The General Aviation Manufacturers Association (GAMA) made waves earlier in the month when it announced it disagreed with some aspects of the MOSAIC NPRM as written, and it was hard at  work on detailed comments to the FAA to outline its concerns. 

• READ MORE: GAMA Takes Issue With Aspects of MOSAIC

In the past, GAMA has often paired up with the Experimental Aircraft Association and other “alphabet” aviation groups in public comments and statements. 

The EAA submitted comments just ahead of the comment period’s close, in concert with the Aircraft Owners and Pilots Association, National Business Aviation Association, and the National Air Transportation Association.

The comments by and large support the proposed rulemaking as written, but do draw attention to particular points that could use extra consideration. It’s easy to find summaries of most of the salient points, but as a student of aviation whose journey has been marked by some of the particular economic forces that have put pressure on GA in my lifetime, the following point in the document drew my eye: 

The average age of general aviation aircraft is estimated to be nearly 50 years. Despite hours flown in single-engine piston aircraft being at their highest in at least a decade, the fleet itself is inexorably aging. Between 2012 and 2021, the total airframe hours of the average single-engine piston aircraft increased by 8.4%. New type-certificated aircraft remain stubbornly out of reach for most small flight schools and private operators, offering no immediate solution to this unsustainable trend. 

The FAA’s MOSAIC proposal, which expands the definition of aircraft allowed to meet design and production standards set by industry consensus standards rather than prescriptive FAA regulations, is a key component in reversing this trend. This approach has brought certification costs down to the lowest practical level for factory-built aircraft while maintaining a high level of safety, as demonstrated over the past 20 years. 

At somewhere between half a million and $1 million—or more, in some cases (depending on whether you’re looking at a Cessna or, say, a Diamond), most new, OEM-produced four-seat aircraft are out of my reach financially. I think this is true for most of the general aviation community—and it certainly is for me. The primary market for these new GA piston aircraft is flight schools—and typically only flight schools with the financial resources to offset that cost with higher income. 

And as the associations’ comments note further into the document, the proposed MOSAIC changes could mean good things for flight schools in particular, because “Most aircraft used for training and rented by fixed-based operators are four-seat models, demonstrating the need to expand the category. Having two additional seats in larger, more capable light sport aircraft would aid market desirability. Many existing flight schools utilize the ‘Gemini’ method of flight training, whereby two students are partnered and always observing one another during the conduct of a lesson.”

But what about individual private pilots, who won’t necessarily want to move on to aviation careers or advanced training? With the average individual annual income in the U.S. falling at just under $60,000, the cost of a new flying machine is currently anywhere from seven to 14 times that mark. Five decades ago, a new airplane was somewhere between $12,000 and $50,000, and the average salary in 1978, a banner year for GA aircraft sales, was $15,060. You begin to see the gap here, and suspect this might have something to do with why fewer of us can indulge in a new airplane like our parents or grandparents. 

How did we get here, and can MOSAIC really help? 

The answer to both is, it’s complicated. While 1978 was an unprecedented year for aircraft sales, with roughly 18,000 new airplanes moving into hangars across the country, there was trouble brewing on the horizon that foreshadowed the decline of the industry in the ’80s. 

There were some landmark lawsuit cases against OEMs beginning in the 1960s that set legal precedents for litigation directed at manufacturers when something went wrong with GA aircraft. By the 1980s, the aviation world was mired in liability suits.

At the time, GAMA and other associations pointed to product liability lawsuits as the deciding factor in the rise of costs, and the groups’ lobbying efforts eventually led to the 1994 General Aviation Revitalization Act, which limited product liability for manufacturers to 18 years. This helped OEMs secure insurance (insurers had been withdrawing business across the industry due to these lawsuit issues) and resume manufacturing and marketing with some confidence. 

And yet, the resource-cost gap for the average pilot has continued to widen—even in today’s used aircraft market. To some degree, that’s accounted for by smaller flight school’s demand for more affordable aircraft, which adds competition to the market for some of those 40 or 50-year-old machines. But, why didn’t GARA have its intended effect—assuming that was to bring the GA market share for individual buyers back up to the glory days.

In 1995, a couple of researchers, Lawrence Truitt and Scott Tarry, asked similar questions in an in-depth study for that year’s June issue of the Transportation Journal, American Society of Transportation and Logistics, Inc. Their article, The Rise and Fall of General Aviation: Product Liability, Market Structure, and Technological Innovation, pointed out that the factors affecting GA economics were more nebulous and complex than the litigation legislation could account for. 

They pointed to the oil crisis of the 1970s, the general recession of the 1980s, the increased longevity of existing airframes, and even a training boom among veterans brought on by the looming threat of losing primary flight training GI benefits. 

The economic and political landscape holds some uncanny similarities to today, with pressures coming from the post-Colgan Air crash legislation, which raised flight training hours needed for airline transport certification (and has something to do with the flight school pressures on the used aircraft market in particular), several recent economic downturns, fluctuations in oil prices, and the lingering effects of a pandemic that affected supply chains and parts prices globally. 

Can MOSAIC help revitalize GA airspace, which accounts for somewhere around 5% of our nation’s GDP? Well, as these associations point out—it looks hopeful. There’s significant potential for some reduced pressures on OEMs and the certification process. There’s increased potential for aviators to participate in this economy on an individual scale. Assuming the FAA carefully considers the full potential impact of its proposal, the future for GA could be very bright indeed. 

I, for one, will believe it when I see it. 

The post My Take on MOSAIC, as Our Comment Window Closed appeared first on Plane & Pilot Magazine.

