The General Aviation Manufacturers Association says it supports almost everything about the proposed Modernization of Special Airworthiness Certification (MOSAIC) initiative but isn’t convinced the FAA has properly considered the risks of one of its main proposals. In its comments on the Notice of Proposed Rulemaking, the organization, which represents about 150 OEMs, parts and subsystem manufacturers and other industry associations, said it doesn’t think the safety record of the existing Light Sport category is enough to support the increased complexity and size of aircraft that will qualify under MOSAIC.
Under MOSAIC, aircraft will have no weight limits but the proposed clean stall speed of 54 knots will effectively cap aircraft size at about 3,000 pounds. They will also be allowed to have a top speed of up to 250 knots and include “complex” features. That compares to the current Light Sport limitations of 1320 pounds and 125 knots. “When all the proposals to increase size and remove or reduce limitations are taken together, there are areas regarding new and complex design and operation of light-sport aircraft that are not fully supported by current operational safety data and require additional consideration and understanding on how FAA intends to implement with the appropriate mitigations for risk,” the organization said in its comments, which run 38 pages and contain dozens of recommendations.
GAMA said its members did not reach consensus on what to do about that but some themes emerged. One is to split the category into two “in which proven, conventional ‘simple to design and simple to build’ has no limitations and a complex or high-risk design or operation that is subject to certain limitations.” The limitations might include speed limits or prohibiting their use for “high volume” operations like “aerial work, flight training, IMC, night, etc.” Another idea is to have different standards for “certitude robustness” for “simple” and “complex” and “recreational” and “high volume” operations.
GAMA also suggests a resurrection of sorts for the Primary Category as way of standardizing the certification approach in the eyes of the rest of the world and opening the U.S. for importation of foreign aircraft that meet MOSAIC standards. It noted Icon Aircraft recently certified its Light Sport A5 amphibian in the Primary Category so it can export the plane to other countries, most of which don’t have a category equivalent to Light Sport. It says the tinkering with the Primary Category should be a “future initiative” while noting that some MOSAIC specs are actually more liberal than those in the Primary Category, which logically should be a higher level of certification. Alternatively, it says the FAA could just scrap the Primary Category when MOSAIC is implemented.
