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FAA Extends MOSAIC Comment Date

To me a more appropriate solution would be to change the VS1 limit to VS0 since almost no one "specs" VS1.
 
Didn't someone in the industry tell us to wait until they crafted a good response we could get behind? I haven't submitted anything yet. Maybe I'm imagining things though.
 
ArlingtonRV said:
What Mel said, and to have VS0 expressed as IAS instead of CAS.
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From a regulatory standpoint this would make no sense. It would make it possible for me to get into the "easier class" just by mounting my pitot tube at an angle, or having an inaccurate static system.
 
Mel said:
To me a more appropriate solution would be to change the VS1 limit to VS0 since almost no one "specs" VS1.
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I agree. I submitted a comment that Operating Limits currently require Logging of Vso, so denoting Vs1 as a limit is inconsistent with vast majority of OpLims already issued.
 
KatanaPilot said:
No you aren't imaging that. I heard Rian Johnson say that at one of the Van's seminars at OSH. I think he also mentioned being on the steering committee. I thought he said he wanted us to wait until he came up with a response and to coordinate our input during the comment period.

I assume they are a bit busy trying to clean up the huge mess they have gotten themselves into and maybe haven't had time to deal with this.
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Gotcha, thanks, glad I wasn't imagining it.
 
I am guessing what they are trying with the VS1 limit is to try to prevent someone from doing something like putting slotted fowler flaps and leading edge devices on a very high performance aircraft to get the landing speed down and getting it in under the new rules. Just a guess
 
Make sure to not forget about this in January

I believe that this is a very important issue; Just the 54-knot VS1 is the difference between most RVs making it, or not making it, as LSAs under MOSAIC. So I do think that we should comment on the Regulations.gov website about MOSAIC.

Like you guys, I had been waiting for guidance from Van's and/or from the EAA on how to most effectively make a comment, as Rian mentioned at Oshkosh. But since Oshkosh, Van's has had to deal with a serious crisis, as we all know, so, I don't blame them for not having the resources to dedicate to this. (The EAA seems to be doing what they can).

So... Below is what I commented on the website. Is it the optimal text? Probably not. I'm not a lobbyist or a communications professional. I'm just sharing this here to make sure that we don't forget about this before the deadline arrives in January.

To comment, go here:
https://www.regulations.gov/commenton/FAA-2023-1377-0001

I believe that the 54-knot max VS1 requirement is too strict. I think that a 54-knot maximum for VS0 (rather than VS1) would be better. Some of the best and most popular four-seaters in GA history have a VS0 under 54 knots, and a VS1 above 54 knots. These airplanes have been proven over the decades to be safe and easy to fly. They’re far simpler and easier to fly than the retractable-gear airplanes that MOSAIC would allow sport pilots to fly (airplanes such as the Cardinal RG which typically also have constant-speed props and cowl flaps… That’s a lot of knobs and levers to manage) and also less accident-prone. They also can operate on fairly short runways. True, not as short as if the stall speed were a little lower, but… it’s not like there’s even data out there for flaps-up runway requirements of GA airplanes. The industry seems to trust pilots to land with the flaps down. If a max stall speed of 54 knots is what you determine will lead to some acceptable level of safety (be it due to runway requirements or to the survivability of an impact as a function of nose-down angle, etc.) then I would encourage you to make it 54 knots max VS0 rather than VS1. Overall, MOSAIC is a terrific proposal that will do great things for GA. I congratulate you on the progress on the proposed rule, which is terrific. This issue with the stall speed is my only nitpick.

BTW, you can browse comments here:
https://www.regulations.gov/document/FAA-2023-1377-0001/comment
 
Even though I live in Canada, I submitted my comment to change the 54 kt VS1 requirement to VSO. If/when MOSAIC is enacted with this change I hope Canada will follow the US lead and enact similar rules.
 
VSO vs VS1

My take as an owner, A&P, former flight instructor, RV rivet pounder for a late friend and a student of aviation:

VS1 is a much more fundamental metric for aircraft performance that VSO to separate the kites from the lead sleds. This is why I feel certain the FAA chose it for determining this proposed category.

I know from reading the comments that a majority of those posting would like to have the 54 knot number refer to VSO so their mini-airliner can make it under the wire.

First, the 54 knot speed chosen for this proposal is not slow. It is 62.1 miles per hour, nearly the maximum highway speed in most places. Asking for the criteria to be VSO is simply asking for a substantially higher VS1 in nearly all cases. Why not just plea for raising VS1 to, say, 58Kt?

