NPRM Archives - FLYING Magazine https://cms.flyingmag.com/tag/nprm/ The world's most widely read aviation magazine Fri, 15 Mar 2024 12:49:30 +0000 en-US hourly 1 https://wordpress.org/?v=6.4.4 Pilots Have Questions When It Comes to MOSAIC https://www.flyingmag.com/pilots-have-questions-when-it-comes-to-mosaic/ Fri, 15 Mar 2024 12:49:15 +0000 https://www.flyingmag.com/?p=198059 Here’s an overview of the proposed MOSAIC regulations and some opinions provided during the comment period.

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MOSAIC (Modernization of Special Airworthiness Certification) is a regulation that affects all aircraft with special airworthiness certificates. Aircraft built by Cessna, Piper, Cirrus, Diamond, and others instead have standard certificates, and their new models remain untouched by this proposed regulation.

In contrast, all light sport aircraft (LSA), experimental amateur-built airplanes, and warbirds are issued special certificates. In my view, the rule can be divided into two main parts: airplane descriptions and capabilities, and pilot certificates, technician privileges, and operating limitations. In short, airplanes or people.

For airplanes, the NPRM (Notice of Proposed Rulemaking) felt like Christmas in July, granting many capabilities industry and pilot member organizations had sought over some years of negotiation. The people part describes who gets to fly and maintain these MOSAIC LSAs and under what rules. This latter section inspired greater concern.

Airplanes: What We Gained

Here’s the list of what FAA offered and how each changed:

Gross weight: LSAs have been limited to 1,320 pounds (land) or 1,430 pounds (water). Under MOSAIC, the weight limit is removed and clean stall constrains size so the aircraft remains what FAA sought: those “easy to fly, operate, and maintain.” It is expected that weight can rise to 3,000 pounds depending on the design.

Stall speed: Presently, LSAs cannot stall faster than 45 knots. This will be raised 20 percent to 54 knots, but this is clean stall, the purpose of which is to limit aircraft size and difficulty. It has no relation to landing speed or slow-flight qualities. This more than doubled the potential size, hence a new term, “MOSAIC LSA.”

Four seats: LSAs are presently limited by definition to two seats. This rises to four in a MOSAIC LSA, but if operated by someone using sport pilot certificate privileges, then only one passenger can be carried. A private certificate with medical may fill all four seats, assuming weight and balance allows.

Retractable gear: Light sport aircraft have been fixed gear only, except for amphibious models. Now any MOSAIC LSA can be retractable. Several imported LSAs already offer retractable options in other countries.

Adjustable prop: LSAs were allowed only ground-adjustable props. Now a MOSAIC LSA can have an in-flight adjustable prop. Such equipment on similar aircraft is common in other countries.

250 knot max speed: An LSA was limited by definition to 120 knots at full power. Now the speed limit matches all other aircraft below 10,000 feet: 250 knots. No one expected such a large expansion, but now retractable and adjustable props make more sense.

Rotary expansion: After 20 years of waiting, fully built gyroplanes will be allowed. That followed years of advocacy effort, but when the opposition finally yielded, the FAA also granted helicopters.

Electric or hybrid: Because the FAA did not want turbine LSAs in 2004, it specified reciprocating engines, unintentionally knocking out electric motors that few were considering at the time. In fixing the definition to allow electric, the agency will also permit hybrids. Examples are already flying in Europe.

Turbine: Perhaps turbine engines were harder to operate 20 years ago when LSA were defined, but today they are seen as simpler, and the FAA will allow them. Turbine-powered MOSAIC LSA candidates are already flying in Europe.

Multiple engines/motors: The LSA has been limited to a single engine by definition. That constraint is removed, although no language was given to address how the pilot qualifies.

Aerial work: The Light Aircraft Manufacturers Association (LAMA) lobbied for MOSAIC LSAs to be permitted to do forms of aerial work, although not passenger or cargo hauling. The FAA has granted this opportunity to the manufacturers, which can specify what operations they will permit. A commercial pilot certificate will be required.