The world’s largest group representing aircraft manufacturers says it has what appear to be some fundamental 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 sister publication AVweb Thursday, January 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 certificates 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 on January 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.”

Editor’s Note: This story originally appeared on AVweb.

The post GAMA Takes Issue With Aspects of MOSAIC appeared first on Plane & Pilot Magazine.

The FAA has announced a 90-day extension for the comment period on its Notice of Proposed Rulemaking (NPRM) titled Modernization of Special Airworthiness Certification (MOSAIC), according to an Aircraft Electronics Association (AEA) press release.

Originally published on July 24, MOSAIC aims to revise regulations governing the manufacture, certification, operation, maintenance, and alteration of light sport aircraft (LSA). 

The proposal’s primary goal is to enhance safety, performance, and privileges under sport pilot and LSA rules, with a focus on suitability for flight training, limited aerial work, and personal travel.

The NPRM, as published in the Federal Register on July 24 (88 FR 47650), originally had a comment period set to conclude on October 23. With the extension, interested parties now have until January 22 to provide feedback on the proposed changes.

• READ MORE: A MOSAIC Q-and-A

This move comes in response to a formal request from several aviation organizations, including the AEA, Aeronautical Repair Station Association, Aviation Suppliers Association, Aviation Technician Education Council, Helicopter Association International, International Air Response Inc., Modification and Replacement Parts Association, and the National Air Transportation Association. These organizations jointly submitted the request on August 29, expressing the need for additional time to thoroughly review and assess the extensive amendments proposed by MOSAIC.

While much of the public’s attention has been drawn to the potential expansion of sport pilot privileges and the increased weight and performance allowances for LSA, organizations like AEA are concentrating on four key areas that may affect its member companies and employees. These are continued operational safety, limitations on modernization and upgrades, personnel, and repetitive rulemaking.

The FAA’s decision allows the public and relevant organizations to more thoroughly identify inconsistencies, duplications, or unintended consequences that may arise from the proposed changes. 

• READ MORE: Your MOSAIC Study Guide

This extension also underscores the importance of engaging industry stakeholders and the public in shaping the future of LSA regulations. This opportunity to provide valuable insights and feedback on the MOSAIC proposal ultimately contributes to the ongoing process.

The post FAA Extends MOSAIC Comment Period appeared first on Plane & Pilot Magazine.

If you haven’t been paying attention, MOSAIC is an acronym for a regulation that affects all aircraft with special airworthiness certificates. Aircraft built by Cessna, Piper, Cirrus, Diamond, and others instead have standard certificates and are not touched by this MOSAIC regulation. In contrast, all LSA, experimental amateur built airplanes, and warbirds have special certificates.

If you already know enough, here are some helpful links:

• Download USUA/LAMA MOSAIC NPRM study guide version 1.0, a PDF document with bookmarks and helpful organization
• Article on using the study guide
• Make a comment on the FAA’s comment page
• Read what other commenters have said on the FAA comment page

The Clock Is Ticking

The FAA offered 90 days to comment on their proposal, which started out as 318 pages of text that no one would call fun reading. For a couple of weeks, most people in the industry hardly had time to look at it. Now time is starting to grow short.

It is possible to request an extension, but of course, that will simply add time to the end, delaying the new rule’s release. Pilots would have to wait longer for its benefits.

• READ MORE: Your MOSAIC Study Guide

On the other hand, while portions of MOSAIC are like Christmas in July, other sections stimulate questions, big and small. The document is only a proposal. It will change. Your comments could help move it in a direction you wish, but you have to comment to hope for an improvement.

The rule can be divided into two main parts: airplanes and pilot certificates, plus operating limitations—including maintenance. The former is like “Christmas in July” with many capabilities that industry and pilot member organizations have sought. The latter describes who gets to fly and maintain these MOSAIC LSA and under what rules. This section inspires more concern; some of this you can pick up from the nearby charts but learning more will take additional study and some discussion.

Please Attend if Possible

I will be presenting two talks on MOSAIC at the Midwest LSA Expo 2023, one on Friday September 8 at 11 a.m. and one at Saturday September 9 at 11 a.m.. Different people attend on different days, said airport manager Chris Collins, so he requested the presentation twice. I’m happy to do so as I am keen to hear what pilots think of MOSAIC.

In this article are included the most informative slides in that presentation. These represent the essence of what many pilots are seeking. I hope they will help your understanding.

To gain extra knowledge by hearing more detail, I encourage you to either come to the presentation or view the video on my YouTube channel; I will get it ready as quickly as possible. It should only take a few days — we don’t have many left.

At my talks, me giving you my views of what’s contained in MOSAIC has value, I trust, but the more important thing that should draw you to the show in person is to ask your own questions and hear those other people ask. Honestly, your opinion is what matters most.

The document is large and not particularly enjoyable reading. Nonetheless, we have tried to make it somewhat easier digest with the USUA/LAMA study guide. I recommend you find elements of it that are meaningful to your enjoyment of flying and comment on them. Don’t try to assess the whole thing.

Or, at least express yourself if you are dissatisfied with the product the FAA offers. While I urge you not to rant, you can most certainly offer constructive criticism, but that will be most effective if you include a possible solution. That will not be possible for everybody, but some of you will be inspired in various ways, and I hope you’ll all give it a shot.

Now that I’ve given you some fascinating thoughts for the weekend I hope you’ll spend a little time because, folks, we’ve only got 50-some days left before the FAA goes back into their huddle to assess the comments and make changes. …tick, tock!

The post The MOSAIC Comment Window Is Half Gone appeared first on Plane & Pilot Magazine.