GAMA Has Issues With MOSAIC; Plans To Issue Comments To FAA


The world’s largest group representing aircraft manufacturers says it has issues with the Modernization Of Special Airworthiness Certification (MOSAIC) proposed rulemaking and will specify those reservations in comments to the FAA. General Aviation Manufacturers Association (GAMA) spokesman Andre Castro told AVweb Thursday (Jan. 11) that the trade group will not fully endorse the MOSAIC rule as currently written because the plans “go beyond what was expected and require additional clarification and justification from the FAA.” AVweb‘s sources said the main issue for GAMA is allowing Light Sport pilots to fly four-place aircraft. Holders of Light Sport certificate holders would, however, be limited to a single passenger.

MOSAIC is intended to broaden the scope of eligible aircraft while expanding performance and weight-based limits on the category. It’s considered a safety move by its proponents because it allows more margins of safety in aircraft available to those with so-called “driver’s license medicals” and more flexibility for creating new designs of light aircraft. The comment period for the NPRM ends Jan. 22. GAMA’s full statement to AVweb follows:

“The GAMA team is currently working across our broader membership to develop collective comments and recommendations in response to the FAA’s MOSAIC proposed rule which are due on January 22nd. Overall, GAMA supports the direction of key aspects of the proposal to increase the size, performance and scope of aircraft that can be flown by sport pilots and be issued a special airworthiness certificate with the objective of improving safety, functionality, innovation, and availability of small general aviation aircraft. However, there are areas of the proposal which go beyond what was expected and require additional clarification and justification from the FAA. In addition, GAMA believes the FAA misses a significantly important opportunity to fully realize the intended objectives and benefits of this proposal by not applying a consistent approach across all small aircraft airworthiness and certification processes. Our submission will go into further detail on these issues.”

Russ Niles
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.


  1. It is long past time for LAMA, GAMA, Dan Johnson, Roy Beisswenger et al to STFU and let at least a simplified or partial version of MOSAIC be implemented RIGHT NOW to permit driver license flying of more and safer makes and models of aircraft within the just proposed Vs and Vh limits that will benefit 99% of pilots. Instead, these lobbyists have dragged out meetings about SP with the FAA for a DECADEv trying to add commercial operations, gyrocopters, banner tows, dumb down instructor requirements and protect profits. Meanwhile, thousands of senior pilots have died waiting for the simple ability to legally continue to fly their fixed wing fixed gear fixed pitch pride and joy day VFR without having to face the kind of medical that must be rigorous enough to cover late night multi engine IFR operations.
    Let my people go fly you selfish heartless profiteers and once the basic OK is law you can monkey with the rest all you want.

    • Well said. GAMA’s motivation in waiting till the end of the extended comment period is shamelessly transparent.

    • Your including Dan Johnson on that list is idiocy. He is probably the biggest advocate for changing the rules for light sport flyers. Mosaic has a whole list of great changes, and I think a majority of them are going to get passed due in great part to Dan Johnson. The reality of adding four passenger planes to light sport pilots license, is directly because of people like Cessna, piper, etc. It will help them sell more airplanes. And I don’t really care. My light Sport plane is 5 times more advanced that some 152 or 172. But what I do care about as a light sport pilot, is getting stupid things like the weight limits, constant speed props, night flying, and the ridiculous speed restrictions removed. Telling people to shut up and not get this thing done, is counter productive. Now that they’ve gone this far, what do we want to do, wait, another 10 years for the changes that should have been done years ago? Your motivation is for YOU. I agree, you should still be able to fly, but cutting off the legs off good changes for the sake of some old guy being able to take his relic up is bad business overall. Making negative comments this far in is suicide. I do agree with the non-important stuff they’ve included but, our pathetic Government will scrap it and start over. You’ll be dead by the time the changes happen.

      • Agreed. I am grateful for what we have- but something is messed up when I am blessed to fly a J-3 Cub but not the ‘heavy’ Cessna 120.

        I hope the perfect doesn’t become the enemy of the good, here.

  2. I concur with Wise OldMan. Some years ago, I had a reason to contact GAMA. I wrote a nastygram email to them moaning about a position they took and — next thing I know — I’m getting a call from a GAMA European rep in Brussels. Ya’ll should have heard the “oral gratification” he was giving me on the subject du jour.
    GAMA has no interest in Light Sport and would likely be happy to see it go away. And the LAMA (LAMADINGDONG) guy has absolutely no interest in including legacy 4 place airplanes in the light sport rules because he’s protecting the current light sport manufacturers. So yes … both organizations ought to shut up and be happy that more older pilots might be retained and maybe more NEW pilots might be minted as a result of MOSAIC. Neither organization is smart enough to recognize that, sadly. BE QUIET!
    I strongly recommend every pilot who has an interest in MOSAIC in its current NPRM form or in slight modification form to make their position known to the FAA ASAP. The deadline is 10 days away today. EAA just released a talking paper on how to address the issues:

    Read it and comment, folks!

  3. This is pure cronyism on display. Suggest the situation with pleasure boats is considered. Kids too young to drive and folks over 80 compete in large sailboats much heavier than four-place aircraft, and no one worries.

  4. I don’t agree that right now is the time to be telling any group to be quiet. THIS is the public comment period, and it ends on Jan 22. I think right now is exactly the time when anybody with a comment should make it. We can tell them to shut up on the 23rd. If you disagree with any public comment on the docket, you are welcome to make a countering submittal.

