Federal Aviation Regulations on ATC Read Backs

Air Traffic Control expects a read back.

In the last article on air traffic control clearance read back, I quoted this guidance from the Airman’s Information Manual (AIM):

4−4−7. Pilot Responsibility upon Clearance Issuance

b. ATC Clearance/Instruction Readback.
Pilots of airborne aircraft should read back those parts of ATC clearances and instructions containing altitude assignments or vectors as a means of mutual verification.

Bear in mind the AIM is a collection of best practices and not regulatory, meaning, you are not required by law to read back any clearance. For regulation, we have to look to the Federal Aviation Regulations (FARs). What do we find there? Almost nothing on the requirement to read back a clearance. Just this:

§ 91.123   Compliance with ATC clearances and instructions.
(a) When an ATC clearance has been obtained, no pilot in command may deviate from that clearance unless an amended clearance is obtained, an emergency exists, or the deviation is in response to a traffic alert and collision avoidance system resolution advisory.

[And]

(e) Unless otherwise authorized by ATC, no person operating an aircraft may operate that aircraft according to any clearance or instruction that has been issued to the pilot of another aircraft for radar air traffic control purposes.

Nothing from Something Does Not Equal Nothing

So why does Air Traffic Control expect a read back of these types of clearances?

“Cleared to land,” or, “Cleared direct to Ormand Beach [VOR],” or, “Cleared for takeoff.”

Maybe the Air Traffic Controller’s Manual, (FAA Order JO 7110,) has something to say on the subject. Let’s take a look:

2-4-3. PILOT ACKNOWLEDGMENT/READ BACK
a. When issuing clearances or instructions ensure acknowledgment by the pilot.
NOTE-
Pilots may acknowledge clearances, instructions, or other information by using “Wilco,” “Roger,” “Affirmative,” or other words or remarks.
REFERENCE-
AIM, Para 4-2-3, Contact Procedures.

b. If altitude, heading, or other items are read back by the pilot, ensure the read back is correct. If incorrect or incomplete, make corrections as appropriate.

The Controller’s Manual says a pilot should acknowledge clearances or instructions, but it does not direct what a pilot should specifically say in the read back. According to the manual, the words “Wilco,” “Roger,” or “Affirmative,” are acceptable responses to a clearance. The Manual also refers back to the AIM, which is not law, to reference the possibility that pilots might read back “altitude, heading, or other items,” but there is no specific legal requirement to do so.

How Many Ways Can They Dance Around the Subject?

After dancing all around this subject in the regs, it comes down to this. All the AIM recommends is “read back of the numbers.” If you want ATC to quality check your understanding of a clearance–which I believe is a very good idea–then read back all relevant information that affects the direction, speed, and altitude of your flight. This includes

  • heading assignments;
  • altitude assignments;
  • speed assignments;
  • runway assignments
  • altimeter settings (because altimeter accuracy influences your aircraft’s altitude;)
  • rate of climb or descent assignments;
  • route changes, including holding pattern instructions;
  • approach and landing clearances;
  • takeoff and departure clearances;
  • runway hold short instructions
  • taxi instructions.

Best Practices

Why? It all goes back to the best practice stated in the AIM:

4-2-1 General

b. The single, most important thought in pilot- controller communications is understanding. It is essential, therefore, that pilots acknowledge each radio communication with ATC by using the appropriate aircraft call sign.

4-2-2 Radio Technique

c. Subsequent Contacts and Responses to Callup from a Ground Facility.

You should acknowledge all callups or clearances unless the controller or FSS specialist advises otherwise.

There you have it. Zero instruction from the FARs or the AIM on exactly what to say in your read back, but a strong recommendation to acknowledge instructions from ATC. Traditionally, air traffic controllers expect you to precisely read back any instruction that affects the flight path, (or ground path,) of your aircraft.

In my last article on this subject, I’m going to point out some examples of information pilots read back on the radio that have no bearing on their flight, and waste time on the radio. This will be an opinion piece, sure to stir up some controversy, so don’t miss it.

{ 8 comments… read them below or add one }

Ken Dyson September 27, 2012 at 12:34 am

This is all I could find.

Reply

JeffKanarish September 27, 2012 at 4:43 pm

Hey Ken,

Meaning what? You could only find the same few references I found, or did you other guidance that I did not include in this article?

Jef

Reply

Mark May 9, 2014 at 12:10 am

Also, the AIM says to read back the runway assigned in a landing clearance, and RUNWAY hold short clearances when taxiing; land and hold short clearances are to be both acknowledged and read back.

