Take Action! MOSAIC comment period.

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Tony R

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There are a some super intelligent folks here that can better convey why limiting to 1 pax or 54 knot VS1 is too limited. Can we get someone to eloquently write a letter so we all can speak with one voice to the FAA? My gun club has a lawyer that drafts letters for members to submit to legislators so we don't send conflicting messages.

Let's use the power of this forum and our collective voice to possibly influence the change.

I don't want to waste this opportunity.
 
Tony R said:
I don't want to waste this opportunity.
Click to expand...

I appreciate the childlike optimism of some, it really takes all kinds to make this world go round.

At any rate, I'm afraid there's nothing really for you to waste. They didn't do that arbitrarily. They know what they're doing.

Comment periods in my experience (oh let's see, part 23, ERAU bolt hole AD, 100hr eddy current Hartzell AD, erau final AD still being sharpened behind the cloak of that admin swamp, I could go on), offer little more than a cathartic release for impotent rage, but fundamentally don't change the parts they really don't want to change.

Mickey mouse "what the definition of 'is' is" verbiage stuff? Sure. But they're not going to change the one thing that would make a fully depreciated Mooney or bonanza into the fold of LSA Shangri-effin-La because "gee chucks, we were hard fast on it, but that SGOTI sure made a compelling argument, and he writes so well...". It also provides cover and the veneer of democracy, without any of the enfranchisement. In a way, participating in that charade is to give legitimacy to that admin tyranny. I rather they dispensed with the platitude, and just said what they meant. I find it less offensive when people tell me they're effing me to my face, but that's me and my predilections. ;)

The unelected and unrepresentative lifetime monarchy that is the modern SCOTUS decreed a while ago that money is speech, legal figments are persons with rights, and bribery is not illegal depending on how much money your buddy has. Which is to say we're all relative mutes by that metric down here in the 'stfu and row!' section of this pay-to-play ship.

But hey, I'm rooting for ya Andy Dufresne. To quote the warden: "[They] Sure can [ignore you forever].. but you write your letters if it makes you happy, I'll even mail 'em for ya, how's that?" :rofl:


On a serious note, I'll make you a deal Tony. They change the Vs1 to 63knots (the KCAS Vs1 to qualify a Beech C33A) and you can PM me and I'll Zelle ya $100 for you to purchase a steak dinner with the frau or mistress at the eatery of your choice. You have my word on it. Which is to say, that and screaming into the FAA void, will get you a steak dinner.
 
Hindsight is nearly 2020 on this. Perhaps with enough crying the VS1 *might* get changed to VS0 but I'm not holding my breath & neither should you. More than one passenger for Sport Pilot? Nope! Not gonna happen ...
 
hindsight2020 said:
I appreciate the childlike optimism of some, it really takes all kinds to make this world go round.

At any rate, I'm afraid there's nothing really for you to waste. They didn't do that arbitrarily. They know what they're doing.

Comment periods in my experience (oh let's see, part 23, ERAU bolt hole AD, 100hr eddy current Hartzell AD, erau final AD still being sharpened behind the cloak of that admin swamp, I could go on), offer little more than a cathartic release for impotent rage, but fundamentally don't change the parts they really don't want to change.

Mickey mouse "what the definition of 'is' is" verbiage stuff? Sure. But they're not going to change the one thing that would make a fully depreciated Mooney or bonanza into the fold of LSA Shangri-effin-La because "gee chucks, we were hard fast on it, but that SGOTI sure made a compelling argument, and he writes so well...". It also provides cover and the veneer of democracy, without any of the enfranchisement. In a way, participating in that charade is to give legitimacy to that admin tyranny. I rather they dispensed with the platitude, and just said what they meant. I find it less offensive when people tell me they're effing me to my face, but that's me and my predilections. ;)

The unelected and unrepresentative lifetime monarchy that is the modern SCOTUS decreed a while ago that money is speech, legal figments are persons with rights, and bribery is not illegal depending on how much money your buddy has. Which is to say we're all relative mutes by that metric down here in the 'stfu and row!' section of this pay-to-play ship.

