This is the first of perhaps several blog posts on the MOSAIC topic. This topic should be of great interest to followers of this blog as it stands to impact a large portion of the GA flying fleet. Certified Aeronautical Products, LLC, being in the business of FAA Approved Aircraft Systems and Performance Upgrades, is experienced in the current issues that MOSAIC intends to address, particularly for “Legacy Aircraft”. We intend to follow this issue and provide input whenever and however possible as this topic develops.
Recently, there has been an increase in news reports on an FAA and general aviation (GA) industry initiative called Modernization of Standard Airworthiness Certificates (MOSAIC). I have been hearing about this for a couple of years, however this topic became of greater interest to me last month when the Experimental Aircraft Association (EAA) released an announcement made by acting FAA Administrator, Dan Elwell at the 2019 EAA Air Venture convention at Oshkosh, Wisconsin. I have begun learning more on this topic over the past month. One thing I have found is that there is not much public awareness on this topic. So, I was delighted to hear that there was going to be a presentation on MOSAIC this year at the 2019 GA Engine Summit that I have attended annually for the past three years.
About the GA Engine Summit – This is an invitational forum hosted by the FAA Boston Aircraft Certification Office. Many in this office are assigned as “standards” staff to work on certification standards for aircraft engines and propellers. The intent of the meeting is for industry representatives to interact with FAA personnel (from various segments of the agency) and discuss issues pertinent to GA aircraft, engines, and propellers. Attendees of this meeting include representatives from various FAA certification offices around the country, from reciprocating engine manufacturers (OEMs) and parts manufacturers (PMA holders), propeller manufacturers, aircraft modifiers (STC holders), industry organizations (AOPA, EAA, AAA, and ARSA), FAA designees (ODA, DER, DAR), and other aircraft engine and propeller industry experts. The 2019 summit was the fourth annual gathering for this event.
This initial posting on the MOSAIC topic is strictly my own record of the GA Engine Summit presentation as I remember and interpreted it. My intent is to provide accuracy in this report to help educate our blog audience. I hope to generate interest and input from others on this topic. If I mis-interpreted any important points or have recorded anything in error, I stand open for correction by others who were in attendance or who are more knowledgeable on this subject. If you intend to comment, please advise the readers whether your comments are your opinion or factual. If facts are presented, please cite your references. I’ll do the same. For this first posting, I’ll try to keep my opinions out and focus on documenting the presentation. I’ll save my own personal opinions and proposals for separate postings. The primary focus of this report is on the "Legacy Aircraft" aspects, for which I and the readers of this blog are most interested.
MOSAIC: Improving Amateur-Built, LSA, and Legacy Aircraft
presented at the 2019 GA Engine Summit at FAA ACO – Burlington, MA
by Doug MacNair, EAA Vice President of Government Relations.
The MOSAIC topic was presented to a small but diverse audience of about 30 or 40 attendees at the GA Engine Summit on September 18, 2019. Doug MacNair from EAA did a good job of explaining the MOSAIC concepts and laying out what the EAA is proposing. But at the same time, he admits that nobody (neither FAA nor industry) knows what the final result will look like. Doug reported that this is a real and active program currently underway at FAA "headquarters", the standards/rulemaking staff in Washington DC, with over 50 staffers working on it. The presentation was quite interesting to say the least, but it is very complex. There is a lot more to it than has been made public so far. To summarize, MOSAIC a long way from having a clear definition.
In general, the MOSAIC concept covers major reform in three areas.
- Easing the Experimental Amateur Built (E-AB) 51% rule to grow the "kit" industry
- Expanding the limits of Light Sport Aircraft (LSA) to enable more pilots to fly more airplane types
- Addressing certain problems with "legacy aircraft" - EAA is proposing a solution as something similar to a new owner maintenance category.
The main point of justification by EAA for its proposal is that there is statistical evidence showing that "experimental" aircraft safety has improved on par with the safety record of aviation as a whole. No real tangible numbers were presented on this. However, both Doug and Sean Elliott (also from EAA) described how all of the subject airplanes fall into a low or the lowest tier on the "safety continuum". (more on this below). Doug noted that the majority of these aircraft are operated for personal and recreational use.
The following are some of the points I noted as related to “legacy aircraft”.
- How MOSAIC came about and why it is going to really happen - David Oord (AOPA) gave a brief explanation. Congress has mandated regulatory changes to deal primarily with UAS (drones), electric powered aircraft, and other emerging technologies by a certain date (I missed the exact date but it is due in 2023 I think). Recognizing that the mandated changes will affect Part 21 and are going to happen, both the FAA and Industry see this as a rare opportunity to get some changes into Part 21 that they've wanted for a long time. An earlier presentation at this conference emphasized that the FAA is getting hammered with these types of new and novel projects at a pace so rapid that they cannot keep up. The existing regulations don't adequately cover certification standards for them. FAA and industry resources are being consumed with efforts to come up with appropriate standards through arduous processes for proposing rules on a case by case basis. The Part 21 changes are intended to settle and curtail most of this. The bottom line is GA industry and FAA want to seize this opportunity to also address certain known GA issues. MOSAIC is one of the main efforts for this.
- The concept of "modernization" of standard airworthiness certificates has to do with trying to streamline and reduce costs for equipping legacy airplanes with "safety enhancing" equipment. Doug cited mostly avionics equipment like TCAS, ADS-B, auto-pilot, LED lighting, etc. as some examples of "safety enhancing” items. It was explained that the certification standards that apply to "legacy airplanes" stand in the way of these safety enhancing technologies because it drives up the cost.