Of course, if we set it high enough, it would include nearly the whole light aircraft fleet, since certified single engine a/c already have a max VSO
limit.

Further, if VSO is used, it will open the door to expensive solutions to lower the VSO with retractable slats, double slotted flaps and what-have-you. VS1 favors a wing loading limit which I believe correlates to survivability and safety without demands for complexity.

For one, I am grateful for this proposal as it stands. I hope it doesn't get too tangled and delayed in a numbers war. Maybe asking for more will get us instead - nothing.

ron
 
Ron, I'm curious to hear your analysis of why a student pilot ought to be able to solo a Piper Cherokee (approximate stall speeds 48 knots dirty / 55 knots clean) but someone with a Sport Pilot certificate would not...
 
Medical

mburch said:
Ron, I'm curious to hear your analysis of why a student pilot ought to be able to solo a Piper Cherokee (approximate stall speeds 48 knots dirty / 55 knots clean) but someone with a Sport Pilot certificate would not...
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I'll chime in on this: I suspect that for the FAA rules writers, this one comes down to the level of medical certificate required...k

Skylor
 
And GAMA has issues with it:

www.avweb.com

GAMA Has Issues With MOSAIC; Plans To Issue Comments To FAA - AVweb

GAMA tells AVweb there are concerns with how far the new MOSAIC certification rules go. Photo: Zenith Aircraft
www.avweb.com www.avweb.com
​
EDIT: And a follow up article today, clarifying some info from GAMA in the article above.
​
www.avweb.com

GAMA Says It Supports Four-Place Aircraft In MOSAIC - AVweb

The General Aviation Manufacturers Association says it will support the expansion of Light Sport pilot privileges to include four-seat aircraft and will also endorse an increase in “the size, performance and scope” of the aircraft covered by the Modernization of Special Airworthiness...
www.avweb.com www.avweb.com
 
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Cumulo said:
VSO vs VS1


VS1 is a much more fundamental metric for aircraft performance that VSO to separate the kites from the lead sleds. This is why I feel certain the FAA chose it for determining this proposed category.

I know from reading the comments that a majority of those posting would like to have the 54 knot number refer to VSO so their mini-airliner can make it under the wire.


ron
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So, you are saying that an RV-9, which falls under this guideline, is a kite and an RV-7, which does not, is a lead sled or mini-airliner? Sure, the 9 will land slower and therefore safer, I suppose. But they are not really that different. Nothing like comparing an old lancair to a cub. Clearly a line has to be drawn somewhere, but you are always going to find folks upset when they land just over the line and that doesn't make it unreasonable.

And there are still many safety factors not accounted for. I bet there are WAY more accidents involving ground looped cubs than there are old lancairs that stalled during short final. Not convinced that stall speed is the be all end all criteria for safe and easy to fly.
 
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Just submitted my (very nice but firmly stated) comments. I used the EAA's guidelines. Do NOT copy-and-paste anything you read about commenting on this NPRM. Those types of comment letters are nearly rejected out-of-hand and it states that on the submission form. One honest, fact-backed written letter is worth more than 1,000 form letters. You have opinions about this: tell them what you think! Don't wait for someone somewhere to tell you what to say. Read the proposal, use the guidelines from EAA and write your own letter! The deadline doth fast approach!!! :oops: :oops: :oops: NOW would be a great time! It's FREEZING outside! 🥶🥶🥶 PS: do not put ANY personal identifying information in your proposal comments. That is public record. There is a form at the end of the site to put your information in so they know who you are that is NOT public record.
 
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TParker said:
EAA has published their comment guide here
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Take a good look at this, they point out a few very concerning areas... like the FAA's question of "should we require homebuilts to comply with Part 36?"
This would be an unmitigated disaster and would effectively permanently kill off new homebuilt registrations, and permanently ground existing ones any time you changed something external, or with your engine/prop, because the cost of demonstrating compliance would make it impossible.

Get your comments in, but do it in your own words...
 
rmartingt said:
Take a good look at this, they point out a few very concerning areas... like the FAA's question of "should we require homebuilts to comply with Part 36?"
This would be an unmitigated disaster and would effectively permanently kill off new homebuilt registrations, and permanently ground existing ones any time you changed something external, or with your engine/prop, because the cost of demonstrating compliance would make it impossible.

