Recreational flying fans… I don’t know about you but I’m getting pretty tired of studying Mosaic. It’s been on my mind every day since FAA issued it on July 24, 2023, just before EAA AirVenture Oshkosh started.
I’ve studied this pretty closely — thanks SO much to Roy Beisswenger for his effort to make a Study Guide. This is not an easy read but it has much we want plus a few things we question or want changed.
If you want some part changed, you have to comment. I can comment and many others have. That’s good but FAA needs a loud response. With 39 days left at posting time, 389 pilots have commented. YOUR comment is still needed.
For a series of Masterclass videos on Mosaic, click or tap here.
To assure my facts were as accurate as possible, I consulted several other experts, each focused in specific areas of interest.
Linked with my own experience — serving on the ASTM committee for many years, going to visit FAA in their government offices in Washington DC (several times), and discussions with the LAMA board plus numerous other aviation leaders — the video below provides the best information I can offer at this time. Is it a perfect understanding of all things Mosaic? No, I keep uncovering new tidbits buried in this lengthy document. Others have often pointed out things I missed.
The video below provides as much detail as possible as quickly as possible in a form not too difficult to consume. It also draws attention to areas where people have found problems or have unresolved issues with what is presented. Again the video tries to illustrate these simply and clearly. I hope you’ll have a look.
Where are the Comments?
If you get through all 45 minutes of the video presentation below – which I hope you will find worthy of that much investment of your time — you will discover that the Q&A portion does not appear. This portion of our discussions went on nearly as long as the formal presentation. It simply got too long and took too much editing.
FAA repeated, “You’re going to like what’s in this.” This slide is what they meant.
I was fascinated when during Q&A, discussions erupted on their own. Being particularly passionate about a part of Mosaic and our privilege to fly, attendees often spoke to one another without my input. This was invigorating to witness but it was sometimes challenging to hear what people said, and not in every case could I keep up with the conversations. In short, I think you’d find it less useful than what I will present.
I am going through all of those comments carefully and will summarize them in printed form, which I think will be much easier to consume.
Many worthy LSA models accepted by FAA under current rules need little or no change for operation under Mosaic. In fully-built or kit form, they should help keep recreational affordable.
While I work on that, I encourage you to do what the video suggests: go up to the search bar at the top of this page and type in Mosaic. That will bring up everything I’ve written about the NPRM in chronological order. A few articles on Mosaic Light-Sport Aircraft will be sprinkled among rule-oriented articles but all have some useful information.
A few of those articles generated lots of comments. In fact, at the time I gave these two talks, this website had generated more total comments than FAA’s website – a fact I hope will change dramatically in a new direction soon. I know people tend to wait until toward the end to act but pilots shouldn’t cut the deadline too close.
If FAA’s new rules are important to you, I urge you to watch this video. I will get to the Question & Answer article as fast as I can and hopefully make good sense of them for you because we all heard some interesting exchanges.
Meanwhile, happy regulatory proposal watching and reading. Following are the essential links you need to comment. All you need to write is a couple or a few paragraphs. See what others wrote and use your own thoughts.
HELPFUL ARTICLE LINKS:
- USUA/LAMA MOSAIC NPRM Study Guide, download a PDF document with bookmarks and helpful organization
- Article on using the Study Guide
- Make a comment, direct link to FAA’s comment page
- Read what other commenters have said, FAA comment page
Currently, LSA dual instruction hours from a CFI-S are not counted toward earning a PPL unless the student obtains the LS license (more accurately: Sport Pilot certificate) before moving on in licensing after obtaining the LS license. I’d like to see that CFI-S instruction time counted, as it would encourage students to move on to PPLs while still taking CFI-S instruction (up to a point), might lower costs overall, and would make more instruction available.
I don’t see anything in the Mosaic draft addressing instructional hours. If I comment, I would include a recommendation that, say, up to 20 hours of CFI-S instruction (or even half of all dual recorded in the logbook) could be counted by an ab initio student working to a PPL directly. Just as the written tests of LSA and PPL largely overlap, so does much of the flight instruction.
Most experts agree that all the time from a Sport Pilot Instructor counts, except where that instructor does not have credential himself or herself. For example, since an SPI may not possess night or instrument experience, obviously, they cannot give you that instruction and have it count towards Pprivate. All the primary instruction, they give you, however, does count.
Dan,
What is the best, most effective way to comment?
I have 4 specific, and unique, topics I am getting ready.
Is it best to put them all in one response or separate them into different and separate responses?
I have quite an introduction as to my qualifications are important and relivent.
Better late than not.
