Legal Interpretations
Culver-IslandAir 2011
Summary
The Question
What does the term "recommended" mean as it appears in FAA Order 8900.1 (FSIMS)?
Background
Island Air Charters asked the FAA Office of the Chief Counsel to interpret the term "recommended" in FAA Order 8900.1, an internal Flight Standards order that directs the activities of FAA aviation safety inspectors.
The FAA’s Interpretation
The FAA declined to decide because legal interpretations generally address questions about the regulations in Title 14 of the Code of Federal Regulations, and this question concerned established internal FAA policy. The FAA referred the company to the General Aviation and Commercial Division to discuss its understanding of how the policy applies to the company's situation.
- Requester
- Culver
- Organization
- IslandAir
- Issued
- February 15, 2011
- Subject
- Air Carrier & Commercial Operations
Page 1
U.S. Department
ot Transportatton
Federal Aviation
Administration
FEB 15 ·2011'
David J. Culver
Vice President.& General Manager
Island Air Charters
l050 Lee Wagener Blvd.
Suite 102 & 104
Fort Lauderdale, FL 33315
Dear Mr. Culver,
Office of the Chief Counsel 800 Independence Ave., S.W.
Washington, D.C. 20591
This is in response to your letter requesting a legal interpretation of the term "recommended" as it appears in FAA Order 8900.1, Flight Standards Information System (FSIMS}.
FSIMS is an internal order, maintained by the Flight Standards division of the FAA, that "directs the activities of aviation safety inspectors (ASis) responsible for the certification, technical administration, and surveillance of air carriers, certain other air operators conducting operations in accordance with the appropriate part of Title 14 of the Code of Federal Regulations (14 CFR), certificated airmen, and other aviation activities. This order also provides direction for tasks related to aircraft accidents and incidents, investigations and compliance, the aviation safety program, administrative areas, and miscellaneous tasks not related to a 'Specific regulation. In addition, it contains regional and district office requirements for the support of AS Is responsible.for those activities." FSIMS 8900. l 1-1. Legal interpretations are generally issued to address questions regarding the regulations found in.Title 14 of the Code of Federal Regulations (14 CFR). Because your issue specifically addresses established internal policy, a legal interp"retation is not appropriate at this time. You are welcome to contact the General Aviation and Commercial Division at 202-267-8212 to discuss yolir concern and ask for their understanding of the policy as it applies to your situation. · I hope this information has been helpful. If you have further questions concerning this response, please contact Sabrina Jawed on my staff at 202-267-3073.
Sincerely,
~/.&,_ft!~ ·
Rebecca MfcPherson ·
Assistant Chief Counsel for Regulations, AGC-200
Snapshot retrieved August 6, 2026.