Eleventh-Hour Cracks In MOSAIC?

One of the big challenges of this job is the absolute necessity of becoming an instant expert on whatever subject is in front of one at the moment. Missteps are inevitable, especially when the subject is complex, but like everyone else involved in this specialized and arcane information flow we do our best.

Anyhow, I was just getting a handle on the ins and outs of MAX 9 door plugs when we were alerted to some kind of disturbance in the force on our way to a much more rational and accessible Light Sport category via the Modernization of Special Airworthiness Certification (MOSAIC) rulemaking process. The extended deadline for commenting on the 300-plus-page document is Jan. 22, and we suddenly heard from sources deeply involved in the nuts and bolts of that process that one of the major stakeholders in it was getting cold feet about some of its provisions. Bye-bye Boeing, but I'm sure we'll get back to you.

It seems General Aviation Manufacturers Association representatives had let it be known that it would be looking for some changes to the NPRM in the comments it would be filing. GAMA has assured us its comments will support the overall direction of the NPRM but "there are areas of the proposal which go beyond what was expected and require additional clarification and justification from the FAA." After some back and forth over the way we interpreted that, GAMA further emphasized that it supports Sport Pilots being able to fly four-place aircraft and that it supports "the increase in the size, performance and scope" of aircraft included in the new regime but—and it may be a fairly big "but"—we'll all find out the details when they file the comments, likely just before the deadline.

Now, it's just one set of comments out of the hundreds, perhaps thousands, that will be registered with the FAA. But the agency gives a fair bit of weight to organizations the size of GAMA because it assumes they represent the collective will of their hundreds of important and influential members.

Groups like GAMA do have to reflect the desires of their members, and airframers are going to have a different point of view than the members of EAA and AOPA, which yield the same level of clout, at least, as GAMA. These groups have each other on speed dial and are constantly in touch on a wide range of issues. They often get together to form a unified front on issues before the regulators and to politicians and it's enormously effective. That requires transparency and trust. I'm sure there are some spirited exchanges that go on before that unified front is achieved but at the end it's all smiles and handshakes. I think I assumed that was going on with MOSAIC, too, but maybe I was wrong.

The difference in this case is that GAMA doesn't seem to have communicated its possibly divergent positions on MOSAIC until the last week or so. And it's worth noting that we got wind of all this through "unnamed sources." Although often scorned in anti-media tirades, unnamed sources serve a vital role in keeping the public informed about important issues. It takes a lot of courage to actually flag an issue and alert someone like me who can start asking questions and bring it into the light of day. By the way, we always verify the sources and we did so in this case. These are all highly respected and incredibly knowledgeable folks, and if they're alarmed we should be paying attention.

Perhaps more telling is that when I called the other groups they seemed to be surprised by it. I'm sure there have been some of those "spirited exchanges" since then but with only a week to go before the deadline, it doesn't seem likely that any substantive dialogue can take place, assuming the changes GAMA wants are themselves substantive.

EAA has now published the essence of its position in the form of a guide for individuals to comment on the NPRM, and it mainly expresses the need for a little more liberal approach on certain aircraft specs so the new rule captures the most popular and numerous existing light aircraft. More importantly, it opens the door to new players to create a new generation of modern, efficient, safe and desirable aircraft that can be used to feed the pilot pipeline.

GAMA's comments may do something similar but I guess we'll have to wait until Jan. 22 to find that out. That's not to say that I think GAMA should toe some imaginary line or give ground on issues it believes will be detrimental to its members, but the rest of us might have some ideas on how to achieve the core goals of MOSAIC while respecting those concerns. It would have been nice to have had the chance.