EAA Submits Comments on Task-Based Phase I Proposal

May 6, 2021 – Last week EAA filed comments on the FAA’s draft proposal to create an optional Task-Based Phase I program for experimental amateur-built aircraft flight testing. Overall, EAA is excited for the rollout of the program, which would allow aircraft builders to replace the rigid time requirements for flight testing with a list of tasks to complete in order to develop data and procedures for the aircraft. This would be an option for aircraft builders, not a requirement.

The task-based program is housed in an upcoming revision to Advisory Circular (AC) 90-89B, the Amateur-Built Aircraft and Ultralight Flight Testing Handbook. EAA’s comments were mostly technical in nature and focused on organizing the document to reduce confusion between the task-based program requirements and the rest of the handbook, which contains general advice on flight testing and is not directly related to the parameters of the alternate Phase I program.

Additionally, EAA pushed for a pathway to adopt requirements for other types of aircraft to use Task-Based Phase I. The current program — and the EAA Flight Test Manual — is written primarily for testing airplanes. EAA also took the opportunity to suggest technical edits to other sections of the AC, which was originally written several decades ago as a partnership between EAA and FAA.

Anyone following the EAA Flight Test Manual will be able to complete the proposed task-based program with ease. Other writers, groups, manufacturers, and even individual builders will be able to develop their own test plans that meet the requirements of the AC, and include the basic tests that any new aircraft should undergo.

The requirements are designed to validate the safety and performance of the aircraft, develop pilot familiarity and proficiency, and create data that can be used to build an operating manual for the aircraft. EAA suggested in its comments that this manual be termed an “Aircraft Operating Handbook” (AOH) to reduce confusion with similar terms for the manuals that are associated with type-certificated aircraft and the specific regulatory requirements that come with them.

EAA expects a final version of this AC to be released in the coming months, and is currently working on improvements to the EAA Flight Test Manual and creating associated guidance to make task-based flight testing even easier as the program is rolled-out.