MOSAIC Malaise

There’s a fly in MOSAIC’s ointment. A significant number of the country’s flight schools are not fully onboard with all of the FAA’s Modernization of Special Airworthiness Certification (MOSAIC) rules. The new regulations allow Sport pilots to fly a variety of single engine aircraft that they couldn’t before, but Sport pilots around the country report to Kitplanes that they’re being refused rental of legally applicable GA aircraft. Additionally, prospective Sport students say very few of the schools they’ve contacted are willing to train them even though it’s now easier for flight schools to do Sport instruction. 

It’s still a disappointing start for Sport aviation enthusiasts. Paul Hamilton, the operator of a flight school in Carson City, NV specializing in Sport Pilot training, says he’s not surprised at the slow start. “There are a number of valid reasons why flight schools might not want to work with Sport Pilots. It’s an extra risk,” he said. “I expected this to a certain extent because [the schools] don’t know much about the new regulations or the Sport certificate. A lack of knowledge often conjures up fear of the unknown.” This MOSAIC headwind has also been noted by aviation organizations like AOPA, EAA, NAFI and others hopeful that MOSAIC would grow the ranks of non-commercial aviators. “We’ve seen it before…with the introduction of the idea of ‘Sport Pilot,’ with Class 3 medicals, etc.,” adds Sarah Staudt, Program Development Manager for the National Association of Flight Instructors (NAFI). “’We don’t like it’ is a natural human reaction to change.” 

Mosaic Recap

Unless you’re new to aviation, you probably know a little something of MOSAIC. In short, the new rules reduce the complexity and expense of bringing aircraft to market through a simpler certification process. More relevant to this article, MOSAIC also updated and expanded the capabilities of Light-Sport Aircraft (LSA) and Sport Pilot privileges. The FAA now allows Sport pilots, using a driver’s license in lieu of a medical, to fly almost any single engine aircraft as long its ‘clean’ stall speed is 59 KCAS or less. New planes can qualify as light sport aircraft as long as their stall speeds don’t exceed 61 KCAS in landing configuration. With additional training and endorsements, Sport pilots can also now fly at night and use aircraft with retractable landing gear and constant-speed propellers with additional training and endorsements. 

MOSAIC was years in the making, with its proponents successfully arguing that it would make new LSAs safer, improve overall safety, reduce cost and time barriers toward becoming a pilot and offer additional conveniences that might encourage more people to fly. Trading the previous LSA maximum takeoff weight (MTOW) limit of 1320 pounds with the stall speed limits would allow Sport pilots to fly larger, more crash resistant aircraft better able to handle less than perfect flying conditions. Additionally, the rules would let the LSAs of the future, sometimes called MOSAIC LSAs (MLSAs), to more easily carry additional safety equipment without the substantial payload limitations they placed on today’s LSAs.

Data Collection

In preparation for this article, Kitplanes communicated with pilots and prospective pilots from all over the country. We asked them about how their local flight schools were responding to MOSAIC. Responses came in from Massachusetts, Texas, New Hampshire, West Virginia, North Carolina, Georgia, Virginia and Washington, among other states. Contacting flight schools directly for information was more challenging. There are more than 1000 schools in the United States, according to IBISWorld, an industry market research company. (That number includes both Part 61 and Part 141 schools. The former primarily cater to recreational flyers, while the later primarily concentrate on commercial pilot training. Kitplanes only spoke with Part 61 schools for this article given that Part 141 schools rarely, if ever, deal with Sport pilots.) We would have had to contact almost 300 schools to make statistically significant claims about their implementation of MOSAIC. Therefore, we cannot report numbers here with any degree of certainty, specifically the proportion of schools who are and aren’t willing to rent to or train Sport pilots. But, after communicating with a number of FBOs and aviators coast to coast there’s amble evidence of worry, confusion and even outright hostility about MOSAIC’s Sport regulation changes. The collected information suggests, however, that a majority of the flight schools in the U.S. want little to do with Sport Pilots, at least for now.  

Objections & Rebuttles

Safety was the biggest concern of all of the schools we contacted that are holding off on MOSAIC’s changes. Some based their decision to not participate upon a belief that Sport Pilots are more likely to have accidents than Private Pilots. Sport Aviation still has a questionable reputation in some corners of aviation despite the FAA’s basing MOSAIC upon Sport pilots having a good safety record. “I want to help aviation grow, but I want to make sure to do it in a way that’s safe,” said Beth Bendel, owner of Monadnock Aviation in Keene, NH. “My present comfort level with the amount of training a Sport pilot receives, combined often with their lack of time in the cockpit, makes it hard for me to confidently hand them the keys to a Warrior or Skyhawk…even with a checkout flight.” Rudy Davila, Director of Operations for Flying Tigers based in Houston, TX, added that safety concerns also mean legal concerns. “More standards are better,” he said, “…and we’re not going to increase our liability just because of MOSAIC.” A number of schools are reportedly still in the process of investigating both safety and liability aspects of the new rules before establishing specific policies. 

Money is also a factor here. A number of Sport pilots and potential students said their area’s schools would not rent to them or do any Sport training in GA aircraft because of insurance costs. A few schools were reportedly happy to train Sport pilots in legacy GA aircraft, but were still not willing to rent to them for insurance reasons. It’s a little soon to know how the entire insurance market will respond to allowing those without a medical to rent and fly a plane that absolutely required one before. Some believe it could be a major issue. Additionally, some schools said they were uncertain whether training or renting to Sport pilots was economically viable. Sport Pilots are less likely to spend as much money with a school because of the reduced time involved in their earning a certificate. One school said Sport Pilot candidates also seem to be even less likely to complete their certificates than Private Pilot students.  

