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
