Aviation Groups Post Joint MOSAIC Comments

By
Russ Niles
-
Published: Updated:
15

Four major aviation groups have signed on to comments to the FAA that would tweak the Modernization of Special Airworthiness Certification (MOSAIC) Notice of Proposed Rulemaking (NPRM) to expand its benefits to recreational aviation. Monday was the comment deadline and EAA submitted the comments that were co-signed by AOPA, NBAA and the National Air Transportation Association (NATA).

The General Aviation Manufacturers Association said it was submitting its own comments, but as of our deadline they hadn’t appeared on the comment page of the NPRM. GAMA said earlier it supports the NPRM in general, including the ability of sport pilots to fly four-place aircraft, but some provisions “go beyond what was expected and require additional clarification and justification from the FAA.” It was to outline those suggestions in its comments.

As we reported earlier, EAA and its co-signatories are looking for a 3-knot increase in the maximum clean stall speed of MOSAIC aircraft to 57 knots, which would allow some of the most popular existing four-place aircraft to be included and give more flexibility to manufacturers considering new designs under MOSAIC. EAA also suggests that sport pilots be able to carry up to three passengers rather than limiting them to a single passenger while flying a qualifying four-seat aircraft, along with some other tweaks.

“All of EAA’s recommendations consider safety as the priority, while envisioning pathways to take full advantage of opportunities that MOSAIC can provide for increased growth and vitality of recreational aviation,” EAA CEO Jack Pelton said. More than 1,200 comments were posted to the NPRM site by late Monday.

Russ Niles
Russ Niles
http://www.avweb.com
Russ Niles is Editor-in-Chief of AVweb. He has been a pilot for 30 years and joined AVweb 22 years ago. He and his wife Marni live in southern British Columbia where they also operate a small winery.

15 COMMENTS

  1. Too bad self-serving LAMA, GAMA, AOPA, EAA, NBAA, NATA , Dan Johnson, and Roy Beisswenger couldn’t have STFU and let the simplest Vs and Vh increases with NO COMMERCIAL OR CFI CONTENT original proposal be enacted months or years ago and then lobbied FAA for their individual profit tweaks later while older pilots were happily and legally getting their last hundred hours in their beloved 172s while still able. Now there will be further months, if not years of delay before implementation while the FAA must wade through and deal with all their comments lacking any sense of urgency.

  2. Sorry… I was just reminded to also thank the Aircraft Electronics Association, Aeronautical Repair Station Association, Aviation Suppliers Association, Aviation Technician Education Council, Helicopter Association International, International Air Response Inc., Modification and Replacement Parts Association for keeping older pilots barred from legally flying solo in their beloved 172s for extra months, years, or forever.

  3. GAMA filed a comment, as did several of its members individually.
    Here’s GAMA: https://www.regulations.gov/comment/FAA-2023-1377-1317

