ICAS members have inquired about some potentially confusing items identified in FAA Order 8900.1 that have the possibility of impacting air shows. Both issues stem from Volume 3, Chapter 6, Section 1 of 8900.1 which deals with the issuance of a certificate of waiver for an aviation event. Let’s have a look at both issues and clear the air. Click here for an up to date link to the current document.
The first issue is a largely cosmetic issue that can be confusing to the casual observer. The document shows a date of “11/27/12” in the top left corner of each page with “8900.1 CHG 86” in the top right. At first glance, this could appear that change 86 of this section was completed on November 27, 2012. After being made aware of this confusion, ICAS learned that the date in the top left indicates the last date that any editorial (non-substantive) changes were made as opposed to substantive changes that would require another “change.” The last substantive edits to the section, known as “change 86” were made effective on February 26, 2010. At that time, ICAS had worked closely with the FAA the implemented draft.
The second issue that was identified by ICAS members was a lingering issue concerning night shows that ICAS had identified as an issue that would require clarification when ICAS was reviewing the draft changes in change 86. The confusion begins with the definition of night: “Night means the time between the end of evening civil twilight and the beginning of morning civil twilight, as published in the American Air Almanac, converted to local time.” That is pretty straightforward: night starts after evening civil twilight. Where the confusion is introduced is subsection 2 of section N of paragraph 3-147 which states that the inspector in charge (IIC) should include a special provision that would “confine aerobatic demonstrations to altitudes above 500 feet AGL and below 5,000 feet AGL after official sunset.” It would appear that in one location, night is defined as the end of civil twilight, and yet, in another location night is defined as after sunset.
The FAA has agreed that the language is unclear and vague. They have committed to issuing internal notices clarifying that night performances begin at the end of civil twilight, and ICAS will be working closely with them to insure that this information is consistently applied. Please contact Dan Hollowell at the ICAS office if you have any questions.
