On Jan. 22, ARSA and the Aircraft Electronics Association jointly submitted comments on the FAA’s Modernization of Special Airworthiness Certification (MOSAIC) proposal. The associations referenced multiple past rulemaking efforts as well as the history of continued airworthiness regulation in critiquing the technical specifics of the proposal while generally supporting the FAA’s effort to revise sport pilot privileges and limitations.
As reported by AEA, the joint comments focused in the following areas:
(1) Decoupling sport pilot privileges from the design and certification of light-sport aircraft as a viable option that should increase pilot recruitment, certification and operations. Recommending a 10 percent increase over the proposed stall speed of 54 knots CAS as supported by the FAA in a 30 year-old rulemaking.
(2) Enhancing the safety, performance and increased privileges for light general aviation aircraft. Providing research demonstrating the current regulations already support the FAA’s goal, without additional rulemaking. Beginning in 1989, the FAA proposed and succeeded in three separate rulemakings designed to create “simplified procedures for type, production, and airworthiness certification, and associated maintenance procedures.” Each of these three regulations allows for “the development of certification standards by the private sector and represents the most productive and cost-effective manner of streamlining the certification process.” (i.e., consensus standards)
(3) Leveraging the agency’s 30-year development of a safety continuum for the design, manufacturing and certification of viable general aviation aircraft, which is represented in the current regulations.
To read the complete comments, click here.
