AEA comments on FAA's MOSAIC proposal

Yesterday (Jan. 22, 2024), the Aircraft Electronics Association and the Aeronautical Repair Station Association (ARSA) submitted joint comments to the Federal Aviation Administration’s proposal for the Modernization of Special Airworthiness Certification. The associations’ comments were developed following input from the membership at three AEA regional meetings, the AEA’s government and industry affairs committee, and in partnership with ARSA.

As stated in the AEA's Oct 4, 2023, regulatory update, the association's primary focus, and therefore its comments, were centered on the following:

The association supports the proposal to decouple sport pilot privileges from the design and certification of light-sport aircraft as a viable option that should increase pilot recruitment, certification and operations. While supporting this proposal, the association also recommended a 10% increase over the proposed stall speed of 54 knots CAS as supported by the FAA’s rulemaking 30 years ago.

The AEA supports the agency’s goal of enhancing the safety, performance and increased privileges for light general aviation aircraft. Through AEA’s research, it discovered 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)

The association supports 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 comments submitted by the AEA and ARSA on MOSAIC, click here

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