Regulatory Alert: AAAE Submits Comments on Draft FAA AIP Handbook

August 18, 2026

Yesterday, AAAE submitted comments in response to the Federal Aviation Administration’s (FAA) draft 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.

In our comments, AAAE generally supported the FAA’s goals to clarify, streamline, and delegate decision-making in the AIP Handbook. However, we raised concerns regarding the lack of a summary of changes, potential review delays due to FAA field office understaffing, and the need for further streamlining. AAAE recommended that the FAA provide a summary of changes and educational outreach for airport sponsors, ensure adequate field office staffing, establish deadlines for project reviews, and provide sponsors with an appeal option for field office decisions. In addition, AAAE urged the FAA to streamline grant requirements by eliminating or relaxing “actual need” and justification requirements for entitlement grants, limiting field office authority for benefit-cost analyses (BCAs), and removing new restrictive justification rules for primary runway rehabilitation and reconstruction projects, among other things.

You can read our comment letter here, which includes many additional detailed comments in the attached spreadsheet. We appreciate everyone who reviewed the draft document and provided feedback to AAAE. In case your airport has additional feedback for the FAA, this afternoon, the agency announced a brief extension to the deadline for providing feedback on the draft AIP Handbook. You may now submit comments until Monday, August 31.

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.

Summary of Draft AIP Handbook. FAA has not released any summary of changes to the current AIP Handbook, which has made it more difficult for industry to assess the significance of the revisions. At a high level and based on our review, FAA made meaningful efforts to improve the readability of the document, including helping sponsors understand requirements for projects to be funded, and incorporated changes made to the program by Congress through the 2018 and 2024 FAA reauthorization laws. In addition, while FAA made several processes more efficient, the agency also included some new justification requirements for certain projects.

Overview of AAAE’s Comments. In our comment letter, AAAE urged the FAA to take the following actions, among others, to simplify AIP processes, improve the usability of the document, and ensure the agency’s stated objectives for the handbook are accomplished:

The FAA should (a) provide a summary of changes made in the draft AIP Handbook and an opportunity to comment on the changes and (b) educate airport sponsors on specific changes that the FAA adopts in the final document.
The FAA should eliminate or relax its requirement that airport sponsors demonstrate an “actual need” or justification for each proposed project before an AIP entitlement grant may be awarded. At the very least, the FAA should simplify determinations that certain types of projects have the necessary justification and an actual need.
The FAA should (a) limit the authority of field offices to require a BCA for “any” project, as proposed, and (b) increase the threshold that determines when a BCA is required for a project.
The FAA should provide increased flexibility, discretion, and decision-making authority to FAA field offices to accelerate reviews, and airport sponsors must be given an appeal option in case that discretion is abused or applied inconsistently.
The FAA must ensure adequate staffing levels in its field offices commensurate with increased responsibilities so that the handbook’s objectives are achieved.
The FAA should adopt the proposal to allow self-certification of eligible costs for terminal projects without limiting this self-certification option to projects that use $10 million or less in PFC revenue.
The FAA should eliminate the new justification requirement that only allows AIP funding for reconstruction or rehabilitation of a primary runway if the runway is within 120 percent of the runway length needed by the airport’s “critical aircraft” (unless a specific exception applies).
The FAA should eliminate the new noise exposure map (NEM) annual certification requirement as a condition of receiving a grant for a noise mitigation project and address other questions regarding required documentation to obtain a grant for these projects.
The FAA should (a) set deadlines for its field offices to complete the various reviews associated with AIP grants and (b) provide airport sponsors with the expected review duration for each type of approval.

What’s Next? FAA will review and adjudicate the comments that the agency received in response to the draft AIP Handbook. FAA has informed AAAE that the agency intends to release a final version of the AIP Handbook by the May 2027 deadline set by Congress. AAAE will continue to engage with the FAA as we move towards a final document and keep you posted of any additional updates.