special airworthiness certificates Archives - Plane & Pilot Magazine https://www.planeandpilotmag.com/tag/special-airworthiness-certificates/ The Excitement of Personal Aviation & Private Ownership Thu, 07 Sep 2023 12:22:33 +0000 en-US hourly 1 https://wordpress.org/?v=6.4.4 The MOSAIC Comment Window Is Half Gone https://www.planeandpilotmag.com/the-mosaic-comment-window-is-half-gone Thu, 07 Sep 2023 12:22:33 +0000 https://www.planeandpilotmag.com/?p=628072 MOSAIC was a subject of intense conversations at EAA AirVenture 2023 in Oshkosh, Wisconsin. Surprising many of us, the FAA released the notice of proposed rule making (NPRM) for MOSAIC...

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MOSAIC was a subject of intense conversations at EAA AirVenture 2023 in Oshkosh, Wisconsin. Surprising many of us, the FAA released the notice of proposed rule making (NPRM) for MOSAIC ahead of schedule. Lots of people who needed to study it were already en route to the EAA airshow for a week, 10 days, or longer.

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:

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.

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.

I have sought opinions and help digesting MOSAIC. LAMA’s board of directors has been reviewing the proposal and board member Phil Solomon invested time in his area of focus. Thanks to Phil for info leading to these charts. [Dan Johnson]

 

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.

The charts were made to be shown large. If they look too small to read, enlarge using your computer or device methods; they should read well. [Dan Johnson]

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.

Continuation of the previous slide [Dan Johnson]

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!

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How to Comment on a Proposed FAA Policy https://www.planeandpilotmag.com/how-to-comment-on-a-proposed-faa-policy Fri, 21 Jul 2023 13:04:03 +0000 https://www.planeandpilotmag.com/?p=627859 When a federal agency, such as the FAA, seeks public input on a proposed policy, providing a substantive comment is an essential way to voice concerns, offer suggestions, and contribute...

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When a federal agency, such as the FAA, seeks public input on a proposed policy, providing a substantive comment is an essential way to voice concerns, offer suggestions, and contribute to the policymaking process. With Modernization of Special Airworthiness Certification (MOSAIC) on the horizon, you may be looking to add your thoughts to the process but aren’t sure how to create a comment that will have the effect you want.

A well-structured and thoughtful comment can significantly impact an agency’s final decision. In this guide, we will explore the key components of making a substantive comment to the FAA, highlighting examples and offering dos and don’ts for effective commenting.

Dos for Making a Substantive Comment

Take Time to Understand the Proposal

Thoroughly read and comprehend the FAA’s proposal to grasp its objectives, implications, and intended outcomes. You can read the MOSAIC proposal and take notes on how it may impact your personal or professional role in aviation. 

Analyze the potential effects on safety, the environment, and industry. You may want to think about composing a comment that addresses a specific impact. Make notes that reflect your observations. Your note may not be your final comment, but you can use it to help construct the one you send to the FAA.

Example of a reflective note: “In the FAA’s proposal for implementing new air traffic control procedures, there is a potential impact on small airports and general aviation pilots, as they might face increased congestion and altered flight paths.”

Provide Specific Evidence and Data

When you’re ready to craft your comment, support it with factual data, research, and evidence to strengthen your argument. If you can, use statistics, studies, and case examples to back up your assertions and bolster your position. 

Example: “I recommend that the FAA review the recent study by XYZ research group, which highlights the safety benefits of the proposed runway extension at ABC airport.”

Offer Constructive Suggestions

If you are opposed to a potential rule or aspect of one, try to present viable alternatives or solutions to address concerns and improve the proposed policy.

Consider the feasibility and practicality of your suggestions.

Example: “Instead of imposing a blanket curfew on all flights, the FAA should consider implementing noise reduction measures for late-night operations at major airports.”

Be Clear and Concise:

Articulate your points in a well-organized and coherent manner. Avoid jargon or technical language that may confuse readers. Keep your comment short so that it can be quickly read and digested.

Example: “I strongly advocate for the FAA to prioritize the implementation of bird strike prevention measures at airports with a history of avian-related incidents.”

Don’ts for Making a Substantive Comment

Avoid Emotional Language

Refrain from using emotional or inflammatory language that may undermine the credibility of your comment. Focus on rational arguments and evidence-based reasoning.

Example of an emotional claim: “The FAA’s proposal is a disaster! It will destroy our neighborhoods and ruin our quality of life!”

Steer Clear of Generalizations

Be specific and avoid making broad, unsubstantiated claims that lack evidence.

Example of an overgeneralized claim: “This proposal will lead to disastrous consequences for the aviation industry.”

Don’t Rely on Form Letters or Boilerplate Phrases

While form letters can show collective concern, personalized comments carry more weight. If many commenters send the same text, those responses may be lumped together rather than considered individually. 

Customize your comment to include personal experiences or perspectives.

Example: “Although I support the general premise of the proposed air traffic control reform, I believe it should incorporate more considerations for rural airports like the one I operate.”

Avoid Confrontation

If you want to ensure your comment will be read and make an impact, it’s important to maintain a respectful tone, even if you disagree with the proposal or other comments. Promote a constructive and collaborative discussion.

Example: “While I understand the concerns raised by other commenters, I believe that we can find common ground by enhancing safety protocols and ensuring continued airspace access for all stakeholders.”

Engaging in the rulemaking process with substantive comments is a great way to actively participate in shaping federal policies like those proposed by the FAA. By adhering to the dos and don’ts outlined in this guide, you can create impactful and persuasive comments that contribute to the agency’s decision-making process and help achieve better policies for aviation safety, efficiency, and fairness. Remember, your voice matters, so use the opportunity to make a difference through thoughtful and well-informed commenting.

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