The FAA’s ahead-of-schedule release of its Modernization of Special Airworthiness Certification proposal (MOSAIC) has the aviation world abuzz—and for good reason.
The proposed rule, scheduled to be published in the Federal Register for comments next week, would greatly expand privileges for light sport aircraft (LSA) pilots, including the ability to fly larger, heavier aircraft at greater speeds. It covers changes to just about every aspect of LSA, from manufacturing and certification to operations, maintenance, and alteration.
But buried within the 318-page document (yes, I read the entire thing, and my head is spinning) are some pretty interesting implications for advanced air mobility (AAM).
Specifically, MOSAIC would allow rotorcraft (defined in the proposal as helicopters and gyroplanes) and electric vertical takeoff and landing (eVTOL) aircraft—which I’ll use interchangeably with the FAA’s term “powered-lift” moving forward—to be certificated as light sport aircraft.
It would also introduce electric propulsion systems to the LSA market and grant rotorcraft privileges to light sport pilots, instructors, and repairmen. In other words, LSA certificate holders may soon be able to fly, instruct on, and repair certain helicopters.
MOSAIC is not yet a final rule, and the FAA’s proposal could change depending on the comments it receives in the 90 days following its publication. But let’s dig into some of the key implications for AAM:
A New Path to Certification for Rotorcraft and Powered-Lift
If MOSAIC is approved as written, helicopters and eVTOL aircraft would enter the light sport arena.
Under current rules, LSA are defined as aircraft other than rotorcraft or powered-lift designs. But the FAA proposes allowing both categories to obtain special airworthiness certification in the light sport category if they are eligible under proposed Section 22.100, which includes the new weight, cruise speed, and stall speed requirements.
Rotorcraft and powered-lift aircraft will also need to adhere to performance-based requirements in the proposed Part 22, which would set out design, production, and airworthiness requirements for the new light-sport inductees. An FAA-accepted consensus standard would serve as the means of compliance.
This change would essentially allow any aircraft class to be certified as light sport, so long as they meet those Part 22 performance requirements and are eligible under Section 22.100. Trained compliance staff would also be required to ensure the aircraft fits with the FAA-accepted consensus standard.
While MOSAIC proposes to lift the two-seat limitation for light sport aircraft, rotorcraft and powered-lift aircraft would still have that restriction. This means air taxi models, like Joby or Archer Aviation’s, wouldn’t fit the bill, but personal eVTOLs with one or two seats would be eligible.
The agency has also asked commenters to chime in with potential weight and noise restrictions for these aircraft.
New Aircraft, New Rules
Of course, incorporating these new aircraft into the light sport class will require a slew of regulatory changes.
Though the FAA proposes relaxing stall speed restrictions for LSA, rotorcraft and powered-lift aircraft won’t face any limitations due to their ability to hover (or, in the case of some rotorcraft, autorotate to the ground). The agency also determined rotorcraft and powered-lift designs inherently place a cap on cruise speed, eliminating the need for a limit.
Instead, it proposes powered-lift manufacturers determine the minimum safe speed for each of the aircraft’s phases of flight, including lift, transition, and wing-borne cruise. The proposed Section 22.115 calls for those estimates to account for the most adverse conditions in each phase, giving pilots an idea of how to transition safely between flight modes.
Powered-lift aircraft and some rotorcraft will need to be designed with “safe, controllable, and predictable characteristics” that would allow a pilot to keep control of the aircraft in the event of an engine failure. The FAA suggested some form of automation could help fulfill this requirement.
Since some powered-lift aircraft and rotorcraft are unable to initiate a controlled landing in emergency situations—a feature inherent in airplane designs—the agency also proposes requiring all light sport aircraft to allow the pilot to maintain directional control, including during descent. This includes airplanes, as new designs may not inherently have that capability.
And finally, MOSAIC proposes rules for powered-lift operations near airports. In Class G airspace, powered-lift aircraft in wing-borne flight (which the agency treats as fixed-wing aircraft) can only make left turns unless the airport declares otherwise, the same as airplanes. The idea is to separate aircraft the FAA considers fixed-wing from other traffic, such as helicopters.
…And New Privileges
Already have a light-sport pilot, instructor, or mechanic rating? Good news: The FAA wants to expand your privileges.
Flight
MOSAIC proposes an amendment that would allow sport pilots to operate “certain simple-to-fly helicopters.” To be eligible, a helicopter would need to be certificated under the proposed Section 21.190 and include simplified flight controls.
The proposal would add helicopter-specific areas of operation and tasks that would apply to sport pilots seeking to fly a helicopter. These would include hovering maneuvers and ground and flight training on heliport operations from an instructor.
Sport pilots would still need to be proficient in other operations currently in the rule (such as takeoff, landing, and performance maneuvers) but would be excepted from operations such as ground reference maneuvers, slow flight, and stalls.
The FAA argues that the minimum experience requirements for a recreational pilot to obtain a helicopter rating also fit sport pilots seeking that designation, since the operational limitations are nearly identical. As such, it would require the latter to complete:
- 30 hours total helicopter flight time.
- 15 hours flight training.
- Five hours of solo flight.
- Two hours flight training enroute to an airport more than 25 nm from where the applicant normally trains.
- Three takeoffs and landings at an airport more than 25 nm from where the applicant normally trains.
- Three hours of solo flying in the aircraft for the privilege sought on the applicable areas of operation listed in Section 61.98 (which would include helicopter-specific operations).
