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
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!