Get your comments in, but do it in your own words...
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HEY!! Have you submitted your comments yet?? YOU HAVE 5 MORE DAYS TO GET THEM IN!!! Quit putting this off! It involves WAY more than just pilots and Light Sport medicals. Read the EAA comment guide and get those comments IN!! The future of how we fly is up to US! Will your comments really make a difference? Your NOT commenting will!
DO IT NOW!! That could be construed as a direct order.......sir........ :D
 
Matt and Larry, my idea was that Vs1 is a more basic metric for slicing the fleet into light and heavy for the proposed medical cert category. From what I have read, one or more of the big organizations EAA? have suggested an increased Vs1 of 57 knots to capture a number popular types - Cherokees, most RV's ? into the DL category. This would have a similar effect to using Vs0, but with the more basic metric. If FAA will go along with this, I think that is reasonable. Good.

ron
 
Cumulo said:
Further, if VSO is used, it will open the door to expensive solutions to lower the VSO with retractable slats, double slotted flaps and what-have-you. VS1 favors a wing loading limit which I believe correlates to survivability and safety without demands for complexity.
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I for one am in favor of setting it to Vs0 for exactly this reason. A wide speed range is IMO the best property of any design, and there are always tradeoffs. The experimental market has produced everything from a Velocity Swearingen SX-300 to a Zenith and all the tradeoffs that come with optimizing for speed or STOL, but thus far nobody has had much incentive to play the game of optimizing for both in a single plane. I would love to see what innovations like movable leading edge devices would yield a Vs0 right at a regulatory limit while being as fast as possible. So far the only experimental I'm aware of receiving that kind of attention is Mike Patey's "Scrappy".

Any posts describing Vs1 as relating to a fundamental metric of design are certainly right, I just want to see what clever designers are capable of doing with a Vs0 limit instead. Movable slats on an RV? Sign me up!
 
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I sent in the following comment:

Presently I hold a repairman certificate for a plane I built but no longer own. Now I own a plane I did not build but cannot be the repairman for. The FAA will issue a repairman certificate to a person owning a S-LSA who attends a school but has NO EXPERIENCE AT ALL building or working on any aircraft. This makes no sense at all since the newbie can now work on, inspect, and sign off condition inspections on the aircraft with no practical experience.

I would propose the FAA allow a person who holds a repairman certificate for an experimental aircraft to attend some proscribed school that allows them to apply that certificate to another EAB aircraft.

Ed Lee, EAA 1026063
CFII, ASEL, AMEL
Builder Sonex N72EL
Owner Vans RV-9A N37EL
 
Tony Kirk said:
Van's has posted their response.

https://www.vansaircraft.com/2024/01/vans-aircraft-thoughts-on-eaas-mosaic-comments-and-guidance/
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If you haven't submitted your response, please click on this and read what Van's had to contribute to the comments. Even if you already submitted your response, it is good to hear what the Mother Ship is thinking.

NOW: YOU HAVE UNTIL MONDAY TO SUBMIT YOUR OPINION! 🕰️THERE IS TOO MUCH FOOTBALL🏈 GOING ON THIS WEEKEND FOR YOU TO PUT THIS OFF!!

Am I yelling? Perhaps. Yes. Get this done!

If you are reading this, you are already sitting at your computer. Write something up! You do not have to cover ALL the topics in the proposal, just the ones you are concerned with or that will affect you/us.

This is your chance to influence what happens to the future of our segment of aviation! Get those keys a-clacking! 🙂
 
Tony Kirk said:
Van's has posted their response.

https://www.vansaircraft.com/2024/01/vans-aircraft-thoughts-on-eaas-mosaic-comments-and-guidance/
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Interesting that Van's quoted the stall speeds of the -10 and -14 in CAS and not IAS, as they have done previously. So they have made some effort to quantify the static position and instrument errors at low speeds and make the correction from IAS to CAS. Glad to see that. It's a necessary step to show compliance with any new rule.

"In addition, the clean stall speeds of the RV-14 and RV-10 aircraft are 61 KCAS and 65 KCAS respectively."​
 
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Roadjunkie1 said:
If you haven't submitted your response, please click on this and read what Van's had to contribute to the comments. Even if you already submitted your response, it is good to hear what the Mother Ship is thinking.

