MOSAIC, New Opportunities?
By Ed Downs
“MOSAIC,” as defined by Google is, “A combination of diverse elements forming a more or less coherent whole.” “MOSAIC,” as defined by the FAA is “MOdernization of Special Airworthiness Certification. Google has it right. And in this case, the “whole” defined by Google is great news for the recreational flying, pilot training and aircraft manufacturing. The final version of the “MOSAIC” rule was signed into law by the FAA and submitted to the Federal Register on July18. This was announced by the FAA at the 2025 EAA AirVenture show and will probably serve as the “start date” for all that is covered by MOSAIC.
Technically, the Federal Register could make some edits and move that date a bit. The “pilot and mechanic” part of the Rule goes into effect 90 days after Aug. 18, 2025, and the aircraft certification part of the Rule goes into effect 365 days after Aug. 18. At this point in time, readers have probably seen a number of summaries of MOSAIC, most focusing on the “significant changes” to the existing Sport Pilot Rule and Sport Pilot limitations. The fact is, MOSAIC is not about Sport Pilots, nor is it a single “rule.”
Like our friends at Google say, MOSAIC is a combination of elements, affecting eleven sections of Title 14 CFR (Code of Federal Regulations, what we call FAR’s), with each section having multiple updates, corrections, and changes. Keep reading! This editorial is not going to try and summarize all 717 pages of MOSAIC but will focus on the main points, which affect existing pilots and those in initial pilot training or thinking of becoming a pilot. More editorials will follow as the “MOSAIC” goes into practice. When all of these elements are put together, a semi-coherent result is that Sport Pilot privileges end up being changed. In other words, what is a Sport Pilot allowed to fly and what privileges are Sport Pilots allowed to exercise as a byproduct of MOSAIC.
First and foremost, MOSIAC defines a new category of flying machine and all the support and certification structure that goes along with it. That new category is “Light Sport Aircraft.” This means “Light Sport Aircraft” joins the ranks of those aircraft categories listed on the backside of a Private Pilot Certificate, such as Airplane, Rotorcraft or Glider (there are more). This is a very big deal; it is the first time a category has been added since 1955.
Well, gosh, one might think, the definition of a Light Sport Aircraft (LSA) was codified in 2004, wasn’t it? What’s the big deal? Did you note the word “definition?” An “LSA” was never an aircraft category, just a definition in FAR 1.1. By upgrading an LSA to a formal category, the FAA chose to make the category much more attractive to aircraft manufacturers but is allowing the certification of new designs that are much more useful than the old LSA definition. This new category can go faster, weigh more, and perform better. It can be stronger and, best of all, it can be certified through the Consensus Standard protocols, not the difficult and lethargic FAA Type Certification Certificate process. In fact, a newly designed and produced LSA (under MOSAIC) receives a Special Airworthiness Certificate and is almost identical to about 80 percent of the most commonly owned airplanes and airplanes used by flight schools. MOSAIC also upgrades maintenance availability by redefining Repairman Certificates. Those who wish to bring new flying machines into the market will love MOSAIC!
So far, so good, but the reader may rightfully ask, “what’s in it for me?” This editorial will not go into the aircraft manufacturing side of MOSAIC, maybe to be covered in editorials to follow. Here is the bottom line of the certification story. A specifically certified LSA under the new MOSAIC standard if virtually identical to about 80 percent of all single engine light aircraft now in service. If you are a Sport Pilot, or exercising the privileges of a Sport Pilot, you do not have to buy or rent a brand new LSA as defined by MOSAIC to get the benefits of the new certification rule. You can just go out to the existing contemporary new or used aircraft market and buy (or rent) one of the many existing flying machines that meet the certification standards of the new LSA category. Virtually all Normal Category single engine aircraft (like the Cessna 172 or Piper Cherrokee line) are good to go. Even older Bonanzas and other such planes, with retractable gear and controllable pitch propellers, may qualify under the new Sport Pilot privileges resulting from MOSAIC. No weight limit, but a speed limit of 250 knots CAS. The stall speed clean (Vs1) cannot exceed 59 knots. Night flying could end up being restricted and no IFR flying.
