Phase I can be a task-based flight test plan. The criteria is located on the attached pdf.
2.1.6.2 Expectations. The ability to use the task-based flight test plan as provided in this AC is enabled via the issuance of an operating limitation that allows its use, in lieu of the minimum 25- or 40-hour flight test periods contained in previously issued operating limitations. The FAA will permit the use of a task-based flight test plan based on your use of this AC and adherence to the objectives of the task-based flight test plan, providing the specified logbook entry, and maintaining the AOH on board the aircraft following flight testing. No formal FAA acceptance process is necessary for the builder to utilize a task-based flight test plan. Issuance of operating limitations with the traditional minimum hourly flight test periods specified for a pilot to flight test their aircraft as the sole occupant of the aircraft during Phase I remains for those who choose to do so in accordance with those operating limitations. There is no requirement to create, submit, or use a formal flight test plan. However, the FAA strongly encourages amateur builders to develop and utilize an individualized, comprehensive, requirements-based, operation centric (task-based) flight test plan appropriate for the complexity of the aircraft with specific tasks and objectives. The FAA also encourages builders to utilize the Additional Pilot Program (APP) described in AC 90-116, Additional Pilot Program for Phase I Flight Test. A task-based flight test plan should contain the minimum elements described in this AC, provide aircraft systems reliability and flight envelope testing to ensure that the aircraft is controllable throughout its normal range of speeds and throughout all the maneuvers to be executed, and ensure that the aircraft has no hazardous operating characteristics or design features. The FAA expects that builders follow their flight test plan, including those who utilize a task-based flight test plan. AC 90-89C
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