Not according to the FAA. Phase 1 requires letters of intent for lease or purchase of aircraft & facilities. For Phase 3 you do need an aircraft to perform the mini-evacuation demo. Terminal space or facilities are never inspected or evaluated at any point in the certification process. http://fsims.faa.gov/wdocs/8900.1/v10%20air%20trans%20over%20sys/chapter%2006/10_006_002.htm