NOW: YOU HAVE UNTIL MONDAY TO SUBMIT YOUR OPINION! 🕰️THERE IS TOO MUCH FOOTBALL🏈 GOING ON THIS WEEKEND FOR YOU TO PUT THIS OFF!!

Am I yelling? Perhaps. Yes. Get this done!

If you are reading this, you are already sitting at your computer. Write something up! You do not have to cover ALL the topics in the proposal, just the ones you are concerned with or that will affect you/us.

This is your chance to influence what happens to the future of our segment of aviation! Get those keys a-clacking! 🙂
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Done!
 
Tony Kirk said:
Van's has posted their response.
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Finally! (But I do understand that the folks there have had other priorities lately...)

Roadjunkie1 said:
DO IT NOW!!
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Yes! Do it now! That link again is

Regulations.gov

www.regulations.gov www.regulations.gov

I like Van's note saying that Primary Category currently requires a Vso of 61 knots or less. That seems like a reasonable limit, much much better than 54 knots Vs1.

(For those interested in the rationale behind these numbers, Barnaby Wainfan gives a good explanation in this video; fast-forward to 9 minutes, and the real meat begins around 10:40. It shows that, if your airplane's stall speed is 61 knots, then your best-glide will be a few knots faster than that, and a typical airplane's L/D will be such that the glide slope will be shallower than 30 degrees, i.e. hitting the ground without flaring (Navy style) should be survivable. As for the current LSA number, 45 knots: Crashes are theoretically survivable at almost any angle, i.e. you'll probably survive a crash unless you fly into a brick wall... according to the "Curve of Doom").
 

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The way I see it, the light sport category allows people to fly those airplanes with a valid driver’s license in place of the 3rd class medical. Now they are proposing to update it so a person could fly a multi engine airplane and fly at night. If a person can mentally and physically fly a multi engine airplane and fly at night, they should be allowed to fly an airplane with a higher VS1 speed than they are proposing or be able to use the VSO speed with conventional flaps only. This is basically the comment I sent in.
 
Not to thread-slide, but a quick Look at the Curve of Doom over my morning coffee suggests that a perfect greaser landing (zero degree descent angle) is not survivable if performed at over 77 knots. I'm sure this means I need to listen to Barnaby's whole presentation... sometime.
 
OK, Forum Followers: What date is it today?? January 22! (How is that possible? Where is this month going....already?!?!) What is so special about this date?? IT IS THE LAST DAY YOU CAN SUBMIT COMMENTS TO THE MOSAIC NPRM, FAA-2023-1377!! SO: you cannot put this off any longer if you are going to submit a comment....and why would you NOT :mad::mad::mad:🤬🤬🤬submit a comment??

Use the LINKS in the above posts to find suggestions from the EAA, suggestions from Vans and other forum comments, and the FAA website that will take you to the COMMENT SECTION. This is it, people! TOMORROW WILL BE TOO LATE!!!

DO IT NOW!!!

Your Aviation Activity Future Self will thank you!!
 
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Well, the comment period is over. It will be interesting to see how our comments changed things or if it was an exercise in futility. It was interesting to see that they extended the comment period as I think the response was bigger than they had anticipated. We shall see. WE AREN'T HAPPY UNTIL YOU AREN'T HAPPY. I'll give them the benefit of the doubt. I, personally, appreciate everyone who did submit comments. If you don't swing the bat, you will not hit the ball. Now we'll wait and see.....................😑
 
I tried to follow the proposed changes, They are extensive. Sport pilot and Private are not much different, save for more than one passenger.... IFR. That is good. I recall night is now OK not to mention the increase in planes that qualify as Light Sport. If the new rules go into effect, 150s and 152s, as well as a Cessna 172, 172RG, 170, 180, and some 182s will be light sport? WOW... There is no weight limit but only a limit on stall. With 4 seats limited to one passenger. Very progressive.

I don't know what to think. Pretty sweeping and libral rules change. Also add the no medical self certify, and basic medical, many changes. Boowho for me, I have to keep up. I guess it is good... HOWEVER...

I ASSUME safety is still important? That means pilots without major medical conditions and trust pilots will ground their self, I assume. (You can get a Gen Practice Doc to sign off a tuna fish sandwich). I assume planes that are easy to fly with low stall speeds, fly at lower slower? A C180 is a Light Sport Plane. OK.

As a CFI I have to understand this. At this time I will take a wait and see. Until is is in the FAR's it means nothing to me personally.
 
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