Public Comments Now Accepted Through 22 January 2024
The Federal Aviation Administration has added an additional ninety-days to the comment period germane to the Notice of Proposed Rule-Making (NPRM) titled Modernization of Special Airworthiness Certification (MOSAIC).
Originally published in the U.S. Federal Register on 24 July 2023, the MOSAIC NPRM comprises proposed amendments to rules pertaining to the manufacture, certification, operation, maintenance, and alteration of Light-Sport Aircraft (LSA).
The FAA, by way of the proposed amendment, seeks, ostensibly, to actualize enhancements to the safety and performance of Light-Sport Aircraft while broadening the privileges of Sport Pilots. If enacted, MOSAIC would affect, in part, flight-training, aerial work, and personal travel undertaken in Light-Sport Aircraft.
The comment period for the MOSAIC NPRM (published at 88 FR 47650) has been extended from 23 October 2023 to 22 January 2024.
On 29 August 2023, eight industry organizations prevailed upon the FAA to grant a ninety-day extension to the original MOSAIC NPRM comment period. Subject organizations included: the Aircraft Electronics Association; the Aeronautical Repair Station Association; the Aviation Suppliers Association; the Aviation Technician Education Council; the Helicopter Association International; International Air Response, Inc.; Modification and Replacement Parts Association; and the National Air Transportation Association.
The MOSAIC proposal’s claimed purpose is to expand the type and number of vehicles eligible for future certification as Light-Sport Aircraft, and to broaden the authority and privileges currently afforded Sport Pilots.
While the larger aviation press’s coverage of MOSAIC has focused primarily upon Part 21: Certification Procedures for Products and Articles and the expansion of the aircraft eligible for future certification as a LSAs; and Part 61: Certification: Pilots, Flight Instructors, and Ground Instructors with the expanded authority of a sport pilot—the proposed rule affects 14 CFR Parts 1, 21, 22, 36, 43, 45, 61, 65, 91, and 119.
Obfuscated by the din of celebration with which MOSAIC was initially greeted are changes to Part 1, which directly affects the entirety of Civil Aviation’s sectors—to include airports and FBOs; the establishment of Part 22, which sets the certification foundation for all future consensus standard-based aircraft certifications; the expansion of the environmental standards applicable to the initial certification and modification of all Light-Sport Aircraft; changes to Parts 43 and 45; significant changes to Parts 61 and 91—which pertain to pilot certification and flight operations respectively; a change from a prescriptive hour-based approach to qualifying LSA repairmen to a performance-based approach more consistent with certificated mechanics; and the introduction of commercial space to Part 119.
Notwithstanding the degree to which the larger parts of the aviation industry, media, and flying public have cottoned to the expansions proposed under MOSAIC, the legislation’s critics—to include the entirety of the aforementioned organizations—urge increased scrutiny of the extents to which MOSAIC stands to adversely impact operational safety and the modernization and upgrading of Light-Sport Aircraft, complicate airman certification, and occasion repetitive rulemaking.
MOSAIC is a tortuously complex proposal eminently and urgently deserving of thoughtful and thorough review. The AEA encourages stakeholders to submit comments pertaining to MOSAIC as early as possible for purpose of affording the FAA opportunity to consider public opinion, and time to amend the proposal in a manner beholden thereto.
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