The real bummer (and still being argued by many) is that if exercising the privileges of a Sport Pilot, you can fly with only one passenger, a truly dumb limitation. At this point you may again be thinking “what’s in it for me” as I am not a Sport Pilot. I am a Private Pilot, or maybe a Commercial Pilot or ATP. Wrong! All you have to do is let your FAA class medical (or Basic med) expire, and you may now exercise the privileges of a Sport Pilot if you have a current, valid driver’s license. Assuming you have already had a Complex Aircraft Endorsement, it is time to walk out to that trusty C-172, kick the tires and light the fires. No flight test, no written exam. As the reader has probably noticed, the big change is that you are not required to have a Class medical or Basic Med.
Basic Med is a good thing, but a Class medical can cost you everything you have put into your flying, virtually at the whim of bureaucrats (not practicing physicians) through the denial process, which kills all flying with any certificate without any form of appeal process other that engaging the Federal Court system. It is the Class medical that is the elephant in the room, and the issue that is most discussed in the Sport Pilot world, be it a new student just getting into flying or a pro that needs to defend a career. Let’s go “pet” that elephant!
Given the 717-page document, less than 50 pages (if you combined them together) specifically address regulatory changes. The remainder address the many inputs that were received during the nearly two year comment period. This is a normal part of the Notice of Proposed Rule Making (NPRM) process that all federal bureaucracies must follow. Many individuals, alphabet groups and companies submitted comments, including this writer. This is a good system, although designed to favor bureaucratic views. A topic frequently covered was the need to insert a Class medical into this process, specifically with night flying and the ability to carry more than one passenger.
As it now stands, to utilize the provisions of Basic Med, one must have undergone at least one Third Class Medical exam given by an FAA approved Aeromedical Examiner (AME), retroactive to 2006. The same is true regarding flying at night under Sport Pilot privileges. What this means is that an entire Federal Bureaucracy (FAA AeroMed) is funded (millions, perhaps billions of dollars) to conduct what might be a once in a lifetime medical examination. The FAA defends this rule by claiming that the physical and mental demands to fly a C-172-like aircraft are so extraordinary that regular medical professionals (your personal doctor, who probably spent at least six years in medical school and additional years as a specialty intern) are unqualified to conduct the typical 3rd Class medical exam, which takes about 20 minutes, often administered by a medical assistant, not the AME.
Somehow, the FAA overlooks the success of Basic Med. Unlike a flight test, written exam, poorly performed Flight Review, failed IPC or even accidental regulatory violation, there is no retake or negotiation. A medical denial is final and flying comes to an end… for life. The only option is court action through the NTSB, a long and expensive process. When addressing the fact that pilots are now almost required to “lie, omit or self-medicate” to save their pilot certificates, the FAA comments responded with a threat of Federal legal action involving fines and/or jail time, the only such reference in the entire rule.
Even NTSB Chair Jennifer Homendy recently commented at an EAA AirVenture Forum that the FAA medical system needs significant revisions, “it is like back to the 1950’s.” The bottom line is a hostile FAA medical system bent on regulatory enforcement, not good health. The original Sport Pilot rule was viewed as having been created so pilots could avoid a class medical. That view is completely wrong, but it has stuck. It is no wonder that this writer, an active CFI, has joined thousands of other aviation educators in advising those with medical concerns to simply let the Class medical expire and get proper care through their personal medical professional, using MedExpress or Sport Pilot Privileges, avoiding the threat of an AeroMed denial.
But in the past, the Sport Pilot option meant being restricted to a small, two-place airplane. That restriction is now gone! Sliding into Sport Pilot is a viable option for avoiding medical bureaucracy. A person making this choice would likely lose little in flying privileges if flying a typical light aircraft for general travel and fun. Of course, we all strongly point out FAR 61.53, which prohibits flying an aircraft with known medical conditions that could prevent safe operation, no matter what medical compliance is being used. As a historical note, while the FAA comments in this Rule use the success of the legacy Sport Pilot rule (2004) and Basic Med to support MOSAIC, the original 2004 version of Sport Pilot was rigorously opposed by FAA Aeromed and written by industry consensus, not the FAA. Basic Med was also rigorously opposed by FAA Aeromed but forced upon the FAA through the Congressional Reauthorization Act of 2015. Let’s end our elephant petting adventure with a note to Secretary of Transportation, Sean Duffy.
