification that, though holding at clearance limit is draining for a pilot in lost comms, [[Transponder]] alone is not a substitute for two-radio radio ***Author*** :: [[FAA Office of the Chief Counsel]] #### Key Quotes * An operable transponder is not a substitute for two-way communication between the pilot and ATC, nor for the estimated time of arrival filed in the pilot's flight plan on which the ATC relies to make other safety-based determinations. Therefore, we affirm our previous interpretations of § [[FAR 91.185 Lost Comms|91.185]](c)(3). #source #legal-interpretation