One downside to all these goodies? Each will increase the price. The good news? Present-day LSAs offer lower prices and have proven enjoyable and dependable. Many LSAs are fine as they are and have no need to change.

A lot of LSA producers already meet higher weights in other countries where permitted. They are merely reduced on paper to meet U.S. standards. It should be straightforward for them to redeclare meeting all MOSAIC-level ASTM standards to qualify for higher weights.

The only question is how far backward compatible they can go for aircraft in the field over which they have had no control for some time. It’s an industry question to resolve, and it will swiftly be handled to aid sales.

A pair of AirCams fly in formation. [Courtesy: Lockwood Aviation]

People and Areas of Concern

Medicals: Lots of questions surround one of the principal benefits of LSA operation: the lack of requirement for an aviation medical if operating as a sport pilot. More specifically, pilots want to fly larger aircraft using these privileges, meaning no medical certificate, or BasicMed, instead using the driver’s license as evidence of their medical fitness.

To keep within their budget, many pilots wish to buy (or keep flying) legacy GA aircraft such as the Cessna 150, 172, 177, and some 182s, plus certain Pipers, Diamonds, Champions, or other brands. Many of the latter aircraft are too heavy to allow such privilege today. MOSAIC appears to change that, but without presenting compelling evidence that possession of a medical assures a flight proceeds safely, the FAA nonetheless clings to this premise. Many assert the occurrence of medical problems sufficient to upset a flight or cause an accident are incredibly small in number.

Stall speed: Most NPRM readers agree that it was a worthy solution to use 54 knots clean stall as a means to limit the size of the airplane and to keep it within the FAA’s mantra of LSAs being “easy to fly, operate, and maintain.”

However, many respondents note that adding just a couple knots to that limit will allow several more airplanes that some wish to buy and fly under MOSAIC rules. Note that the 54-knot reference is not related to landing speeds or slow flight, where lift-enhancing devices like flaps would normally be used.

Some pilots asked if adding vortex generators could reduce stall speed enough to qualify. The problem lies in proving a slower stall speed was achieved. Stall (VS1) printed in the POH will be the standard about compliance.

Several pilots have complained about use of calibrated versus indicated airspeed for the stall limit, but this is another matter that might be clarified after the comment period.

Endorsements: One of the significant lessons learned in 20 years of pilots operating LSAs is the so-called magic of endorsements. Instead of asking pilots to receive training, take a knowledge test and possibly an oral exam, followed by a practical flight test, they can just go get trained for added skills from an instructor who then endorses their logbook accordingly, and they’re good to go. This puts a significant burden on flight instructors to do their jobs well, but that’s already the situation.

The NPRM already refers to the use of endorsements for retractable gear training or adjustable prop training, and many believe that expanding endorsements to all privileges described in the MOSAIC proposal has merit.

Noise: For the first time, the NPRM introduced noise requirements that encompass several pages. Coincidentally, the LSA sector is already one of the quietest in the airborne fleet.

This is partly because of European noise regulations that have been in place for a long time, motivating quieter engine and exhaust system development. However, LSAs are also quieter because the powerplants are modern, thanks to the faster approval process implied by industry consensus standards.

The industry was not pleased about the noise proposal, as these requirements add burden without identifiable benefit. Nonetheless, the situation might be handled through the ASTM process more quickly and still satisfy political demands.

Night: MOSAIC’s language invigorated many readers when the NPRM expressed support for a sport pilot to fly at night—with proper training and a logbook endorsement. Then the proposal refers to other FAA regulations that require BasicMed or a medical. If you must have a medical, you are not exercising the central privilege of a sport pilot. Why suggest that a sport pilot can do things that are blocked by other regulations? This conflict should be resolved.

This is one of several aspects of the NPRM that many describe as “inconsistencies,” where one part of MOSAIC appears to restrict another part, often for unclear reasons. Such observations lead many to declare the NPRM looks “rushed to market.” Hopefully, most problems can be addressed in the post-comment period.