“Dear Secretary Duffy,
Know that at least one of the pilots flying the commercial or military airplane you travel in are in violation of federal law, having lied or omitted data on their FAA MedExpress form and that at least one of the FAA controllers managing your flight has done the same. Self-medication to avoid FAA medical issues is common. Isn’t it time to learn from the good health and education model of Basic Med and totally revamp the FAA AeroMed system? By now, people around the world should have learned that deep state, unmonitored bureaucracies do not prevent medical crises. They may, in fact, cause them. I give you COVID.”
As more CFI’s become familiar with MOSAIC, we may find that the Sport Pilot certificate replaces the Private Pilot certificate for entry-level flying. When seeking a Private Pilot license, one is required to enter the FAA medical bureaucracy by applying for at least a Third Class medical certificate (through an AME) before a solo flight can be authorized. No such requirement exists for Sport Pilot training. Sport Pilot training can now be done in aircraft that are operated by almost all flight schools. The main advantage to starting as a Sport Pilot is that the FAA minimum hours of training is reduced from the 40 hours for a Private Pilot Certificate to only 20 hours total time for a Sport Pilot Certificate. Of course, in the real world, both certificates take many hours more than the minimum, but in the end, the new Sport Pilot will be spending half what it takes to become a Private Pilot.
Common sense does kick in, with the minimum-hour Sport Pilot being restricted from flying into complex airspace (Class B, C and D) or operating a plane with retractable landing gear or a controllable pitch prop. But once the initial Sport Pilot Certificate is achieved, the new pilot can now obtain additional training for complex airspace privileges, more complex aircraft or night flying authority. The additional training must be endorsed by an authorized CFI, but there is no additional written exam or flight test involved. This “cafeteria” approach to expanding skills as they are needed work well if flying in rural areas but will probably be incorporated into initial training (with an endorsement for each privilege) in areas of congested airspace.
The basic initial Sport Pilot Certificate requires a minimum of 20 hours total time, divided into 15 hours of dual instruction, 5 hours of solo, 2 hours of cross-county training with 10 landings at an airport involving a traffic pattern. One solo cross-country must be flown with a landing at an airport more than 75 miles from the departure airport, incorporating landings at two locations that are more than 25 nautical miles apart.
For those who are shuddering at these minimum standards, keep in mind that the Sport Pilot Airman Certification Standard (ACS, flight test skills) requires the Sport Pilot applicant to demonstrate skill very similar to a current Private Pilot. The low hourly requirement means, as a CFI, one can train to a performance standard, without having to comply with arbitrary hourly requirements.
All Sport Pilot flying hours are applicable to all higher certificates. This writer hopes that flight schools and independent CFI’s, often locked into traditions of the past, will get a clue, and take advantage of this terrific opportunity to increase training. Start your customer with an economical Sport Pilot certificate and then crank them up to Private, IFR, commercial and ATP as the need arises, but lock the customer in with the lower initial cost. Refer to the following new regulations for details.
• 61.313 Sport Pilot training experience needs, Page 679 of the rule.
• 61.316 Plane that a sport pilot may fly, Page 684 of the Rule.
• 61.321 Adding an additional category of class, Page 685 of the Rule.
• 61.329 Obtaining privileges to operate an aircraft at night, Page 687 of the Rule.
• 61.331 Obtain privileges to operate an aircraft with retractable landing gear or an airplane with a manual controllable pitch propeller, Page 687 of the Rule
One last technical issue regarding MOSAIC has been causing some confusion in summaries that are appearing. As a Sport Pilot, one may fly an airplane with a stalling speed no greater that 59 knots Vs1 (Clean, stall speed with no high lift devices). For an airplane to be certified under MOSAIC (Category, Light Sport Aircraft), it must have a stalling speed no greater than 61 knots Vso (dirty, stall speed with flaps and gear down). This weird difference means a Cirrus SR-20 could be certified as a LSA (not likely) but could not be flown by a person exercising Sport Pilot privileges. More weirdness will probably be exposed as this MOSAIC enters common use.
Had enough… this editorial has covered about 10 pages of the 717 page MOSAIC rule. More fun to come!