AEA requests extension for comment period for MOSAIC proposal

As reported by the AEA at the beginning of August, the Federal Aviation Administration recently published the proposal for the Modernization of Special Airworthiness Certification (MOSAIC). The primary purpose of the proposal is to expand the aircraft that may be eligible for future certification as a light-sport aircraft, and to expand the authority and opportunity of a sport pilot.

What has not been discussed, however, is that the agency is proposing to amend nine separate regulations. And, in supporting the proposal, the docket includes 17 supporting documents (including two draft advisory circulars), 129 footnotes with numerous standards and 26 Federal Register cites, and seven policy documents equating to well over 1,000 pages of directly relevant information.

The NPRM proposes to amend 14 CFR Parts:

  • 1: Definitions.
  • 21: Certification Procedures for Products and Articles. 
  • 22: (New), Design, Production, and Airworthiness Requirements for non-Type Certificated Aircraft. 
  • 36: Noise Standards: Aircraft Type and Airworthiness Certification.
  • 43: Maintenance, Preventive Maintenance, Rebuilding, and Alteration. 
  • 45: Identification and Registration Marking. 
  • 61: Certification: Pilots, Flight Instructors, and Ground Instructors. 
  • 65: Certification: Airmen Other Than Flight Crewmembers.
  • 91: General Operating and Flight Rules. 
  • 119: Certification: Air Carriers and Commercial Operators.

While the public’s focus has been on the expanded sport pilot privileges and limitations as well as the weight and performance increases of the light-sport aircraft, the AEA is primarily focused on three areas:

  • Continued Airworthiness:
    • The impact of the proposal on the general aviation maintenance industry.
    • Replacement of parts and accessories.
    • Alterations and modifications.
  • Personnel:
    • LSA repairman (maintenance) privileges and limitations.
    • Impact on workforce development.
  • Repetitive rulemaking: 
    • Part 23 rewrite versus MOSAIC.

To read the NPRM, click here.

Comments must be submitted no later than Oct. 23, 2023.

As reported in the AEA regulatory update to members on Aug. 7, 2023, this is an extremely complicated proposal with more than 1,000 pages of text to review. As such, the AEA along with more than a half-dozen industry partners have requested a 90-day extension of the comment period to support a thorough review. To read the request for extension submitted to the FAA on Aug. 29, 2023, click here.

The association will discuss the proposal at upcoming AEA Regionals in the United States. Also, look for an additional section-by-section review of the proposal in the October issue of Avionics News.

Contact Ric Peri, AEA vice president of government and industry affairs, by email at or by phone at 202-589-1144.