When surveyed about why night privileges are valued, most pilots wanted to be able to complete a cross-country flight with a landing after dark.

IFR/IMC: Contrary to what many think, the FAA has never prohibited LSAs from IFR/IMC operation. It is the lack of an ASTM standard to which manufacturers can declare compliance that prevents such sales. (Some special LSA owners elect a change to experimental LSA status and can then file IFR, assuming they have a rating, are current, and the airplane is properly equipped.)

However, as with night operations, many LSA owners report higher-level pilot certificates often including instrument ratings, and they would like to be able to use their LSAs to get through a thin cloud layer.

Maintenance and TBOs: The maintenance community has found several objections within the NPRM. It appears that changes could cause a loss of privilege for LSA owners who have taken training to perform basic maintenance on their own LSAs.

In addition to altering the privileges of light sport repairman mechanic (LSRM) certificate holders, MOSAIC adds capabilities such as electric propulsion, hybrid, turbine, and powered-lift devices, which leaves the mechanic-training industry guessing where to start. Some organizations wonder if it’s worth the investment to create appropriate courses with uncertain privilege at the end.

Indeed, eight training organizations suggested they would petition for an extension to the comment period. It was successful, so the extension will delay the expected arrival of the finished MOSAIC regulation. Absent any extension, the FAA has repeatedly said 16 months were needed, equating to the end of 2024 or early 2025.

One group creatively suggested using add-on training modules to solve the problem in much the same way that endorsements can be used to solve pilot training enhancements.

Lack of sector expertise: The FAA knows a great deal about conventional, three-axis airplanes but far less about so-called “alternative LSAs.” For machines that use different control systems or operate substantially differently than airplanes—weight shift and powered parachutes come to mind—some industry experts believe a better system is to authorize an industry organization to manage these sectors. This has been common throughout Europe for many years and could work well in the U.S.

In a document of its size, some errors will arise and some clarifications will be needed. It is only a proposal after all. Pilots can comment on certain aspects but will have little idea how the FAA can or will solve various points, even if they offer solutions.

This frustrates some readers and can cause uncertainty about a pending or planned airplane purchase. In turn, purchase-decision delays frustrate airplane manufacturers. That’s the precarious terrain surrounding new regulations. Such comments on regulation are part of the American way, where the citizens can be part of the process. Here’s your chance to speak and be heard.

[Courtesy: Flight of Flight Design]

This column first appeared in the November 2023/Issue 943 of FLYING’s print edition.

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FAA Extends MOSAIC Comment Period https://www.flyingmag.com/faa-extends-mosaic-comment-period/ Wed, 04 Oct 2023 23:13:02 +0000 https://www.flyingmag.com/?p=183624 The FAA has extended the comment period for its MOSAIC proposal by 90 days, allowing stakeholders and the public more time to provide feedback on changes to light sport aircraft regulations. The proposal aims to enhance safety, performance, and privileges while addressing industry concerns about continued operational safety, modernization limitations, personnel implications, and repetitive rulemaking.

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The FAA has announced a 90-day extension for the comment period on its Notice of Proposed Rulemaking (NPRM) titled Modernization of Special Airworthiness Certification (MOSAIC), according to an Aircraft Electronics Association (AEA) press release.

Originally published on July 24, MOSAIC aims to revise regulations governing the manufacture, certification, operation, maintenance, and alteration of light sport aircraft (LSA). 

The proposal’s primary goal is to enhance safety, performance, and privileges under sport pilot and LSA rules, with a focus on suitability for flight training, limited aerial work, and personal travel.

The NPRM, as published in the Federal Register on July 24 (88 FR 47650), originally had a comment period set to conclude on October 23. With the extension, interested parties now have until January 22 to provide feedback on the proposed changes.

