MOSAIC Roadblocks

wetzelaviation

wetzelaviation

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So as many people know the FAA started pushing MOSAIC in July at Airventure. The first part of the changes went into 22 Oct 2025 but currently no new LSRM or LSRI are being issued at this time. The FSDO’s are stating that they are waiting on guidance on how to process the applications. So in essence we have a regulation that the FSDO’s are not able to do anything with.

In addition, the FAA put out several guidance documents including this one - https://www.faa.gov/newsroom/fact_sheets/MOSAIC_Fact_Sheet.pdf - which states that some operating limitations need to be updated before the rules can be exercised under the new regulations. Same story with updating our operating limitations. So my question is why did they approve MOSAIC with a 22 Oct 2025 go live date if they we’re gonna block the very things and information that the keep putting out. Apparently something is seriously wrong somewhere and the process needs to be fixed to match the regulations that are now in effect.

It is wild that the FSDO would be put into this position and not be able to do anything with the regulations that are already in place.
 
wetzelaviation said:
It is wild that the FSDO would be put into this position and not be able to do anything with the regulations that are already in place.
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In general, it helps to have an understanding of how the APA system works. Given MOSAIC has split effective dates there are some overlaps that will not be completed until July 2026.

And while the MOSAIC NPRM was finalized via the APA process there are additional processes that must be completed to get those new rules down to the ground floor so to speak.

Every new FAA rule goes this process except emergency ADs. And as noted, throw in a shutdown at the same time and everything gets backed up.
 
Bell206 said:
In general, it helps to have an understanding of how the APA system works. Given MOSAIC has split effective dates there are some overlaps that will not be completed until July 2026.

And while the MOSAIC NPRM was finalized via the APA process there are additional processes that must be completed to get those new rules down to the ground floor so to speak.

Every new FAA rule goes this process except emergency ADs. And as noted, throw in a shutdown at the same time and everything gets backed up.
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I definitely get it. This goes to show what fallout occurs as a result of the shutdown. Hopefully they figure it out soon. It doesn’t seem like most of this is remotely something that would have been affected by the shutdown. Operating limitations for example have a process and that’s not changing.
 
wetzelaviation said:
I definitely get it. This goes to show what fallout occurs as a result of the shutdown. Hopefully they figure it out soon. It doesn’t seem like most of this is remotely something that would have been affected by the shutdown. Operating limitations for example have a process and that’s not changing.
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Backlogs. A month plus worth.
 
The FAA will need to issue a revision of FAA Order 8130.2, which contains the template for creating operating limitations. Some other order doubtless contains guidance for the issuance of certificates and will also need to be updated.
 
I'm in the same boat but happy to wait given the blessing this is to many of us EAB owners.
 
wetzelaviation said:
Operating limitations for example have a process and that’s not changing.
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Even without the shutdown it would have tsken a while to get all supportive documentation updated. However, I believe the operating limitations changes are tied to the certification revisions that come into effect in 2026.
 
Any day I think of this I search for FAA Order 8130-2L and hope...
 
So MOSIAC 2.0 isn't saving anyone any money? Shocking I tell you. SHOCKING!

If the FAA's been working on this for 20 years you think they would have some of these things all figgered out by now.
 
FORANE said:
Got an email from Carol Carpenter today:
The FAA plans to have the guidance and the new form done by the end of this month.
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Do you know what specific form and guidance this is?
 
4RNB said:
Do you know what specific form and guidance this is?
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Carol is the DAR who runs Rainbow Aviation with her husband Brian. Rainbow Rainbow is the first and one of only three FAA approved schools to offer LSRI/LSRM training. She seems to have an ear to the ground, and even some degree of influence over, the goings on with this aspect of the FAA. The form would be the revised operating limitations. The guidance would be the guidance to the FSDO's regarding how to issue LSRI/LSRM certifications.

My FSDO contact advised me on Nov 20th that he had everything necessary to issue my LSRI certification except the guidance referenced above. He said he expected to receive that guidance soon, perhaps by the end of the month.

As to the question re: specific form, I do not have knowledge of a specific form number, only that I am hearing from these two sources that it is expected out soon.
 
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FORANE said:
Carol is the DAR who runs Rainbow Aviation with her husband Brian. Rainbow Rainbow is the first and one of only three FAA approved schools to offer LSRI/LSRM training. She seems to have an ear to the ground, and even some degree of influence over, the goings on with this aspect of the FAA. The form would be the revised operating limitations. The guidance would be the guidance to the FSDO's regarding how to issue LSRI/LSRM certifications.