Paul
Paul, you are not late because you still have more than three weeks to prepare and submit your response. I hope you will do so, as you are a significant voice in our community.
I don’t believe it is necessary to put each comment topic into separate comments. Although that would increase the comment count, what you truly want is for FAA to hear your input. As I tell everyone, don’t simply tell them what you don’t like. If possible, offer them a suggestion or a solution. FAA does not have all the answers.
Please… Comment!
I really don’t understand why we are going through these loops. One of the main issues is if a pilot fails a medical certification they can’t fly. These changes will still have pilots afraid to take medicals so they can be sport pilots. The rules should just be changed so that pilots can fail a medical and still fly but not commercially or with only one passenger. But if a pilot can get a PPL (sans medical) and has basic health (can see and hear), let them fly.
A worthy perspective.
Please… comment!
I have written my Senators, as well as suggesting that others do so as well, to address the medical situation.
HR3935 has passed the House, and is currently in the Senate, and in it, Section 203 proposes to amend the very sentence that requires a medical after July 14, 2006 in order to fly with Basic Med. Here is what it will change:
(a) In General.—Section 2307 of the FAA Extension, Safety, and Security Act of 2016 (49 U.S.C. 44703 note) is amended—
(1) in subsection (a)—
(A) by striking paragraph (2) and inserting the following:
“(2) the individual holds a medical certificate issued by the Federal Aviation Administration or has held such a certificate at any time after July 14, 2006;”;
What this will do is change this sentence:
“(2) the individual holds a medical certificate issued by the Federal Aviation Administration on the date of enactment of this Act, held such a certificate at any point during the 10-year period preceding such date of enactment, or obtains such a certificate after such date of enactment;”
…to this:
“(2) the individual holds a medical certificate issued by the Federal Aviation Administration or has held such a certificate at any time after July 14, 2006;”
In practice, it changes absolutely nothing. I propose to instead delete that sentence. If that sentence is deleted, then Basic Med becomes possible without having had a medical that could be 17 years old.
It is important to note that since this is law enacted by Congress and signed by the President, FAA cannot on its own eliminate the need for a medical in order to fly under Basic Med. Only the Legislature can do that.
I find it interesting that in the same section, they plan to increase the number of seats from 6 to 7, and the weight from 6000 pounds to 12500 pounds. It just makes me wonder if some Congressman has a plane with 7 seats that he wants to be able to fly without a medical. More of taking care of themselves and let us eat cake.
Anyway, I encourage people to write their senators and lay out the case that a 17 year old medical proves nothing, so this requirement should be eliminated from 49 USC 44703.
Rich, great job on your research and that is an excellent idea.
As you may know from my video, I completely agree that any medical examination 17 years ago has no relevance today (it didn’t have much the day after). FAA is clinging to this medical thing, perhaps for the reason you suggest, but that reason is not good enough.
My challenge to FAA, or Congress, is to provide compelling evidence that possession of an aviation medical ensures a flight can proceed safely. I have never seen any such evidence. Simply put, the number of aviation accidents attributable to a pilot’s medical condition is vanishingly small.
Thank you very much for the hard work you always put in in order to keep us informed. Your efforts are very much appreciated.
While it may be too late for this particular event, I’d be interested in hearing what some of the questions are at the end of the presentation.
Thanks!
It took a while to sift through all the comments — sometimes where more than one person was speaking at oncee — but all those comments or questions that I could interpret have been presented in this article. Thanks for your close attention to this matter.
Thanks for doing that Dan- that was very informative. 2 questions:
1. My understanding is that sport pilots under MOSAIC still can’t fly IFR, but after listening to your presentation, you made reference to it as a possibility. Can you clarify?
2. Do you have any idea whether some of the traditional LSA aircraft (such as the Evektor Harmony) have the structural capability to raise their MTOW under MOSAIC? Put another way, are they currently artificially limited due to the rules?
Thanks for all you do.
(1) To fly legally in the IFR system requires an IFR rating. That won’t change nor will currency requirements or the minimum equipment list (easily achieved). However, whether an IFR-rated pilot can enter the IFR system without a medical is an open question. FAA appears very attached to medicals.
(2) Many current LSA have been tested to higher weights than 1,320 pounds. A builder would have to redeclare compliance with all ASTM standards, which means showing documentation of their testing to higher weights. Many can do that and I would expect they will. An open question is… can or will they make a higher weight limit “backwards compatible” with models already in operation. I’m less sure of that as the manufacture can’t know how an airplane has been maintained or treated.
I am pleased you found the material useful.