This move comes in response to a formal request from several aviation organizations, including the AEA, Aeronautical Repair Station Association, Aviation Suppliers Association, Aviation Technician Education Council, Helicopter Association International, International Air Response Inc., Modification and Replacement Parts Association, and the National Air Transportation Association. These organizations jointly submitted the request on August 29, expressing the need for additional time to thoroughly review and assess the extensive amendments proposed by MOSAIC.

While much of the public’s attention has been drawn to the potential expansion of sport pilot privileges and the increased weight and performance allowances for LSA, organizations like AEA are concentrating on four key areas that may affect its member companies and employees. These are continued operational safety, limitations on modernization and upgrades, personnel, and repetitive rulemaking.

The FAA’s decision allows the public and relevant organizations to more thoroughly identify inconsistencies, duplications, or unintended consequences that may arise from the proposed changes. 

This extension also underscores the importance of engaging industry stakeholders and the public in shaping the future of LSA regulations. This opportunity to provide valuable insights and feedback on the MOSAIC proposal ultimately contributes to the ongoing process.

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MOSAIC Questions Linger in Light Sport Aircraft Community https://www.flyingmag.com/mosaic-questions-linger-in-light-sport-aircraft-community/ Wed, 27 Sep 2023 17:37:45 +0000 https://www.flyingmag.com/?p=181266 Many pilots have questions about the Modernization of Special Airworthiness Certification proposed rulemaking underway at the FAA. Here are some answers.

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Editor’s note: This article first appeared on Plane & Pilot.

I don’t know about you, but I can guess that Modernization of Special Airworthiness Certification (MOSAIC) fatigue is setting into a lot of quarters. Some pilots have done an extraordinary job of digging into the FAA’s 318-page Notice of Proposed Rulemaking (NPRM) document to distill essential parts that need to be addressed. Many pilots get exhausted just looking at the NPRM.

Me too.

MOSAIC has given us an inside look at how the FAA works. Many improvements resulted when the industry worked in harmony with government officials. Nonetheless, careful study found areas of concern in the NPRM. Recent articles in other publications hit essentially the same points as I did in my talk. Those points were partly my thinking, but I also relied on other experts to whom I had posed a variety of questions.

[Credit: Dan Johnson]

Still, some of the best commentary has come from non-experts—regular pilots who were concerned about a certain part of the NPRM and explored it thoroughly. With this in mind, I was keen to hear from my audiences at the Midwest LSA Expo 2023.

What follows represents my distillation of a number of questions that were asked in lengthy Q&A sessions following the two presentations. Several conversations developed between people in the audience, and therefore asking you to listen to all of that would not be engaging. I attempted to faithfully reproduce those questions and comments, and my responses, below.

Aircraft Descriptions

If my LSA has been restricted to 1,320 pounds to meet current regulation, will a pathway exist to use a higher weight if the aircraft has been appropriately tested?

The answer depends. If your aircraft is Experimental Amateur Built, you are the manufacturer and can change what you want. So if you want to fly on drivers license medical at a higher weight — so long as you clean stall at 54 knots or less — you can do so. On a Special LSA, the manufacturer will have to redeclare that they meet all applicable ASTM standards at the higher weight and could then start supplying aircraft with higher gross weights. However, that does not mean they will go backwards compatible and make all earlier aircraft so capable. A manufacturer would have no idea how the aircraft had been maintained or operated and they may not want to take on the added risk.

I asked several experts to help me as I studied MOSAIC. One was LAMA Board Member, Phil Solomon from whose info I made this slide. [Credit: Dan Johnson]

Some producers may not make aircraft specific to the U.S. market…

I agree, but many CAAs, especially in smaller countries, mirror FAA regulations closely. Since the U.S. aviation market remains the largest in the world, many producers cannot ignore American rules.

Will the FAA allow a sport pilot, perhaps by endorsement, to carry more than one passenger?

This represents a good place to urge your comment. If you believe a sport pilot, with added training and an endorsement, should be allowed to fly on a drivers license, say so.

