Here is the AIM's definition for a clearance limit:
CLEARANCE LIMIT− The fix, point, or location to which an aircraft is cleared when issued an air traffic clearance
Assume a clearance such as: "Cleared to Los Angeles Internal Airport (KLAX) via..."
This means our clearance limit is KLAX.
But what does this mean if I follow the instructions in 91.185?
If the clearance limit is not a fix from which an approach begins [it's not], leave the clearance limit at the expect-further-clearance time if one has been received [it hasn't], or if none has been received, upon arrival over the clearance limit
A pilot should fly until the last fix on the route and then direct to their clearance limit: KLAX at their last assigned altitude (let's assume FL280).
and proceed to a fix from which an approach begins
Now fly direct from KLAX, with no assigned route, to an Initial Approach Fix (CRCUS or SEAVU).
commence descent or descent and approach as close as possible to the estimated time of arrival as calculated from the filed or amended (with ATC) estimated time en route
Hold at SEAVU or CRCUS (for which there is no published hold--so they can make one up), UNTIL their ETA into LAX. Then, descend in the hold and fly the approach. Or, realizing these fixes are 35nm away from KLAX, would a pilot turn around half way between SEAVU and KLAX to return to SEAVU at their ETA to descend?
Is that crazy to anyone else? To follow this regulation, a pilot would fly over their destination airport and then return to an IAF to do an approach. Does ATC really want us to do this in a lost comm situation? At a minimum, this doesn't seem like a prudent use of fuel which brings safety of flight into the mix.
When and where can I legally start an approach in this scenario?