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Photo from EAAThe comment deadline for the MOSAIC proposal is approaching and the EAA is speaking out in support and encouraging members and pilots to submit comments. The EAA submitted comments on behalf of its membership and issued a guide for members to submit their own, showing overall support while providing recommendations to enhance the proposal.
The Modernization of Special Airworthiness Certification Notice of Proposed Rulemaking was proposed in July 2023 and on Oct. 4 the comment period was extended. The NPRM proposed amending rules relating to the certification and operation of LSA, modernizing the regulatory approach to the light-sport category and including performance-based requirements to reflect any ongoing and future advances in technology and use for these category aircraft. MOSAIC was proposed to address the ongoing changes in the industry and the impending integration of new aircraft like eVTOLs. As the extended comment period comes to a close, the EAA developed a commenting guide to detail the areas of the proposal where the EAA shows support and those where recommendations have been issued.RELATED STORY:FAA extends MOSAIC comment period
The EAA said the proposal builds on two decades of positive experience with Sport Pilot and Light-Sport Aircraft and proposed expanding the definition and privileges of both. The organization sees the benefits in expanding the capability, size and scope of the aircraft that can be built using industry consensus standards and which aircraft can be flown using Sport Pilot privileges. The EAA is encouraging members to consider topics in the guide and submit their own, using personal experiences to support the proposal. The FAA needs to hear support from the community and the recommendations in the areas where the proposal needs improvement.
The guide reminds members that comments and suggestions supported by "thoughtful safety justifications" will have the most impact and a better chance of influencing changes to proposed rules. The EAA guide also notes that comments will have a greater impact if they are reasonable and within the rule's scope. The EAA recommends beginning comments with general statements for supporting and expanding LSA and Sport Pilot, pointing out several key points to expand upon.Recommendations in the guide include what is outlined in the FAA proposal, the EAA recommendation followed by its justification
Safety, as stated by the FAA in the proposal, is a crucial aspect of the NPRM. The NPRM is building on the safety record of current LSA and Sport Pilots, providing an opportunity to enhance safety. The increase in size and weight will continue to enhance safety by allowing pilots to operate familiar aircraft and encouraging the inclusion of safety-enhancing equipment. With current limitations, pilots are forced to choose between installing safety features like equipment and additional structures, while sacrificing handling characteristics, performance and useful payload to remain under the weight limit.
The rule will benefit flight schools and their ability to upgrade to newer aircraft with improved safety features and equipment. The MOSAIC ruling will improve safety and access to flight training and rental aircraft at many local flight schools. The ruling will create a basis for new aircraft entering the market, helping consumers, manufacturers, maintainers and airports. The new aircraft entering the General Aviation marketplace to further drive innovation, improve safety and lower costs.Read the EAA guide here
With expanded benefits to workforce development in aviation, the new ruling will provide entry pathways to pilot and aviation maintenance careers through the Sport Pilot and Light-Sport Repairman certificates. The ruling will allow for a larger range of flight training and aviation career opportunities across the country, growing the exposure of the aviation industry as a viable career path to more of the general public. MOSAIC will remove the existing boundaries to innovation through the expansion of the types of aircraft that will fit in the LSA category. The ruling will support both environmental and efficient developments. With the rule, the eventual certification of electric aircraft, rotorcraft and powered lift will solidify America's position as a world leader in general aviation. The EAA has also recommended members urge the FAA to finalize the rule swiftly.
The guide also outlines the various recommendations the EAA has made over the NPRM. The ruling proposes eliminating the current maximum takeoff weight limitation of 1,320 pounds and increasing Vs1 stall speed from 45 knots CAS to 54 knots CAS and the EAA supports the removal of a maximum takeoff weight but recommends increasing the stall speed to a minimum of 57 knots Vs1 and ensuring the FAA has the flexibility to consider additional safety enhancements like crashworthiness as a way to define the expanded LSA parameters. Other recommendations include supporting the increase in LSA seat counts, opposing the application of Part 36 noise certification requirements, supporting allowing Sport Pilots to fly with passengers to match the aircraft seat count and adding night operation privileges with certain training and experience requirements.Read the MOSAIC NPRM here
The EAA said its government team will continue to evaluate the proposal and formulate official comments. When the EAA's comments are submitted, it will continue its advocacy efforts as the FAA reviews public comments and continues the rulemaking process, contemplating changes to the proposal in the development of a final rule. The comment deadline is Jan. 22 and there is still time to submit yours.