With Time to Digest, an Industry Mulls the Reality of MOSAIC

Analysis By Gene Yarbrough

On July 19, 2023, FAA published the much anticipated but seriously delayed NPRM for Modernization of Special Airworthiness Certification (MOSAIC) rule. This regulatory reform has been discussed, fomented, promulgated, and negotiated for nearly twenty years, and now that the NPRM has been published it is obviously a pared and watered-down version of what the languishing personal and recreational aviation community really needed.

Initially, the concept for MOSAIC was to expand the types of aircraft a light sport pilot could operate, increasing the capabilities of the aircraft available in both weight, passengers, speed, and safety. Reading the NPRM reveals either that hope has been either carved out entirely, diminished in actual practical value, or has been the subject of a sort of one-card-Monty trick of salesmanship. Why has there always got to be a fly in the ointment?

MOSAIC promised 4-seat aircraft, increased gross weight, and expanded performance numbers of speed and range. At first glance the proposed rulemaking delivers all these things, but with one serious caveat that basically cuts the knees out of the new operating limitations. Good luck finding a 4-place aircraft that will stall at 54 knots or less at full gross weight.

Additionally, the first hints at MOSAIC included changing the 51% rule for experimental-amateur (E- AB) kit-built aircraft, allowing professional build help. This hope has completely evaporated from the NPRM as published. As certified factory-built aircraft have grown well out of the average flying person’s budget range this provision of the rule was one of, if not truly the most valuable gem of the concept. However, the NPRM does not mention any caveats or changes to the 51% rule holding the entire personal aircraft concept hostage all the while the cost of acquisition and ownership of personal airplanes continues to climb while the total numbers of personal airplane owners get older, and less in total numbers.

Focusing on what the ruling actually does offer sounds like it’s a big deal and could be a strong positive influence on the personal and recreational aircraft industry. Gross weights of eligible sport aircraft have been eliminated, top speeds have been eliminated, seating has been increased to 4 place aircraft, although passengers are still limited to only one person in addition to the pilot, fuel capacities, and therefore range has been eliminated, so at first blush it would seem MANY legacy and newer airframes are eligible to convert to sport aircraft category. But wait there’s more, have a look at the small, almost insignificant detail of maximum stall speed of 54 knots. What 4 place airplane has a clean stall speed of 54 knots at full gross weight?

Many people no doubt envision their Cherokee or 172 being converted to light sport aircraft status and enjoying the benefits of that category. In reality, only some of the typical 4 place aircraft will comply with the MOSAIC regulation. So much for the hope of new-found freedoms in MOSAIC...

Unfortunately, and all too characteristically, FAA stopped just inches short of the goal line. Perhaps if FAA were in the business of promoting the industry they lord over, instead of seeking every opportunity to choke it out, we could actually reap the benefits of new technologies and make personal flying and aircraft ownership affordable again.

There are rumors in the back channels of increasing the stall limit slightly, perhaps to 60kts? Hope may spring eternal yet. We have 90 days to have our voices heard, make our desires known to FAA -- what have you got to lose?

FMI: www.faa.gov