    Excerpts – first the good news:
    “GAMA supports the key aspects of the MOSAIC proposal to increase the size, performance and scope of aircraft that can be flown by sport pilots and issuance of a special airworthiness certificate in the light-sport aircraft category with the objective of improving safety, functionality, innovation, and availability of small general aviation aircraft. However, there are areas of the proposal regarding new and complex design and expanded operations of light-sport aircraft which are not fully supported by operational safety data alone and require additional consideration and understanding on how FAA intends to implement with the appropriate mitigations for risk.”
    “In addition, GAMA believes FAA could more fully realize the intended objectives and benefits of this proposal by applying a consistent safety continuum approach across all small aircraft airworthiness and certification processes. This proposal highlights the safety benefits that flow from owners and operators having options to migrate from an experimental aircraft to a light-sport aircraft which is positioned higher on the safety continuum and, therefore, meets higher aircraft certification requirements. It is essential that FAA also ensure that owners and operators continue to have economical options to migrate from experimental and light-sport aircraft to type-certificated aircraft which are higher on the safety continuum and meet higher aircraft certification requirements. GAMA recommends that the FAA more effectively apply the safety continuum, which serves as the primary rationale for the MOSAIC proposals, to the type certification process of part 23 small airplanes and part 27 rotorcraft to ensure a level of certitude in rigor and burden appropriate for low-risk small aircraft as FAA has determined is appropriate in this rulemaking and to better enable the manufacture of safe and economical small type-certificated aircraft.”
    “- GAMA opposes FAA’s proposal to add new FAR part 36 noise requirements to…
    o Experimental aircraft. By definition these aircraft are not in compliance with published requirements and therefore all requirements and limitations necessary are defined within the experimental airworthiness certificate.
    o Light-Sport Aircraft Category.”
    “The FAA’s rationale and safety case for expanding light-sport aircraft in this NPRM are equally important to be applied to type certification processes for Part 23 airplanes in order to better realize the intended objectives and safety benefits.”
    “GAMA supports the MOSAIC proposal to expand sport pilot privileges to increase the size, performance and scope of aircraft that can be operated by a sport pilot.
    • GAMA recommends that the maximum stall speed be further increased to 58 knots CAS to better capture a broad range of specific airplane makes and models with very similar flight characteristics such as the Piper Archer which is just above 57 knots. This stall speed remains below that of primary category consistent with the safety continuum.”
    “GAMA supports the FAA’s proposal to increase the size of light-sport aircraft airplanes and allowing for an increase in maximum takeoff weight as this is the most significant constraint on current LSA and such an increase in size would enable safety enhancement and robustness of design to support intended operations. We agree that the weight limitations in the definition of light-sport aircraft preclude many design and safety features and the ability to produce more robust airplanes. GAMA supports FAA’s proposal to remove a weight based limitation for light-sport airplanes and instead use a performance based stalling speed which indirectly limits maximum weight. GAMA Recommends that FAA consider an increase in the maximum stall speed for light-sport aircraft eligibility in section 22.100 for an airplane to 58 knots CAS to align with the recommended increase in stall speed for what airplane a sport pilot can operate. ”
    “GAMA supports the MOSAIC proposal to increase the scope of LSA aircraft that can be issued a special airworthiness certificate to include rotorcraft and powered lift as we agree that the opportunity and benefits of the light-sport category FAA explains in the preamble should be made available to other types of GA aircraft.”
    “GAMA recommends that FAA consider a maximum weight of 2,700lbs for rotorcraft which is consistent with primary category rotorcraft, and a maximum weight of 3,375lbs for powered-lift which reflects FAA accommodation for special features in other primary aircraft categories.”
    “GAMA recommends that FAA’s disposition of comments to the MOSAIC NPRM and determination of the final rule should seek consistency with the promulgation of the powered-lift SFAR final rule as these establish the baseline requirements.”
    “GAMA supports the proposal to increase the size, performance and scope of aircraft that can be issued a special airworthiness certificate in the light-sport aircraft category with the objective of improving safety, functionality, innovation, and availability of small general aviation aircraft.”
    “GAMA supports the FAA’s proposal in 91.319(c) for granting operating limitations to particular aircraft holding experimental airworthiness certificates to conduct operations over densely populated areas or in congested airways. ”
    “GAMA recommends in the section-by-section comments that FAA should be able to recognize the safety pedigree of experienced organizations and organizational capabilities to support the assessment of experimental aircraft and consideration for accepting appropriate operating limitations.”

    Excerpts – not so good
    “GAMA Recommends that FAA conduct a more detailed evaluation of safety assurance risks of design compliance and production conformance for each aspect of the proposed increase in the size, performance, capability, and operation relative to LSA operational data–and that FAA determine whether any limitations or additional requirements are appropriate in the interest of safety. Member companies offered various concepts and proposals on approaches FAA could consider, but there is not consensus across GAMA’s membership.”
    (GAMA offers suggestions for establishing additional “tiers” of LSA, similar to the existing 87kt threshold, for additional pilot training and endorsements. The issue here, for MOSAIC, would not be the proposed solutions, but rather the likely extensive time taken to study the issues GAMA wants addressed.)