My FSDO contact advised me on Nov 20th that he had everything necessary to issue my LSRI certification except the guidance referenced above. He said he expected to receive that guidance soon, perhaps by the end of the month.

As to the question re: specific form, I do not have knowledge of a specific form number, only that I am hearing from these two sources that it is expected out soon.
Click to expand...

Thanks for the details.
My understanding is FAA order 8130-2K needs updated to the L form in order for DARs to have new methods of issuing airworthiness documents.
I'll PM you
 
wetzelaviation said:
So as many people know the FAA started pushing MOSAIC in July at Airventure. The first part of the changes went into 22 Oct 2025 but currently no new LSRM or LSRI are being issued at this time. The FSDO’s are stating that they are waiting on guidance on how to process the applications. So in essence we have a regulation that the FSDO’s are not able to do anything with.

In addition, the FAA put out several guidance documents including this one - https://www.faa.gov/newsroom/fact_sheets/MOSAIC_Fact_Sheet.pdf - which states that some operating limitations need to be updated before the rules can be exercised under the new regulations. Same story with updating our operating limitations. So my question is why did they approve MOSAIC with a 22 Oct 2025 go live date if they we’re gonna block the very things and information that the keep putting out. Apparently something is seriously wrong somewhere and the process needs to be fixed to match the regulations that are now in effect.

It is wild that the FSDO would be put into this position and not be able to do anything with the regulations that are already in place.
Click to expand...
Basic question here:

What is LSRM and LSRI?
 
RalphInCA said:
Basic question here:

What is LSRM and LSRI?
Click to expand...
light sport repairman inspection and light sport repairman maintenance
MOSAIC expanded the light sport maintenance and light sport repairman certifications to include experimental armature built aircraft. Now, after one has completed the 2 day lsri or the 15 day lsrm course they may sign off the condition inspection on EAB aircraft.
 
It's also possible the FAA may issue a national policy memo to provide an interim path while the normal Order Policy documents are updated. Perhaps inquire with your FSDO or other contacts
 
FORANE said:
light sport repairman inspection and light sport repairman maintenance
MOSAIC expanded the light sport maintenance and light sport repairman certifications to include experimental armature built aircraft. Now, after one has completed the 2 day lsri or the 15 day lsrm course they may sign off the condition inspection on EAB aircraft.
Click to expand...
To elaborate:

The holder of an LSRI certificate may perform the annual condition inspection on an ELSA (experimental-light sport) or EAB (experimental-amateur built) aircraft owned by the certificate holder.

The holder of an LSRM certificate may perform maintenance and the annual condition inspection on an ELSA or SLSA (special light-sport, i.e. factory built) aircraft.

No certificate is required to perform maintenance on any experimental aircraft, only for the inspection.
 
Bell206 said:
It's also possible the FAA may issue a national policy memo to provide an interim path while the normal Order Policy documents are updated. Perhaps inquire with your FSDO or other contacts
Click to expand...
There's been hope that a simple position statement could be issued negating the need for all the busywork of redoing op lims. Carol said the FAA lawyers say that is not an option.
No matter, it will come to pass. I received another email from Carol today saying:
The FAA maintenance division told me they plan for the update by the end of Dec
You should be able to make an appointment in January
 
FORANE said:
There's been hope that a simple position statement could be issued negating the need for all the busywork of redoing op lims.
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Policy Memos are only temporary until the appropriate permanent Order is revised. As you found no permanent shortcuts allowed. Memos alse provide a temp regulatory path when a large section of "working" documents need to be updated such as 1000s of OpsLimits. I can only state its being looked at this point.
 
Dana said:
To elaborate:

The holder of an LSRI certificate may perform the annual condition inspection on an ELSA (experimental-light sport) or EAB (experimental-amateur built) aircraft owned by the certificate holder.

The holder of an LSRM certificate may perform maintenance and the annual condition inspection on an ELSA or SLSA (special light-sport, i.e. factory built) aircraft. AND EAB

No certificate is required to perform maintenance on any experimental aircraft, only for the inspection.
Click to expand...
 
wetzelaviation said:
So my question is why did they approve MOSAIC with a 22 Oct 2025 go live date if they we’re gonna block the very things and information that the keep putting out.
Click to expand...

It's not a MOSAIC or FAA thing. Once a proposed rule is published (which happened in 2023), matters of timing are dictated by the Administrative Procedures Act. Once the ball is rolling, the relevant federal agency (in this case, FAA) loses a lot of discretion.

Overall, minimizing agency discretion is a very good thing. It forces the hand of a federal agency to publish a final rule in a reasonable, timely manner; otherwise some desk jockey could just say "we're working on it" in perpetuity, with little accountability.

