FAA-2023-1377 LSA Comments on MOSAIC NPRM

Sep 25, 2026

Uploaded by Jiven

Comments submitted in response to a U.S. Department of Transportation docket addressing the MOSAIC NPRM and Light Sport Aircraft (LSA) rules. The author supports several proposals, including eliminating a maximum takeoff weight limitation, increasing stall speed in the clean configuration with added considerations for approved stall-speed-lowering modifications, and raising LSA seat count from 2 to 4. The author opposes applying Part 36 noise certification to Experimental Airworthiness and Special Light Sport Aircraft, citing reduced relevance, lack of evidence, and increased cost without safety benefit.

LanguageEnglish

CategoryExam

FormatPDF

Pages3

Reading Time8 min

AccessFree to download

Comments on MOSAIC NPRM

Supported proposals

Opposed noise certification proposals

1/20/2024 Docket OperationsM-30 U.S.Dept.of Transportation (DOT)1200 New Jersey Avenue SE,Room W12-140 West Building Ground FloorWashington,DC20590-0001 Review Committee: Light Sport Aircraft Re:MOSAIC NPRM Docket No.FAA-2023-1377Comments I would like to take the opportunity to offer my comments with regard to the above referencedNPRM.I would also like to applaud the FAA's efforts to expand and modernize the rules andregulations with regard to both Light-Sport Aircraft and the operating privileges of Sport Pilots. Obviously,the intent of modernizing rules and regulations is to maintain the safety of operationswhile improving access to an expanded fleet of training aircraft and by expanding the numberand capabilities of those aircraft.This is usually accomplished through encouraging aircraftmanufacturers to innovate new safety enhancements and capabilities.In addition to thoseenhancements and offerings,it will provide economic incentives to not only increase the numberofactive pilots,but will provide them with new affordable aircraft and related technologies.Needless to say,those economic incentives will necessarily boost the number ofjobs available inthe aviation industry and in particular to the general aviation community. In the interest of brevity,I will limit my comments,recommendations and justifications on a fewof the proposals that I believe will allow for the greatest positive impact. FAAProposal:Elimination of the 13201b.maximum take-off aircraft weight.Fully support. Justification:An increase of maximum weight has already been issued for some aircraft in orderto accommodate USDOT highway safety standards.Additional weight for the installation ofsafety equipment(ballistic chutes etc.)could be easily accommodated without compromisingother essential equipment or operational capabilities. —2— FAAProposal:Increasing stall speed in clean configuration from 45 kts.CAS to 54kts.CAS.Support with comments. Justification:Increasing the stall speed to a minimum of 57 kts.will allow several existinglegacy aircraft to qualify for inclusion into the LSA category.By so doing,it will increase thenumber of aircraft available for flight training,maintaining currency and to Sport Pilots.It willalso increase the availability of parts and maintenance procedures which are already familiar tomany mechanics and suppliers.In addition,the higher stall speed will usually be representativeof aircraft of higher structural integrity which could be representative of better crashworthiness.For pilots transition to LSA aircraft,it would also provide increased familiarity with traditionallegacy aircraft and as such could increase the safety of training and operational use. Additional Consideration:In addition to increasing stall speed,the FAA should consider theability of existing aircraft with lower stall speeds if those aircraft are equipped with stall speedlowering modifications.Even though an aircraft is originally certified with a stall speed,thatspeed can be lowered(sometimes significantly)by additional modifications that will lower theoriginal certification stall speed.Only modifications that have been approved by the FAA andinstalled by an approved repair/modification center would be accepted.If necessary,theapproval could be by demonstration,much like a pilot can receive a demonstrated ability checkride. FAA Proposal:LSA seat Count raises from 2 to 4 seats.Fully Support. Justification:The increase in the number of seats allows for better utilization of aircraft.Assuch,it would allow a flying club or a partnership to purchase one aircraft that will fullfill theneeds of the members/renters etc.when there is a mix of Sport Pilot and Private Pilots.It willalso encourage those with lower ratings to seek higher ones to fully utilize the aircraft'scapabilities.For flight schools that train pilots by having another student as an observer in theaircraft,it would allow for such flexibility.Lastly,the FAA's own safety

FAQs

Which MOSAIC NPRM-related proposals does the author support?

The author supports eliminating the 13201b maximum takeoff aircraft weight, increasing stall speed in the clean configuration, and increasing LSA seat count from 2 to 4 seats.

What justification is given for increasing stall speed in the clean configuration?

The author argues that raising stall speed to at least a specified threshold would help existing legacy aircraft qualify for LSA, expand training aircraft availability, improve parts/maintenance familiarity, and generally align with higher structural integrity and crashworthiness.

Why does the author oppose Part 36 noise certification for experimental and S-LSA aircraft?

The author states that applying certification requirements undermines the purpose of experimental categories, lacks evidence of safety or noise-related benefits, and would impose significant economic burden due to uniqueness of experimental aircraft and expected compliance difficulty.

Sep 25, 2026

Uploaded by Jiven