FAA memo returns airport flexibility in flight testing

Experimental aircraft in Phase I flight testing, per FAA Order 8310.2J, were limited to specific airports. The latest version (2K) restricted testing to one airport, but allowed a second with a valid safety justification.

And now FAA memo AIR-600-GM17 overturns 8310.2K’s single airport restriction, according to officials with the Experimental Aircraft Association (EAA).

“EAA appreciates the FAA’s action in responding to our feedback and reversing this change,” said Tom Charpentier, EAA government relations director. “Needlessly limiting airports during flight testing is detrimental to safety and the flight testing process itself.”

Order 8130.2 sets policies for issuing airworthiness and export certificates, plus special flight authorizations.

Phase I Flight Testing

Phase I flight testing is the initial operational period for an experimental amateur-built aircraft after certification under 14 CFR § 21.191(g). It ensures the aircraft is safe for general use by requiring tests in a designated area. Pilots must follow FAA Advisory Circular (AC) 90-89C, which outlines structured test and safety guidelines.

Under the original Order 8130.2K, Phase I testing was limited to one airport. An exception allowed a second with “valid justification” for safety or a specific flight test, requiring FAA approval.

The FAA’s memo updates Operating Limitation No. 39: “This aircraft may only operate from [identify airport(s)].”

This change confirms multiple airfields can be listed without extra justification.

It applies to amateur-built aircraft and those with experimental airworthiness certificates under § 21.191(d) (Exhibition), (e) (Air Racing), (h) (Primary Kit-Built Aircraft), and (i) (Light-Sport Aircraft).