Section 5-3-3 of the AIM lists "Additional Reports" that "should" be made on an IFR flight. There are 9 of them in a radar environment and 2 more in non-radar. The only reference to the FARs is to 91.183 which lists just 3 items, of which only the 2 dealing with safety of flight (weather / other) apparently apply at all times. What is a reference for the others?

Like, "time and altitude...reaching a holding fix", "change in average true airspeed..." or "vacating any previously assigned...altitude"? Please don't say "the AIM is not regulatory". Failing to do any of these things could, as I understand it, get one violated on 91.13 if there's an incident. But is there any specific regulation beyond 91.183? Like the one about ETA change of more than 2 minutes, except 3 minutes in the north Atlantic seems very specific in a regulatory-like way.

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    $\begingroup$ Pretty sure that the answer is no, but I think it's a stretch to say that not making a call per AIM 5-3-3 would constitute careless or reckless operation. ("If there's an incident" suggests that there would need to be at least a few other contributing factors to make something reportable...) I think 91.13 is intended to cover things that are a bit more blatant than simply forgetting a radio call or being off your ETA. We really don't want the FAA issuing flight violations for neglecting best practices, or we'd all be in trouble! $\endgroup$ Commented Sep 26, 2021 at 17:26

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Short answer: the AIM is giving you more details on how to comply with the regulations, it isn't just repeating what the regulations already say.

For context, the AIM itself says in its opening section (emphasis mine):

This publication, while not regulatory, provides information which reflects examples of operating techniques and procedures which may be requirements in other federal publications or regulations. It is made available solely to assist pilots in executing their responsibilities required by other publications.

Going back to 91.183(c), it says that a pilot must report:

Any other information relating to the safety of flight.

A pilot might wonder exactly what information the FAA thinks is related to safety of flight, and how many reports ATC really needs to receive. The AIM provides guidance by listing specific reporting items. It's like the FAA is saying "report these things and you'll (probably) be in compliance with 91.183(c)".

Another example is 14 CFR 91.103, which says:

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight

"All available information" is very broad and the AIM provides more specific guidance in a couple of places including 5-1-3(b), which essentially says "check NOTAMs before your flight". I assume most pilots would agree that checking NOTAMs is an obvious and essential preflight step, but 91.103 doesn't mention them at all.

In other words, these are examples of the AIM giving more details on how to comply with a regulation; it isn't just repeating the regulation.

You might still ask, if these things are so important then why aren't they in the regulations in the first place? One very general answer is that changing regulations is extremely slow and difficult, whereas the FAA can publish a new version of the AIM whenever it likes. Procedures and technology change much more quickly than regulations can, and there's far too much technical detail in aviation for it to be practical to have it all in the regulations themselves.

  • $\begingroup$ This is fine as far as it goes, but I guess I’m puzzled by the specifity of things like “climb or descend at 500 ft/min” and the “ETA+/-2min except in the North Atlantic where its’ 3 min.” things. They are very specific but there’s no reference given for their source, which must exist somewhere else. $\endgroup$ Commented Sep 27, 2021 at 4:25
  • $\begingroup$ Why do you say a source must exist elsewhere? Can’t the AIM be a source? $\endgroup$ Commented Sep 27, 2021 at 14:45
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    $\begingroup$ @FosterBoondoggle The AIM is full of very specific details that presumably come from many different sources: regulations, ACs, technical studies, the TERPS, ICAO standards, international agreements etc. Listing the source for each one would likely make the AIM a lot longer than it already is. Having said that, there's obviously a reason of some kind for everything, even if that reason isn't easy to track down to a single source. $\endgroup$
    – Pondlife
    Commented Sep 27, 2021 at 15:59

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