  5. And thus endeth MOSAIC… not with a bang, but with a greed-based whimper. Such things start with platitudes of safety and the greater good, but always seem to end as a hollow shell that only benefits the money makers.

    Does anyone really think the FAA will treat a reasoned comment from an individual with as much weight as an attorney written comment from GAMA?

    Just my 2 cents and I haven’t had my morning coffee.

  6. MOSAIC effects MUCH more than just Light Sport pilotage and aircraft categorization and certification. If implemented as written, significant changes to ten different CFRs will take place. Including parts 65 and 43. There is a lot in MOSAIC that is disguised by the spotlight on the LSA title.

  7. With the sound of oxen being gored in the background…did anyone think that the pressure groups would let this go by without an attempt to gut it like an 8-point buck?

    It doesn’t matter what the consumer wants or a century’s worth of data indicates…the bottom line of Textron, et al is what matters. That there is a revolving door between the FAA and the industry manufacturers and associations at the higher levels should be a way to forecast that what comes out of MOSAIC will be way different from what was proposed.

    Will we see 152/172/cheorkee/warriors/archers moved to a category that will allow for greater infusion into the ‘sport’ realm, acknowledging that most of the activities with those rides fit the definition of ‘sport flying’? Who knows? Not putting any bets on it…we (the pilot population) hve been left at the altar too many times (remember, we only got Basic Med because it was written into law after Oak City’s foot dragging on real medical reform went on for decades in the face of medical evidence to the contrary, and proven for the most part since ’17) to hope too much that the MOSAIC bride will come down the aisle.

  8. So, how long has sport pilot been working perfectly? A long time already. There have been no losses, fatal, or serious injuries that can be DIRECTLY attributable to Basic Med, Light Sport or anything else that would render MOSIAC untennable. It seems rediculous for GAMA to oppose implementation (even if in phases) with absolutely zero statistical evidence. I someone can obtain PVT or with higher licenses and ratings, what exactly is the objection? We in the GA world don’t operate in the same flight regimes as corporate and pose no threat to ‘your’ airspace. The same rules of basic airmanship should apply to all under MOSIAC

  9. The FAA has a well-worn “POUND SAND” stamp they can and have placed on any comment regarding a Reg, AD etc. Ask the many Cardinal Owners who have been forced to unnecessarily dismantle their airplanes against their objections. The FAA doesn’t need GAMAs approval to pass a rule, just the will to do the right thing. Their record on that is not so well worn.

  10. Bryan has an important point. Depsite years of “working on it,” we only got basic med when Congress intervened with a deadline to do it — and at that, FAA still broke the deadline. I am far from convinced that this will be any different. FAA routinely drags their feet and gets “credit” for making progress on something important. This proposed regulation is way too comprehensive on topics covered and too complicated. I dont expect we will see MOSAIC on the forecasted calendar. An this is exactly what the agency needs to justify delays in finalizing. I liken it to Congress’s use of Omnibus Appropriations bills: 1/ avoids the work of doing separate bills and working out details, 2/ way too many corners and wrinkles to hide sacred cows. 3/ many controversial issues hidden in “all or none, take it or leave it” packages. Bona fides: said from the perspective of a now-retired federal agency regulation writing attorney from a different department.

    • Michael Huerta … SLOWLY I TURNED … step-by-step … inch-by-inch … listening to him SPEW about medical reform at Airventure year after year. All of us have Sen. Inhofe to thank for Basic Med … NOT the goons at 800 Independence.

    • Nice. You put this image in my mind of an SNL style comedy skit where a guy comes back from giving a speech about the great strides made in the arduous process of changing the processes to a bunch of people in an old government office sitting around wasting time. They then congratulate him on his lines and make jokes about how long it will take and whether they should double their output by actually working two hours a day! They then break into laughter and go back to wasting time.

  11. I support MOSAIC as proposed and will probably fly under these rules some day. I have read the NPRM. GAMA’s effort to thwart progress is shameless. Please respond to the NPRM with a letter of support.

  12. I’m already a Sport Pilot with my own planes so as long as it doesn’t change my ability to fly them It’s OK with me. I fly for fun, not for money and do it by the Hour, not by the Mile.
    I waited 10 years for what Light Sport is NOW.

  13. Perfect for one lobbying group is the enemy of good for all of us.

    Impressive the FAA is willing to take MOSAIC even this far. Let’s take the win and move forward.

    GAMA can do what EAA did under BasicMed… offer free STC to remove the aft seats to keep 4 place plane under LSA piloting category.

  14. And, always remember this :

    General Aviation Manufacturers Association – AOPA
    Nov 15, 2023 · GAMA represents aircraft producers and related businesses and works with AOPA and other groups to promote aviation-friendly policies at the national level.

  15. As long as the FAA is going to mostly ignore private GA and leave the real regulation of the industry up to the insurance companies, nothing viable will come out of the NTSB or the aviation industry dues collector organizations. We’ll get a lot of verbiage from the paycheck collectors. We’ll get more regulations that are contrary to aviation safety and training, such as the regulation against using non-standard airworthiness aircraft for flight traing. Don’t expect anything meaningful from a government agency that even figure out what fuel to use in recip engines.