Applicants would also need to complete three hours of training with an authorized instructor to prepare for a practical test. The test would cover areas of operation addressed under the proposed Sport Pilot Helicopter Airman Certification Standards (ACS), such as pre- and postflight procedures, performance maneuvers, airport and heliport operations, takeoffs, and landings.
Sport pilots seeking to add a helicopter rating would also need to complete a knowledge test, as opposed to the less stringent proficiency check that currently allows them to add new privileges.
Since powered-lift designs are complex and many are still in development, MOSAIC would not allow sport pilots to fly them—at least not yet. The FAA hinted it may consider adding that privilege for aircraft that fit within the constraints of sport pilot operations and certification requirements. For now, though, the agency has proposed separate powered-lift pilot certification and training requirements.
Instruction
Like sport pilots, sport pilot instructors would also gain helicopter privileges under MOSAIC.
Similarly, instructors would need to pass a knowledge test and a practical test based on a proposed Sport Flight Instructor Helicopter ACS, which resembles the Sport Pilot Helicopter ACS but includes a few extra study areas.
They would be required to log ground and flight training on areas of operation that apply to other aircraft, as well as the newly proposed helicopter-specific operations. The FAA also wants to add a “special operations” area, which would encompass some of the tasks under the Sport Flight Instructor Helicopter ACS. However, like pilots, they would also be exempt from operations such as slow flight and stalls.
In terms of experience, sport pilot instructors would need to accumulate 150 hours of flight time as pilot in command (PIC), including:
- 100 hours flight time as PIC of a powered aircraft.
- 50 hours flight time in a rotorcraft or helicopter.
- 25 hours cross-country flight time.
- 10 hours cross-country flight time in a rotorcraft or helicopter.
- 15 hours flight time as PIC of a helicopter.
To address the vacuum of sport pilot instructors that may be created when MOSAIC takes effect, the FAA proposes relying on Subpart H instructors who already have a rotorcraft category helicopter rating on their certificate.
The agency would allow these instructors to receive training and endorsements from manufacturers of simplified-control helicopters, qualifying them to train other instructors or sport pilots seeking helicopter privileges, training, and endorsement. In the FAA’s view, this would establish an initial group of instructors with helicopter privileges.
Repairs
With their expanded privileges, sport pilots and instructors have cause for celebration. But repairmen also have reason to rejoice!
Since MOSAIC would add rotorcraft and powered-lift aircraft to the light-sport category, the FAA anticipates an influx of aircraft in the market—and greater demand for repairs. Fittingly, it proposes an alteration to the repairman certificate (light sport aircraft) that would allow holders to work not only with helicopters but also powered-lift aircraft.
Training course providers would have six months following MOSAIC’s effective date to comply with newly proposed training standards, which are based on the existing ACS for aviation maintenance technicians. During that time, repairmen seeking to work with rotorcraft and powered-lift aircraft will need to complete an ACS-based course rather than an hours-based course.
To add helicopter or gyroplane privileges, MOSAIC would only require repairmen to complete a single rotorcraft training course, which covers both of those categories.
Electric Aircraft Enter the Fray
MOSAIC’s implications for light sport aircraft are without a doubt exciting. You could even say they’re electric—literally.
Currently, the definition of LSA limits designs to a single reciprocating engine, if powered. But MOSAIC proposes to omit this requirement, opening up the market to all kinds of engine and propulsion systems.
Per the FAA, this should encourage the development and innovation of different powerplants for LSA, “especially electric-powered aircraft.” It contends that any risk from the rule change would be mitigated by the aircraft and pilot certification process, but its benefits could range from a reduction in cost and emissions to much greater ease of operation.
The agency noted that the current American Society for Testing and Materials Standard F2840 lays the groundwork for developing electric propulsion units for electric-powered aircraft that cannot currently be certified as light sport aircraft. Accordingly, it recommended revising that standard to account for propulsion units that could be installed on rotorcraft, powered-lift aircraft, and any other new aircraft that might be certified as light-sport under MOSAIC.
Importantly, the FAA proposes these electric systems be designed to be removed or isolated, which would help prevent overheating, fire, and damage to electrical systems in the event of a malfunction. They’ll also need to have features that minimize the risk of an electrical fire during an emergency landing.
Should MOSAIC take effect as previewed, chances are it will take a while for the FAA to sort out the manufacturing and operational requirements for electric light sport aircraft. But the agency is clearly committed to incorporating them, and that could one day have a massive impact on aviation emissions.
Final Thoughts
To reemphasize—MOSAIC is simply a proposal, and it could change based on the comments from industry stakeholders. But the incorporation of rotorcraft and powered-lift aircraft into the light-sport category and the expanded privileges of sport pilots, instructors, and repairmen are likely to stick, at least in some form.
That could be a game-changer for the personal eVTOL market in particular. One- and two-seater eVTOL manufacturers such as Air and Jetson, which currently would need to endure the lengthy special type-certification process, could theoretically speed up things by certifying in the light-sport category.
The helicopter market stands to benefit greatly. That industry, like many others, is currently facing a pilot shortage, and it could get a boost from newly certificated light sport pilots, instructors, and repairmen.
The outlook for electric light sport aircraft is a bit murkier—if MOSAIC is approved, the FAA will still have some rulemaking to do in order to give them a lift. But in removing the single-engine requirement, the agency specifically singled out electric aircraft as a beneficiary, giving hope that it will continue its efforts in that regard.
In short, MOSAIC won’t be approved for at least a few months, and it won’t take effect until six months after that. But when it does, expect a major shakeup for AAM.