Ignorance of MOSAIC regulations, and of the Sport certificate in general, were also factors. “I really need to learn more about all of this,” said Bendel. “I may change my mind in 6 months after I learn more and see what’s happening nationwide. But for now we’re not renting to Sport pilots.” Meredith Holladay, a CFI and owner of Holladay Aviation in Jacksonville, FL, contends that some regulatory issues need to be ironed out before she’s okay with MOSAIC. “The FAA has left a lot of gaping holes in regard to Sport Pilot endorsements for CFIs,” she said. “The regulations are unclear and I need this endorsement thing settled before I’ll train and rent to Sport Pilots.”

If a school is already fully booked with Private Pilot students it’s understandable why Sport training doesn’t make sense for them. No one contacted suggested that schools should be happy to lose money, much less be forced to work with Sport Pilots. The counter argument here is that flight schools are ignoring a chance to make money, especially since they no longer need a Special Light Sport Aircraft (SLSA) for Sport training. “I believe a couple years down the road that those who don’t train Sport Pilots are going to lose clientele,” states Murray Huling, Vice President of Government and Regulatory Affairs for AOPA. “They also shouldn’t forget that the Sport license can be stepping stone to a higher certificate,” he adds. Stoney Jarvis, the Flight School Manager for Aero Elite in Winchester, VA adds there are two viable markets schools can immediately take advantage of with the regulation changes. “MOSAIC will not only allow older pilots who’ve let their medical lapse to fly again, it will also help a number of young adults to become pilots. A lot of the younger people I talk to who are interested in aviation have used ADHD drugs or depression medications in the past,” he explains. “It’s a lot easier for them to go the Sport Pilot route than worry about an FAA issuance.”  

Insurance costs shouldn’t be of much concern to flight schools, according to those we spoke with in the insurance industry. None of the flight schools contacted going forward with MOSAIC mentioned insurance issues at all. Jarvis said his schools have been working with Sport Pilots for several years, typically training five Sport Pilots each year and now putting them into their legacy aircraft, and that their insurance rates have not gone up. Other schools report the same. Of course, insurance coverage and rates can vary significantly, and some schools could see additional expenses. Multiple requests for comment on this from the Aviation Insurance Agency, an industry association, were unsuccessful. Lance VanWormer, an insurance advisor at CS&A Insurance, did explain that insurers are far more concerned about airplanes than pilot certificates at flight schools when setting rates. “Insurers take into account that schools train and rent to students, and their rates can be as much as three times higher than a single pilot seeking insurance because of that. “But,” he said, “the fee is generally set more on the cost of the aircraft used for training than who’s flying it.” 

Some MOSAIC proponents believe schools are using claims of insurance costs to justify a rejection of Sport aviation in its entirety. “A lot of pilots, CFIs and flight schools have been brainwashed into thinking that Sport Pilots aren’t ‘real’ pilots,” according to Hamilton. “This is so well ingrained that they don’t want to even think about Sport training at all.” The logic here is flawed argues NAFI’s Staudt, and shouldn’t be part of an argument about safety. “These schools would think very little about transitioning a Private Pilot to a high-performance aircraft when they’d only flown a J3 Cub. The difference there is far more significant than a Sport Pilot jumping from an LSA to a 172,” she believes. “It’s really just a matter of transition training regardless of the certificate. You should see some Private Pilots flying LSAs for the first time! Access the pilot’s skills, go at an appropriate pace and move on from there.” Jarvis contends that Sport Pilots may be better able to transition from LSAs to a Cesana or Piper than most people think. “With LSAs typically being so light they can sometimes be challenging to land,” he explains. “We’ve found that Sport Pilots are relatively easy to transition to heavier planes.”   

Logic does dictate there are some legitimate safety issues. Sport Pilot training, and the subsequent DPE check ride before a license is issued, is identical to that of a Private Pilots with the exception of IFR and night flying. “It’s valid for a school not to rent an IFR capable plane to a Sport Pilot who wants to go on a multi-day cross country given their lack of this type of training,” contends Holladay. “But to suggest that Sport Pilots can’t be as good as Private Pilots [with equivalent hours in most VFR situations] is ridiculous.”

The Future Of Sport Aviation Under Mosaic

There isn’t sufficient information available at this time to determine the extent of this dilemma and how it might be resolved if necessary. An examination of the issue would certainly be expensive and time consuming, and there’s a question of who might do the research at this time. The FAA emailed a response to a request for comment saying that it is “engaging closely with the aviation community to ensure a smooth transition under the new provisions.” The statement did not provide any details of the extent of the FAA’s engagement. It did say, however, “that while we do not regulate flight-school rental policies, we encourage schools to embrace the opportunities MOSAIC presents for expanding access and participation in aviation.”  

NAFI’s Stoudt believes “it’s just a matter of time for people to adjust.” She says her organization is already working toward helping instructors adapt to MOSAIC. The economy will certainly be a significant determinate too. If schools end up struggling to find students, something entirely possible given recent economic trends, then they may well be more amiable to working with Sport Pilots. “Part of the impetus behind MOSAIC was to create more opportunities for flight training,” according to Experimental Aviation Association (EAA) spokesman Dick Knapinski. “Decades of 70-80 percent washout rates for private pilot flight training means thinking the same way is not going to bring a different result.” As for Sport Pilot accident rates, if they increase under MOSAIC, then insurance may be a major factor. Finally, there’s still the ongoing problem with the number of Designated Pilot Examiners (DPE) for Sport Pilots. There aren’t anywhere near enough of them, according to CFIs who work with Sport Pilots. Getting a Sport checkride is difficult in most parts of the country. Producing more aviators without increasing the number of DPEs isn’t going to help the situation one bit.