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Fishies and spiders can always take 10 on Swim and Climb checks, why not birdies on Fly checks? Right?
thanks,
-nuun
Fishies = Apples, Spiders = Oranges, Flyers = Bananas.
Do not compare them. The only thing they have in common is that they are "modes of movement" - but the similarity stops there.
Swimmers and Climbers can choose to take 10, even during combat, because the rules say so. Flyers cannot choose to take 10 during combat, because rules do not say that they can. That is why. I can't really speak to the reason why such a decision might have been made, but if I had to guess, I'd say it's because flight (even for natural flying creatures) is a very complex mode of movement. When you watch a bird nose dive into a moving car or a building window, you realize that even the "best" flyers sometimes suffer the consequences of a missed Fly check. ;)
Remember you only need a Fly check for complex maneuvers and when you get hit while flying.
Without a check it can remain flying at the end of its turn so long as it moves a distance greater than half its speed. It can also turn up to 45 degrees by sacrificing 5 feet of movement, can rise at half speed at an angle of 45 degrees, and can descend at any angle at normal speed.