But hey, I'm rooting for ya Andy Dufresne. To quote the warden: "[They] Sure can [ignore you forever].. but you write your letters if it makes you happy, I'll even mail 'em for ya, how's that?" :rofl:


On a serious note, I'll make you a deal Tony. They change the Vs1 to 63knots (the KCAS Vs1 to qualify a Beech C33A) and you can PM me and I'll Zelle ya $100 for you to purchase a steak dinner with the frau or mistress at the eatery of your choice. You have my word on it. Which is to say, that and screaming into the FAA void, will get you a steak dinner.
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When cynicism becomes an entertaining art form— no one beats Hindsight. My only comment is they (the FAA) don’t always know what they’re doing. There is typically some misplaced period or comma, or outright misprint/error resulting from internal squabbles or oversights. Every organization does it. A high powered attorney can find such things and slip a shiv between someone’s ribs with surgical skill. “Did you mean…” translates to “here comes the blade”.
 
Tony R said:
I agree it will probably do nothing but at least I can say I did what I could. You've already ceded the power to them by doing nothing. I'd rather walk away a little bloodied up and say I gave my best.
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Very noble but not wise to engage in a fight you are nearly certain you cannot win. I was taught, "A good run is better than a bad stand at anytime."

I do think that some of the small items *may* be negotiable to some extent but at the end of the day the things you've asked for, IMHO, ain't gonna happen. I'm with you as far as having a united front if we are asking for minute changes that may be considered. But if the demands are too great they will go straight into the dumpster and not through the office ...
 
Dale, this is the dialogue, what do you think is appropriate and achievable? In this fight the NPRM is pretty generous already so it is not like they are going to say...those PoA guys are asking for too much, let's throw the whole thing away.

Does anyone here actually read what AOPA is doing for use and how we can help?? Please tell me you are all AOPA members? If you are not please don't comment.
 
Tony R said:
In this fight the NPRM is pretty generous already so it is not like they are going to say...those PoA guys are asking for too much, let's throw the whole thing away.
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Yep ... what they have given is pretty generous and no they won't throw it away. They made a few concessions during the original Sport Pilot rule making and later on there were some other tweaks but they were seeking to solve the two seat "fat ultralight" with no N number issue and the goals were different and very diverse.

This time that they are quite aware of what they are after and the rule will likely stay much as it is written. I do hope that the stall speed might be changed from "clean" to "landing configuration" (Vs1 to Vs0). This would in effect (for those planes using flaps) allow a slightly lower stall speed bringing in a few more planes.

But the fact that we get night, retractable gear, controllable props, more weight & speed tells me that we have gotten (if it stands as written) much more than hoped for. It would be wonderful if they would give a way for pilots to do more maintenance and perhaps take courses to do inspections on their certified aircraft but that's just not gonna happen.

As for me this doesn't really change anything but I'm thrilled for many others that can now fly a plane that they may have been put out of over medical reasons.
 
FWIW, the more issues brought up in the comments, the longer it takes for the FAA to review, categorize, consider, and respond to the comments, and consequently the longer it takes to issue a final rule.
 
Much verbage here - with little actual data. Waiting for actual publication.
 
Daleandee said:
Very noble but not wise to engage in a fight you are nearly certain you cannot win.
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Why??? What are they going to do to you if you submit comments that they disagree with to the NPRM?
 
Half Fast said:
Read it closely. It appears to me that you have to have at least Basic Med to fly at night.
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Why would that be a part of a light sport aircraft or sport certificate rule change? Basic Med all but guarantees one a PPL instead of a sport certificate. Most (many?) sport pilots are flying LSA because they can't pass basic med. Unless...basic med becomes available without an a priori 3rd class medical, which would be amazing for people like me who want a PPL but can't go 3rd class medical.
 
Michael Gallagher said:
Why would that be a part of a light sport aircraft or sport certificate rule change? Basic Med all but guarantees one a PPL instead of a sport certificate. Most (many?) sport pilots are flying LSA because they can't pass basic med. Unless...basic med becomes available without an a priori 3rd class medical, which would be amazing for people like me who want a PPL but can't go 3rd class medical.
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I don't disagree with anything you wrote. I'm merely pointing out what the proposed rule says.