There is no Light Sport instruction at my airport (0S9) and perhaps the entire state of Washington and this rule won’t help. It does not address the lack of affordable owner built light aircraft needed for instruction.
I could easily get a sport pilot instructor certificate since I already have a private certificate. But there no aircraft options to buy or build to use for instruction unless I want to spend $50,000 to earn back $500 per year.
Bill Berson
Thanks for the excellent review of the NPRM. It was great to be there in person.
It was great having you in attendance. Both days had a roomful.
Critical Loss of Transition
Many of us still remember the “glory days” when pilots of light aircraft could help transition pilots to fly in very light/slow vehicles. It was a powerful system, providing good access to safe operations. The very slow nature is part of what provides safety. The “high drag/ low mass” is what made transition necessary.
It is amazing that the exemptions had more than 8000 instructors, serving more than 60,000 man-years of flight support for the community. That includes more than 400,000 student contacts. Losing the exemptions was a major impact to transition support.
With the advent of Light Sport Aircraft (LSA) and Sport Pilot (SP), the exemptions were ended. In their place was sport pilot instructor (SPI. Which to be fair, is reasonably easy to obtain). And instruction was to be supported by Special Light Sport Aircraft (SLSA). The problem being that the exempt instructors were expected to leave their exempt vehicles and buy a much more expensive SLSA certified by the manufacturers.
There are also some changes to the system called “Letter Of Deviation Authority” (LODA). This process allows a SPI to teach in experimental class aircraft. That allowance means that under a LODA, the experimental aircraft brought in under ELSA could be used for instruction. The problem is that only about 18 of the total 190 LODA’s have been approved for the light class of aircraft. Think about it, we have 18 instructors in light aircraft under LODAs compared with the loss of 8000 previous exempt instructors.
A Sport Pilot can train a transitioning pilot in an N numbered aircraft. And they can train a transitioning ultralight pilot. But they cannot have a financial incentive. The costs for converting to SLSA aircraft makes the expense too high to attract the needed transition services.
We could fix part of this problem if we could get the needed changes out of the FAA. The FAA is currently considering two Notices of Proposed Rule Making (NPRM). One is an expansion of SLSA which includes some corrections for instructors. The second NPRM is revisions to the LODA process.
We should comment to both NPRMs. The contact information to see the current NPRM’s and to comment to those NPRM’s is provided below. Commenting is easy.
Comments should focus on recommending that SPs be allowed to provide “transition-for-hire” in certified and experimental class of Light Sport Aircraft with stall speeds less than 35 knots. Where transition is limited to: takeoff, minimum-controllable-airspeed and landing.
It is important to note that this proposal is supported by the history of the exemption process and its successes. It is further supported by the concept that beyond the exemptions, this proposal would have licensed pilots, in numbered aircraft.
http://www.federalregister.gov
MOSAIC NPRM Docket FAA-2023-1377-0001 for initial doc.
LODA NPRM Docket FAA-2023-1351-0001 for initial doc.
Jim Stephenson
kimojim@aol.com
Dan, in the video you indicate that MOSAIC will open up Piper Archers, Sling High Wings and a few others to Sport Pilots. In the cases of Archers, Sling High Wings and Sling TSI, the VS1 Calibrated Air Speeds (CAS) are higher than 54. I believe this would keep them beyond the reach of Sport Pilots.
I checked Archer III; the POH indicated a 52 knot VS1. Some Pipers are higher.
Many LSA or Mosaic LSA candidates can modify airframes to meet 54, I suspect, although a large number of successful commenters might raise it by a few knots. The Standard Airworthiness Certificate airplanes from legacy GA companies cannot change so their POHs will indicate whether they qualify or not.
Dear Dan,
Here in Brazil, I am the VP of the Brazilian Aeronautical Maintenance Association – MANTAER and the Operations Director of the Brazilian Aeronautical Formation Association – ABEFAER.
There is no harder struggle than to convince people to participate on discussions about the things which will impact directly on their own life!
A good friend uses to say that there is no Democracy if there’s no organized society. And that’s all Associations are about: an organized society, to fight for the interests of a group.
I sincerely hope more of your sport aviation community will contribute on such an important issue for this important sector of aviation business!
On our side, we have a group of manufacturers and consultants, who are discussing with ANAC on what can we profit from the FAA NPRM.
We are a small group and, fortunately, we have the confidence of ANAC to listen to us and to understand we represent most of the community’s opinion.
I’ll try to keep you posted on our proccedings.
Cheers! And keep up with the good work!
Very informative.
Has anyone made a list of Part 23 aircraft that fit those parameters?
I have not, but perhaps someone will.