Regulatory Alert: FAA Requests Comments on AIP Handbook Update
July 16, 2025
Today, the Federal Aviation Administration (FAA) requested comments from industry stakeholders on recommended changes to the agency’s Airport Improvement Program (AIP) Handbook, which is also known as FAA Order 5100.38D. Specifically, FAA is seeking feedback on the current AIP Handbook ahead of a draft handbook that is expected to be released for formal comment sometime before May 2026. In a message today, the FAA Office of Airports emphasized they are interested in hearing the airport industry’s “ideas on areas of interest, opportunities for workload reduction for airports, and overall handbook structure.”
FAA has requested that AAAE and other trade associations consolidate feedback on behalf of their members and submit comments no later than Wednesday, August 6. We encourage airport sponsors to take advantage of this opportunity to weigh in early in the process and before FAA begins its update to the handbook. To compile feedback, we have developed a spreadsheet template that your airport can use to document and share recommended changes with AAAE. You can find the spreadsheet here. If you have comments, we ask that you please email a completed spreadsheet to Justin Barkowski (justin.barkowski@aaae.org) or Megan Eisenstein (megan.eisenstein@aaae.org) no later than Monday, August 4.
Background. The current AIP Handbook was originally published in 2014. While some updates were made in early 2019, the handbook still does not reflect changes made by the FAA Reauthorization Act of 2018. Last year, 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. With the FAA Office of Airports planning to begin those updates soon, the agency is soliciting feedback from industry stakeholders early in the process.
AAAE’s Recommendations on the AIP Handbook. Earlier this year, AAAE solicited feedback from our members to develop recommendations for the Trump administration to consider implementing as part of its agenda to advance “deregulation” and reduce the size of the federal workforce. The comments led to the development of our “Commonsense Recommendations for Regulatory Reform,” which we submitted to DOT and FAA leadership in March.
In our recommendations, we urged FAA to simplify the overly complicated AIP Handbook by (a) allowing AIP project eligibility questions to be determined by the statutory definition of “airport development” and (b) eliminating the “project justification” test the agency applies before funding projects under AIP. We will continue to push these specific recommendations, as we believe they would help reduce workload on FAA staff, reduce costs, and help streamline project eligibility questions.
What’s Next? We highly encourage airport sponsors to review the current AIP Handbook, download our spreadsheet template, and submit feedback and recommendations to AAAE staff no later than Monday, August 4. This is an opportunity to have your voice heard before FAA begins its first comprehensive update to the AIP Handbook in over a decade.