§ 61.329 How do I obtain privileges to​
operate an aircraft at night?​
​
You may act as pilot in command​
with a sport pilot certificate during​
night operations if you:​
.​
.​
.​
(d) Either hold a medical certificate​
issued under part 67 of this chapter or,​
provided the pilot holds a valid U.S.​
driver’s license, meet the requirements​
of § 61.23(c)(3) and conduct the​
operation consistently with § 61.113(i).​

61.23(c)(3) is Basic Med.
 
Half Fast said:
I don't disagree with anything you wrote. I'm merely pointing out what the proposed rule says.

§ 61.329 How do I obtain privileges to​
operate an aircraft at night?​
​
You may act as pilot in command​
with a sport pilot certificate during​
night operations if you:​
.​
.​
.​
(d) Either hold a medical certificate​
issued under part 67 of this chapter or,​
provided the pilot holds a valid U.S.​
driver’s license, meet the requirements​
of § 61.23(c)(3) and conduct the​
operation consistently with § 61.113(i).​

61.23(c)(3) is Basic Med.
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Yeah, that's kind of weird. How many people have a Sport Cert but also BasicMed?
Maybe enough of us can comment and request that the requirement for having a previous Class 3 to be BasicMed eligible be removed. And then we can all go outside and shout into the wind, for good measure.
 
Michael Gallagher said:
Most (many?) sport pilots are flying LSA because they can't pass basic med.
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Or because their needs don't run to larger or faster aircraft, and they don't need the medical hassle.. why bother? I have a PP, but flew without a medical or basicmed for a number of years because my planes fit the LSA limits. When I bought a heavier plane, I got a medical and then went basicmed.
 
While I tend to agree that any NPRM formal comments are unlikely to get much traction, I went ahead and submitted a formal comment earlier today anyway.

I suggested that VS1 to be increased to 60 knots. This would help make more (most?) PA-28s eligible under MOSAIC, since they're the Piper equivalent of the C172 (which generally already meets the VS1 limitation).
 
I think that regardless of the number selected by FAA, the rational limit is Vs0 because clean stall speed has no impact on pilot skill and judgment to fly but low landing speed arguably does have an impact.

Incidentally 54 kts Vs0 would (in my view properly) include more aircraft.
 
It is interesting that they chose Medical/Basic Med as the limiting factor for flying at night instead of a higher-level cert exercising SP privileges. I'm guessing that it is due to the frequency and/or rigor of the DL vision test. In my state, with renewal by mail, one can go quite a few years without having a vision test at the DMV.

I have not read the entire document, so I may be asking a question that has already been answered, but do they explain their rationale in any of the discussion parts of the document?
 
Tusayan said:
I think that regardless of the number selected by FAA, the rational limit is Vs0 because clean stall speed has no impact on pilot skill and judgment to fly but low landing speed arguably does have an impact.

Incidentally 54 kts Vs0 would (in my view properly) include more aircraft.
Click to expand...

I agree, but for whatever reason, FAA seems hung-up on using VS1.
 
Stevel said:
It is interesting that they chose Medical/Basic Med as the limiting factor for flying at night instead of a higher-level cert exercising SP privileges. I'm guessing that it is due to the frequency and/or rigor of the DL vision test. In my state, with renewal by mail, one can go quite a few years without having a vision test at the DMV.

I have not read the entire document, so I may be asking a question that has already been answered, but do they explain their rationale in any of the discussion parts of the document?
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"Proposed § 61.329(d) would
also set forth certain medical
requirements: the PIC must either hold
a medical certificate issued under part
67, subpart D, Third-Class Airman
Medical Certificate, or meet the
requirements of § 61.23(c)(3) as long as
the person holds a valid U.S. driver’s
license. Additionally, the operation
would be required to be conducted
consistent with § 61.113(i). If there is
any conflict between § 61.113(i) and
proposed § 61.315(d)(4), then proposed
§ 61.315(d)(4) would take precedence."
 
Capt. Geoffrey Thorpe said:
"Proposed § 61.329(d) would
also set forth certain medical
requirements: the PIC must either hold
a medical certificate issued under part
67, subpart D, Third-Class Airman
Medical Certificate, or meet the
requirements of § 61.23(c)(3) as long as
the person holds a valid U.S. driver’s
license. Additionally, the operation
would be required to be conducted
consistent with § 61.113(i). If there is
any conflict between § 61.113(i) and
proposed § 61.315(d)(4), then proposed
§ 61.315(d)(4) would take precedence."
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Thank you. That changes things. The problem is that the language here didn't make it into the proposed 61.329. Now I'm thinking that this is just a proofreading failure and should be resolved quickly in the comments process.
 
