The comment period for the FAA’s notice of proposed rulemaking, Modernization Of Special Airworthiness Certification (MOSAIC), ended as of January 22, and aviation associations drew my attention—along with others—this month with their lengthy and considerable comment submissions.
The General Aviation Manufacturers Association (GAMA) made waves earlier in the month when it announced it disagreed with some aspects of the MOSAIC NPRM as written, and it was hard at work on detailed comments to the FAA to outline its concerns.
In the past, GAMA has often paired up with the Experimental Aircraft Association and other “alphabet” aviation groups in public comments and statements.
The EAA submitted comments just ahead of the comment period’s close, in concert with the Aircraft Owners and Pilots Association, National Business Aviation Association, and the National Air Transportation Association.
The comments by and large support the proposed rulemaking as written, but do draw attention to particular points that could use extra consideration. It’s easy to find summaries of most of the salient points, but as a student of aviation whose journey has been marked by some of the particular economic forces that have put pressure on GA in my lifetime, the following point in the document drew my eye:
The average age of general aviation aircraft is estimated to be nearly 50 years. Despite hours flown in single-engine piston aircraft being at their highest in at least a decade, the fleet itself is inexorably aging. Between 2012 and 2021, the total airframe hours of the average single-engine piston aircraft increased by 8.4%. New type-certificated aircraft remain stubbornly out of reach for most small flight schools and private operators, offering no immediate solution to this unsustainable trend.
The FAA’s MOSAIC proposal, which expands the definition of aircraft allowed to meet design and production standards set by industry consensus…