Regulatory Alert: FAA Releases and Requests Comment on Draft AIP Handbook
May 16, 2026
Yesterday evening, the Federal Aviation Administration (FAA) released a draft of the agency’s Airport Improvement Program (AIP) Handbook, also known as FAA Order 5100.38E, which provides guidance, policies, and procedures for administration of the AIP. According to FAA, the goal of updating the AIP Handbook was to clarify statutory requirements, eliminate redundancies, create an easily updated structure, increase opportunities for process efficiency, and delegate more decision-making to FAA field offices.
As of the time of this alert, FAA has not released any summary of key updates or changes, making it difficult to assess the significance of the revisions. However, based on our initial review, FAA made meaningful efforts to improve the readability of the document and make it easier for airport sponsors to understand requirements for projects to be funded. FAA also made several processes more efficient, such as providing FAA field offices with more authority and allowing self-certification when determining appropriate costs for terminal projects. In addition, FAA seems to have made some modest changes to AIP-related policies, such as relaxing justification requirements in certain cases. However, a more thorough review is necessary to fully understand the magnitude of the changes being proposed.
You can view the draft AIP Handbook here. FAA will accept public comments on the draft document until Monday, August 17. To develop AAAE’s response, we are forming a working group to help identify concerns and recommend changes to FAA. AAAE’s Planning Working Group will be hosting an initial discussion regarding the draft AIP Handbook on Wednesday, May 20, at 2:30-3:30 p.m. ET. You can sign up here to participate in the discussion and, if interested, our working group that will meet in the coming months to develop comments for FAA.
We highly encourage the appropriate airport staff to review the draft AIP Handbook and share feedback with us as we develop our comments and response to FAA. This will be an important opportunity to weigh in on the policies and procedures that govern the primary grant program used by airport sponsors for infrastructure development.
Background. The current AIP Handbook, which outlines FAA’s policies and procedures for administering the AIP, was originally published in 2014. While some updates were made in early 2019, the handbook still does not reflect changes made by Congress through the 2018 and 2024 FAA reauthorization laws. In 2024, as part of the FAA Reauthorization Act of 2024, Congress directed FAA to publish a draft update to the AIP Handbook by May 2026 and a final updated version by May 2027. The final version will be the first comprehensive update to the handbook in over a decade. Last year, AAAE staff had the opportunity to provide feedback to FAA as the agency began rewriting the existing AIP Handbook.
Summary of Materials Released. Yesterday evening, FAA released an unpublished Federal Register notice that provides a brief overview of the draft AIP Handbook and outlines the deadline for public comment. In addition, FAA posted each chapter and appendix in the handbook on its website here. A single document containing the entire draft AIP Handbook has not been published; however, AAAE has compiled the preamble, chapters, and appendices into a single document that you may view here. FAA has not released any documents summarizing the major changes or revisions, although the agency suggests one is forthcoming.
Key Takeaways from AAAE’s Initial Review. Based on our initial review of the materials released by FAA, we have several high-level takeaways to share:
- Streamlining the AIP Handbook: The draft AIP Handbook introduces a significant structural overhaul compared to the current version. The draft document has fewer pages (312 pages for the draft versus 586 for the current handbook), fewer chapters, and substantially reorganized appendices. The intent of the appendices was to ensure all the requirements relating to a specific type of project (e.g., airfield infrastructure) are contained in a single location for ease of readability. FAA also indicated the agency will soon make available an AIP funding tool that allows interested parties to understand how specific types of projects, at different types of airports, may be funded.
- Making Modest AIP Policy Changes: In our “Commonsense Recommendations for Regulatory Reform” document, AAAE advocated for FAA to eliminate, or scale back, the project justification test the agency applies before funding projects under AIP. While FAA retained justification requirements, the agency appears to have relaxed those requirements for some projects. For example, the eligibility of equipment beyond Part 139 standards currently requires an airport sponsor to meet a “significant safety requirement” and obtain approval from FAA headquarters. Under the draft handbook, ARFF equipment above the minimum requirements could be approved if an FAA field office determined it was necessary and the equipment would mitigate a safety concern.
- Implementing Process Efficiencies: While FAA’s primary focus appears to be making the AIP Handbook easier to understand, the draft update also streamlines some procedures to improve administration of the AIP. For example, FAA previously informed AAAE that one resource-heavy process has been determining allowable costs for terminal projects with both eligible and ineligible areas. (Costs are generally prorated using the ratio of eligible area to total area.) Under the draft handbook, FAA would allow airport sponsors—rather than FAA staff—to calculate and self-certify these eligible costs if the sponsor is requesting that FAA cover no more than 70% of the eligible costs for the terminal project.
- Incorporating Prior AIP Policy Changes: When Congress or FAA makes any changes to the AIP, FAA does not issue a new update to the AIP Handbook. The agency instead issues a Program Guidance Letter (PGL) that outlines a specific statutory or policy change to the program. Since the last iteration of the AIP Handbook was released, airport sponsors have had to rely upon dozens of PGLs to understand changes in AIP policies, especially following passage of the 2018 and 2024 FAA reauthorization laws. Each of the PGLs that have been issued since 2017 will be canceled upon issuance of the final AIP Handbook next year.