Stevel said:
Thank you. That changes things. The problem is that the language here didn't make it into the proposed 61.329. Now I'm thinking that this is just a proofreading failure and should be resolved quickly in the comments process.
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No, the proposed 61.329 is consistent with the quoted language. § 61.23(c)(3) and § 61.113(i) are the BasicMed regulations.
 
Neil Rubin said:
No, the proposed 61.329 is consistent with the quoted language. § 61.23(c)(3) and § 61.113(i) are the BasicMed regulations.
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What I am seeing is a discussion that says they are going to do one thing and the proposed addition doing something else. I am specifically referring to the language about conflicts in each.
 
Stevel said:
What I am seeing is a discussion that says they are going to do one thing and the proposed addition doing something else. I am specifically referring to the language about conflicts in each.
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Earlier it was suggested that I thought anyone commenting would be wasting their time. That's not what I meant even if it was perceived that way. I don't think asking for the Vs1 to be taken to 60 knots or more passengers for sport pilots is ever gonna happen. Ganging up and asking for huge rule changes is not going to be productive. Just my humble opinion.

Having said that, the clean-up of inconsistencies & conflicts should be pointed out. Could we possibly get a BM provision for Sport Pilot Certificate holders that doesn't require a previous medical? I doubt that's what is meant but it makes me warm & fuzzy to think that it's a remote possibility ... :goofy:
 
Daleandee said:
I don't think asking for the Vs1 to be taken to 60 knots or more passengers for sport pilots is ever gonna happen.
Click to expand...

In the words of retired FBI Hostage Negotiator Christopher Voss, "everything in life is a negotiation."

They propose 54, we ask for 60, final rule is somewhere in the middle. Worst case scenario, it stays at 54.
 
Daleandee said:
Earlier it was suggested that I thought anyone commenting would be wasting their time. That's not what I meant even if it was perceived that way. I don't think asking for the Vs1 to be taken to 60 knots or more passengers for sport pilots is ever gonna happen. Ganging up and asking for huge rule changes is not going to be productive. Just my humble opinion.

Having said that, the clean-up of inconsistencies & conflicts should be pointed out. Could we possibly get a BM provision for Sport Pilot Certificate holders that doesn't require a previous medical? I doubt that's what is meant but it makes me warm & fuzzy to think that it's a remote possibility ... :goofy:
Click to expand...
These back and forth posts came from the night flying part seeming to require Basic Med in the language of the section, but the discussion part of the document about that subject seeming to point to granting the ability to earn that privilege to SP in general. Basic Med comes up a lot in the back and forth, but it was not the primary point. Nobody has suggested anything about changing Basic Med itself.
 
Stevel said:
These back and forth posts came from the night flying part seeming to require Basic Med in the language of the section, but the discussion part of the document about that subject seeming to point to granting the ability to earn that privilege to SP in general. Basic Med comes up a lot in the back and forth, but it was not the primary point. Nobody has suggested anything about changing Basic Med itself.
Click to expand...

Actually there have been numerous discussions about desiring to eliminate the need for a previous medical before going to basic med. I'm just hoping against hope that this language in this new NPRM could grant that a Sport Pilot might gain BM without having previously held a medical. I can dream ...
 
Daleandee said:
Actually there have been numerous discussions about desiring to eliminate the need for a previous medical before going to basic med. I'm just hoping against hope that this language in this new NPRM could grant that a Sport Pilot might gain BM without having previously held a medical. I can dream ...
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I was just confused about why you would quote my post to say something about changing Basic Med, as it was not part of that discussion.
 
Stevel said:
I was just confused about why you would quote my post to say something about changing Basic Med, as it was not part of that discussion.
Click to expand...

I was feeding off of your comment, "I am specifically referring to the language about conflicts in each" and trying to elaborate on the the fact of inaccuracies and confusion in the NPRM.

My real excuse is that I'm old and confused ... :eek:
 
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