So, as a practical matter, working out the finer details may take a little time, since they didn't really have any discretion to move the effective date, once the final rule was published.
 
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RalphInCA said:
What is LSRM and LSRI?
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Its gonna make everyone an <sarcasm> AnP/IA </sarcasm> in 16 hours or two weeks.

Think about it... a person 'off the street' can take a two week class and now sign off other peoples condition inspections for LSA/ELSA/EAB.

I have my doubts. I hope it works out though... because people can die if safety issues are not found/corrected. Also who would want the liability of signing off another persons plane? And who would think that a person with a entire two weeks of training has the skills to find these safety issues?
 
pfarber said:
Its gonna make everyone an <sarcasm> AnP/IA </sarcasm> in 16 hours or two weeks.

Think about it... a person 'off the street' can take a two week class and now sign off other peoples condition inspections for LSA/ELSA/EAB.

I have my doubts. I hope it works out though... because people can die if safety issues are not found/corrected. Also who would want the liability of signing off another persons plane? And who would think that a person with a entire two weeks of training has the skills to find these safety issues?
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I doubt that the effect (or even the intent) is to have someone sign off other people’s airplanes. But it does give the opportunity to sign off one’s own airplane.

Unlike A&P school, it’ll probably be self-limiting…people who have no experience maintaining anything probably won’t assume the course will teach them how to do it.
 
MauleSkinner said:
I doubt that the effect (or even the intent) is to have someone sign off other people’s airplanes.
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The LSRM does allow one to sign off other aircraft; the LSRI only the holders aircraft.

pfarber said:
Its gonna make everyone an <sarcasm> AnP/IA </sarcasm> in 16 hours or two weeks.
Click to expand...
But they'll probably come out with a better understanding on how aviation mx works then you do. No?;)
 
pfarber said:
Its gonna make everyone an <sarcasm> AnP/IA </sarcasm> in 16 hours or two weeks.

Think about it... a person 'off the street' can take a two week class and now sign off other peoples condition inspections for LSA/ELSA/EAB.

I have my doubts. I hope it works out though... because people can die if safety issues are not found/corrected. Also who would want the liability of signing off another persons plane? And who would think that a person with an entire two weeks of training has the skills to find these safety issues?
Click to expand...
I can’t find an AP or IA to sign off my EAB as it is…
 
I like the idea for personal use...signing off my plane that I didnt build. I agree that the two week class wouldnt be adequate for someone wanting to start a business repairing or inspecting others. Insurance has got to be pretty tough for that.
 
I know we will get guidance on this at some point. I don’t think either class completely prepares somebody to actually do the inspections or maintenance. The part everybody forgets is that you must have done the work previously to be able to do that same work or task. What usually happens is the LSRI/M will take additional classes or work with an A&P/IA until they understand all of the intricacies of what the inspections entail. Even with the manufacturers checklist or AC 43.13 as reference there are lots of little things that can bite you if you don’t understand why you are checking the finer details. It took me almost 2 years until I was comfortable to actually do an inspection myself and if I run into anything that doesn’t look quite right the first things I’ll do is contact the manufacturer or an A&P that has worked on that type of aircraft for a second opinion.

I think long term this will help people maintain their aircraft which is the goal. Lots of A&P’s won’t touch EAB for the perceived liabilities if they miss something. I’ve seen some excellent EAB examples and ive seen some that I would not put my family in under any circumstances. It really comes down to the quality of the kit, skill of the builder and if they consulted others along the way when they didn’t understand something.

I’ve found some very minor issues doing inspections and some issues that were pretty serious and I think the range of possibilities on how an aircraft has been maintained and the quality of the work performed. With SLSA’s the maintenance steps are provided by the manufacturer and the same is true for kit planes most of the time. The plans built planes are where I’ve seen some wild deviations from plans and that’s then only thing with the implementation that is bothering me.

I’m hopeful that this will end up working out well for owners and the industry as a whole. We all have to be vigilant and get additional training above and beyond the required training and classes to ensure the goal of MOSAIC is met which is to keep everybody safe and make aviation more attainable (definitely not affordable as we have seen).
 
Since LSRM can get paid for it, I got no beef with scrutiny of those who seek to profit. But wanting to block LSRI? Yeah that's just boilerplate petty gatekeeping. APs generally already favor the sidestepping of EAB and are not particularly worried about losing business due to EAB inspection relief. LSRI-hate reeks of builder elitism. For brevity I'm not going to rehash all the points that illustrate facbuilt mx restrictions aren't a panacea and EAB isn't falling out of the sky even in pre-LSRI inclusion circumstances.