    Excerpts – interesting (LSA is successful – why can’t Part 23 benefit from similar thinking?)
    “GAMA recommends that FAA establish a clear pathway with provisions for manufacturers of current type certificated aircraft that meet the definition of a light-sport aircraft to have the option available to design, produce, and certificate newly manufactured models (i.e. derivative) under part 22 and issued a special airworthiness certificate in the light-sport aircraft category.”
    “GAMA supports FAA’s proposal to establish criteria for simplified flight controls which recognizes that rapid advances are occurring in aircraft automation and flight control technology with pilot interfaces and flight controls that do not resemble those found in traditional aircraft cockpits…. This would facilitate the development of these important safety innovations and technologies by providing a certification path. This enables clear recognition of an aircraft’s safety capability so that it can be appropriately considered for flight training, pilot privileges and operations. ”
    “GAMA recommends in the section-by-section comments, proposed text for less prescriptive criteria for simplified flight controls that is more performance based and provides improved flexibility in terms of where technologies may evolve and the opportunity for future advancements.”
    “GAMA recommends that the FAA allow a sport pilot to operate a light-sport powered-lift that has been designated as having simplified flight controls consistent with the proposal for light-sport rotorcraft.”

  6. I posted a long comment but it’s awaiting moderation. TLDR:

    GAMA filed a comment, as did several of its members individually.
    Here’s GAMA: https://www.regulations.gov/comment/FAA-2023-1377-1317

    GAMA mostly supports the proposals, and many of the changes the pilots’ letter groups want, including higher Vs1 and opposition to the noise regs. However, they had some concerns about Sport Pilots possibly operating larger, faster, more complex aircraft. They didn’t have a consensus solution but said their members had suggested additional training requirements (endorsements) for SPs when operating more complex aircraft. This would presumably be an extension of the 87kt breakpoint already included in Sport Pilot regulations. The concern, for everyone else, is not the suggestion itself (in principle it seems not unreasonable) but the request that the FAA should “study” these issues: as we know, the “study” could take 20 years (no fault of the FAA, it has rules to follow).
    They also recommend that FAA revisit Part 23 and apply MOSAIC thinking to it. I think that’s a good idea. I wouldn’t like to see MOSAIC held up to wait for it.

  7. I posted a long comment but it’s awaiting moderation. I posted a shorter one, but it’s also awaiting moderation. Both included a link; let’s try without that. TLDR:

    GAMA filed a comment, as did several of its members individually.

    GAMA mostly supports the proposals, and many of the changes the pilots’ letter groups want, including higher Vs1 and opposition to the noise regs. However, they had some concerns about Sport Pilots possibly operating larger, faster, more complex aircraft. They didn’t have a consensus solution but said their members had suggested additional training requirements (endorsements) for SPs when operating more complex aircraft. This would presumably be an extension of the 87kt breakpoint already included in Sport Pilot regulations. The concern, for everyone else, is not the suggestion itself (in principle it seems not unreasonable) but the request that the FAA should “study” these issues: as we know, the “study” could take 20 years (no fault of the FAA, it has rules to follow).
    They also recommend that FAA revisit Part 23 and apply MOSAIC thinking to it. I think that’s a good idea. I wouldn’t like to see MOSAIC held up to wait for it.

  8. Einstein said that time is relative. There’s real time, government time and then FAA time, in descending order.

  9. Well … I was hoping a final rule might pop out at Airventure 2024 but … looks like it won’t happen in MY remaining lifetime 🙁 . All it’ll take to put the final dagger in the process is another Boeing debacle.

  10. Personally, I took the original summer 2023 MOSAIC NPRM along with its announced comment period in good faith at face value and honored it in that manner, with no staff I might add. Why could all of these aviation alphabets with their expensive staff cadres not have done the same? For the FAA to now accommodate the big name alphabets and aviation personalities in their MOSAIC delay tactics makes a mockery out of the entire NPRM and comment period process. With their collective wrench having been successfully been thrown into the works, the entire NPRM and comment period process has for me now been entirely invalidated. I frankly have been betrayed by the same lawful processes to which I committed myself by letter of law during my half century long professional aviation career.

    Good morning Oklahoma City! Shit or get off the pot! It is now more of an imperative than it is has ever been!

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