- There is no current definition of "legacy airplanes". However, the slide Doug showed proposed that the EAA considers them as "aircraft over a certain age, 30 years or more". He outlined that these airplanes are used almost exclusively for personal and recreational use. They are lumping a majority of Type Certificated airplanes into this one category. To me, having a prior notion of legacy airplanes being much older than 30 years, I went away with a different picture than the one I expected. As I listened and learned more about the problems being identified, I developed some more of my own personal opinions that I will talk about in a later blog post.
- Size of the Legacy Aircraft Fleet: One question I asked was "How many of the current flying fleet includes these legacy aircraft". No hard number was quoted, but the room consensus was that it is a majority of the 150,000 flying GA airplanes.
- As mentioned EAA's justification comes from a broad look at what has been dubbed "the safety continuum". There have been numerous committees among industry, FAA, NTSB, and others talking about this for the past several years. It is what they call a refined approach to dealing with safety where accident rates are studied and the outcome is a grouping of aircraft in terms of the many factors that affect safety. It is a risk-based approach to studying aircraft safety. It is a complex attempt to consider everything that affects safety (examples: number of passengers, weight, stall speeds, amount of fuel carried, age, complexity of systems, how they are operated, number of engines, type of construction, etc.). The point of the EAA proposal is that the airplanes on the lower end of the safety continuum do not require as stringent regulation as those on the higher end. It was discussed that the FAA has already begun to address some of this by the amendments recently made to 14 CFR Part 23 airworthiness standards for small airplanes. The rule changes at amendment 54 have broken down small airplanes into 4 different classifications. The standards for new small airplanes that str low speed, lighter weight airplanes, fewer passengers, etc. are relaxed more than those for higher-risk airplanes.
- The EAA’s justification specifically with respect to relaxing the "Maintenance" standards were pitched on a slide with the following bullets:
- Maintenance related accidents for amateur built are similar to that if TC'd aircraft of comparable type, size, and operation
- Example: 4.5% of PA-28 accidents vs. 4.3% of all amateur-built accidents (including true experiments).
- Maintenance privileges for TC'd aircraft, operators, and operations similar to amateur built may be appropriate.
- I found the presenter had very little backup for his assertions about the overall safety of GA aircraft, both certified and experimental. A lengthy report was published by the NTSB in 2011 about the safety of E-AB aircraft. Since then, I am not aware of any detailed reports that have quantitative data. The presenter did make reference to the findings of the 2011 NTSB and some of the changes that came from it. He noted that improvements have been realized and that the E-AB safety record has improved dramatically since 2011.
- The EAA proposal as related to the legacy aircraft fleet was broken down on a single slide as follows:
- Opportunity to align legacy TC fleet with E-AB and E-LSA to a degree
- Opportunity for a new non-commercial category
- Parts - (approval) based on fit, form, function
- Modernized equipment/avionics installation on same basis
- Approvals at field level
- maintenance by A&P, owner-operator, repairman
- Special Airworthiness Certificates: In side discussions before and after the presentations (and based on prior conversations I had with the MOSAIC Program Manager in Washington DC) I have learned that the EAA proposal for MOSAIC to include adoption of a new special airworthiness category for legacy airplanes is no longer being considered and will not happen. Instead, the focus is shifting more toward streamlining of approvals for replacement parts and other types of relief to the problem.
- Some discussion during the presentation noted that strides have already been accomplished by FAA in the area of Risk Based PMA Process as a streamlining approach. There’s also an existing industry document published by MARPA and adopted by FAA to allow streamlining approvals for non-safety significant parts. These are steps in the same direction as intended by MOSAIC.
There were not a lot of opportunities to ask questions specific to legacy aircraft because the meeting attendees got into a lengthy discussion about the safety continuum. Still it was a very informative presentation that I appreciate having the opportunity to hear. I look forward to future participation in the development of MOSAIC.
END OF REPORT
[note] I apologize for the random font sizes in this report. I am experiencing a lack of expertise in HTML formatting. Always learning.... TLB
Acronyms from this blog post:
AAA, Antique Airplane Association
AAA, Antique Airplane Association
ACO, FAA Aircraft Certification Office
ADS-B, Automatic Dependent Surveillance—Broadcast
AOPA, Aircraft Owners and Pilots Association
ARSA, Aeronautical Repair Station Association
EAA, Experimental Aircraft Association
DAR, Designated Airworthiness Representative (FAA delegation)
DER, Designated Engineering Representative (FAA delegation)
E-AB, Experimental – Amateur Built Aircraft
E-LSA, Experimental Light Sport Aircraft
FAA, Federal Aviation Administration
GA, General Aviation
LED, Light Emitting Diode
MARPA, Modification and Replacement Parts Association
MOSAIC, Modernization of Standard Airworthiness Certificates
NTSB, National Transportation Safety Board
ODA, Organization Designation Authorization (FAA delegation)
PMA, Parts Manufacturer Authority
STC, Supplemental Type Certificate
TC, Type Certificated
TCAS, Traffic Collision Avoidance System
UAS, Unmanned Aircraft System
Watch for future postings about this topic. PLEASE LEAVE YOUR COMMENTS BELOW. Thank you!