But gatekeepy builders know they've lost the plot when the FAA outflanks them from the left. To those who resemble the remark, I retort with the same "Cope and seethe" I was offered for decades in fac-built. And that's fine, I'm just looking for affordability in flying recreation, I gave up on the myth of pilot solidarity a long time ago.
 
wetzelaviation said:
The part everybody forgets is that you must have done the work previously to be able to do that same work or task.
Click to expand...
There’s a bit more to that rule which is also the same for mechanics. In both rule sets, while there is the option of performing the work under supervision of a mechanic/repairmen to gain the necessary experience to satisfy 65.109(c) and 65.81(a), it also states: If that person has not previously performed that work, the person may show the ability to do the work by performing it to the satisfaction of the FAA […].

And the prevailing guidance of “performing it to the satisfaction of the FAA,” has historically been broad to provide solutions to perform maintenance when there is no available experienced mechanic or repairman with the necessary experience. For example, one can meet that requirement via a field maintenance training course or simply performing the mx to the OEM manual procedures.
 
hindsight2020 said:
Since LSRM can get paid for it, I got no beef with scrutiny of those who seek to profit. But wanting to block LSRI? Yeah that's just boilerplate petty gatekeeping. APs generally already favor the sidestepping of EAB and are not particularly worried about losing business due to EAB inspection relief. LSRI-hate reeks of builder elitism. For brevity I'm not going to rehash all the points that illustrate facbuilt mx restrictions aren't a panacea and EAB isn't falling out of the sky even in pre-LSRI inclusion circumstances.

But gatekeepy builders know they've lost the plot when the FAA outflanks them from the left. To those who resemble the remark, I retort with the same "Cope and seethe" I was offered for decades in fac-built. And that's fine, I'm just looking for affordability in flying recreation, I gave up on the myth of pilot solidarity a long time ago.
Click to expand...

And some just want to play the victim.
 
Bell206 said:
There’s a bit more to that rule which is also the same for mechanics. In both rule sets, while there is the option of performing the work under supervision of a mechanic/repairmen to gain the necessary experience to satisfy 65.109(c) and 65.81(a), it also states: If that person has not previously performed that work, the person may show the ability to do the work by performing it to the satisfaction of the FAA […].

And the prevailing guidance of “performing it to the satisfaction of the FAA,” has historically been broad to provide solutions to perform maintenance when there is no available experienced mechanic or repairman with the necessary experience. For example, one can meet that requirement via a field maintenance training course or simply performing the mx to the OEM manual procedures.
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That’s why I’m saying. I think the LSRM types are getting additional training from Rotax, Jabiru, EAA workshops, FAA Safety, etc.

The maintenance manual definitely rules and the AD’s and following service bulletins. Most of the LSRM’s I know are doing it to maintain their own aircraft mostly. There may be exceptions but I haven’t met anybody working as an LSRM commercially. The insurance is prohibitive and very expensive.

I think people just want to maintain their own aircraft for the most part.
 
wetzelaviation said:
The maintenance manual definitely rules
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I think going forward with the changes, you’ll find Part 43.13 is the defining regulatory rule. However, it does contain references to the maintenance manual but also has another one of those catchall references with: “or other methods, techniques, and practices acceptable to the Administrator” which allows the use of non-OEM mx guidance.

I believe in the end they are bringing the LSRM more in line with the existing mechanic and other repairman rules to meet future goals. At least that’s what I see from following the mx side for many years.

wetzelaviation said:
There may be exceptions but I haven’t met anybody working as an LSRM commercially. The insurance is prohibitive and very expensive.
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I believe it will take a solid year or two with the new LSRM rules in effect to see any changes. With 3rd party EAB inspections now an option for LSRMs, I think you’ll see a new market emerge for their services. Prior to that not much of a market outside of select areas. As to insurance, it will depend on the LSRM’s risk tolerance. For example, I know several A&Ps that work without insurance however are very selective in their clientele or services provided.
 
Dana said:
To elaborate:

The holder of an LSRI certificate may perform the annual condition inspection on an ELSA (experimental-light sport) or EAB (experimental-amateur built) aircraft owned by the certificate holder.

The holder of an LSRM certificate may perform maintenance and the annual condition inspection on an ELSA or SLSA (special light-sport, i.e. factory built) aircraft.

No certificate is required to perform maintenance on any experimental aircraft, only for the inspection.
Click to expand...
I was under the impression that LSRM would be able to do condition inspections on EAB aircraft also, including ones that they do not personally own.
 
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