The FAA says “….specific readback of altitude clearances in an approach clearance is not mandatory….”

Also, the AIM doesn’t have us reading back the assigned taxi route.

Reply

JeffKanarish May 9, 2014 at 1:01 pm

Mark,

I absolutely agree with you. The AIM has a lot of contradictory information. This whole article is really about how the FAA minces words in the AIM.

I’ve rewritten one sentence in this article to clarify it is a good idea to read back the items in the list if you want ATC to quality check your understanding of the clearance, including your taxi route. I’ve also added runway assignments and runway hold short instructions to the list thanks to your comment.

Also, back in 2008, the FAA proposed adding this statement to 2-4-3 of the Air Traffic Controllers manual J.O. 7110.65: “Because of the volume of phraseology already associated with approach clearances, specific read back of altitude clearances in an approach clearance is not mandatory; however, to the extent traffic volume allows it is still encouraged.”

If you look at the current version of J.O. 7110.65, which is version V, this statement is not in the manual.

Jeff

Reply

Ted July 15, 2014 at 9:25 am

So a ground controller says “United 7*$, taxi to runway 8R via taxi ways Z, Y, A, hold short of runway 8L on RB”. I say “Roger *&) ground, United 7*$, Runway 8R, hold short Runway 8L on RB, copy all.”

I then get the same clearance which I respond the same way. I get the clearance repeated again in which I again respond the same way. I then get the clearance repeated again in which I respond “Am I missing something or has the AIM changed recently? I thought an acknowledgment of the runway assignment and any holdshorts and an acknowledgment of an understanding of the instructions are the only required readbacks? I then get a terse response that I am required to readback all taxi instructions as per the ATIS. I then read back the entire instructions verbatim and all subsequent instructions verbatim. Seems like overkill to me since at no time did we deviate from the initial clearance or in danger of deviating. Had this controller just said “request full readback” instead of repeating it 3 times, then I would be glad to comply. I’ll say this: You would never hear a controller at ORD require full ground control readbacks of all aircraft. I have heard them issue taxi instructions to up to 5 aircraft without a single readback. If they see you moving the way they want that is good enough for them. If you screw it up then you’ll definitely hear about it.

The controller’s manual is no help as it only states what the controller should or must say and not the pilot.

This controller in my view did not stick to the “Brevity” clause in 4-2-1 of the AIM and declared that their specific ATIS is now the definitive regulating control. I thought ATIS was an information system and more advisory in nature. ie……Altimeter is 29.95 but a controller may say the altimeter was 29.96 when checking in. If I were to treat the ATIS as gospel should I disregard the controller’s input? I won’t even say “Over” because I already know the answer.

Reply

JeffKanarish July 16, 2014 at 3:48 pm

Hey Ted,

I’ve had this problem at Newark. Unfortunately, right or wrong, some controllers are like bulldogs when it comes to what they want to hear as a readback on the radio.

I’m not exactly clear on what the ATIS broadcast said about reading back taxi instructions in this case. Did it say, “Read back all hold short instructions,” or did it say, “Read back all taxi instructions”?

The AIM is clear about the need to only read back runway hold short instructions, runway assignments, and clearances to enter or cross a runway.

I agree, the controller should have told you what he wanted, as in, “Give me a full readback of the taxi instructions,” as opposed to playing Stump the Dummy. As I said, the ground controller at Newark played the game in exactly the same way you described.

Yours is an example of a no-win situation. My philosophy has always been, give ATC what ATC wants while on the radio as long as it does not jeopardize safety. If I have heartburn about what ATC wanted, I’ll pick up the phone after the flight and talk it over with the ATC facilities supervisor.

Thank you for hashing this out with me.

Best,

Jeff

Reply

Fletcher June 11, 2015 at 8:57 pm

ATC has to get a runway read back, it has a double role of runway assignment and hold short instruction. This is the only required read back, and it’s a requirement in the AIM and JO 7110.65. For quality assurance purposes and to eliminate confusion about ATC instructions I would read back anything with numbers.

Reply

JeffKanarish June 12, 2015 at 11:23 am

Fletcher,

Exactly. If you look up 2 comments before yours, you’ll see a reader named Mark made the same comment. I replied the point of article is how much information the AIM misses. Also, did you see the bulleted list of items for read back in this article where I wrote, “runway assignments”? Of course you should read back your assigned runway.

Jeff

Reply

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