ARSA, AEA Point to History with Joint MOSAIC Comments

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.

Previously updates on MOSAIC rulemaking...

10/5/23 - FAA Grants Industry Request to Extend MOSAIC Comments

October 5, 2023

On Oct. 4, the FAA extended the comment period on its Modernization of Special Airworthiness Certification (MOSAIC) proposal by 90 days. The public now has until Jan. 22, 2024 to submit comments.

For background on the industry’s request for this extension, review the August 2023 update below.

Industry Requests More Time for MOSAIC Comments

August 29, 2023

On Aug. 29, ARSA joined six trade associations and one member company in requesting the FAA extend the comment period on its Modernization of Special Airworthiness Certification (MOSAIC) proposal. The group requested an additional 90 days beyond the current Oct. 23 deadline and provided a digest of issues to be carefully analyzed in assessing the notice of proposed rulemaking.

The request urged the FAA to consider:

(1) The true extend and nature of the proposal, which would amend nine parts of 14 CFR.

(2) The significant technical, administrative, and financial impact on small businesses.

(3) How the 2016 final rule revising part 23 was implemented to resolve most of the issues meant to be addressed by MOSAIC.

(4) Expanding the economic analysis to truly cover all impacted parties.

(5) How the rulemaking for powered-life aircraft operations, which is also in process, relates to, impacts, and complicates the MOSAIC proposal.

(6) How the ongoing work of the ARAC Repairman Working Group impacts the MOSAIC proposal.

As the association collaborates on high level analysis and comments on the MOSAIC proposal, ARSA encourages members to follow the rulemaking and comment (regardless of when the final comment due date falls).

To view the rulemaking docket, click here.

To review the extension request letter, which more thoroughly explains the six points above, click here.

To see ARSA’s training on engaging the government through rulemaking comments, follow the link below.

In addition to ARSA, the extension request letter was signed by the Aircraft Electronics Association, the Aviation Suppliers Association, the Aviation Technician Education Council, Helicopter Association International, the Modification and Replacement Parts Association, the National Air Transportation Association, and International Air Response, Inc.

On Demand Bundles – Effective Comments and the Fourth Branch of Government

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