What weight limit is applied to MOSAIC LSA?

No weight limit is specified. Instead, aircraft size is well governed by specifying clean stall at 54 knots. That is VS1 not VS0, clean—not flaps out. The purpose is to limit aircraft size and does not relate to slow flight or landing speeds.

Why the 54 knot clean stall? Why not with flaps?

Understand that the FAA’s point about a 54-knot clean stall is to provide a means of limiting the aircraft size. It works well for that, but this can also be easily defended by the pilot (show the FAA the POH) and verified by the FAA (by examining the POH). It’s a simple solution.

I fly a Beech Sundowner, a [Cessna] 172-like aircraft. The POH states a 62-knot clean stall. If I add vortex generators to it and lower the stall speed to 54 knots, will it qualify even though the POH will still say 62?

Since Sundowner is a Part 23 certified aircraft, it would require an STC to add anything to the airframe. At that time, a modification could be added to the POH but FAA officials in various places will not initially know how to handle this. The problem is, how do you know it stalls at 54 or less, and how do you defend it? The cost to demonstrate convincing evidence that stall is now lower than the POH states may be excessive.

You referred in one slide to “high performance.” That term and “complex” are already defined in Part 61. If it has an adjustable prop, a 200 horsepower engine, and flaps, it is “high performance.” If it is retractable, it is “complex”, although it may not also be “high performance” (ex: a C-172 RG is complex but not high performance).

The FAA perceived a gap between LSA and Part 23 certified aircraft; they evidently see pilot certification similarly in discussing endorsements. While MOSAIC LSA gain many capabilities, sport pilots remain bound by other rules. It was not clarified how a sport pilot qualifies for “high performance” operations. We hope endorsements will suffice; they’ve worked well for 19 years of SP/LSA.

Will aircraft from other countries that have met other certification systems be accepted under MOSAIC?

The commenter refers to a government arrangement called “reciprocity” where one country accepts the methods of other countries. It comes as part of the Bilateral Safety Agreement. While the FAA will accept such approvals, they are still likely to assure an aircraft still meets every line item in ASTM standards for MOSAIC LSA.

Sport Pilot Privileges

If I already have retractable experience or night experience, can I use that as a sport pilot under MOSAIC?

You will have to get an endorsement, it appears, but any instructor who sees a lot of related recent experience in a logbook and flies with you for verification may be willing to endorse your logbook accordingly in short order. If you are not current with those skills, that person may recommend added training.

Is the reason for the medical requirement to fly at night related to color blindness?

The FAA did bring that up at EAA AirVenture 2023, saying that when the states give you a drivers license, they don’t adequately test for this. Personally, I find the argument weak to require pilots to pursue a medical over the relatively remote possibility that they might one day need a light signal from the control tower.

Couldn’t I just go to a doctor and only have my vision checked for color blindness?

That would make a worthy comment and would appear to address the FAA’s stated concern.

Will the opportunity to fly IFR be available to sport pilots without a medical?

Given the FAA’s attachment to medicals, that seems unlikely. However, the same response about the weak relationship between medical possession and aviation safety remains.

The FAA continues to hold tight to its belief that possession of a medical makes flying safer, despite little evidence to support that assertion. Using a drivers license in lieu of an aviation medical for sport pilots has proven very workable. [Credit: Dan Johnson]

As pilots age, insurance companies want more frequent medical visits (even if the FAA may not). Will the insurance companies accept drivers license medical on MOSAIC LSA?

That’s a worthy question but not one about MOSAIC. Insurance companies are private and can require any evidence of medical fitness their contracts specify. They have accepted LSA use on drivers license medical and as I keep saying, no one has presented compelling evidence that possession of an aviation medical assures the flight is safer. What insurance companies do in the future is more a matter of the reinsurance market than an FAA regulation. At present, any pilot over 75  will find challenges getting insurance, regardless of that person’s health.

Have any parts of sport pilot flight instructor been changed?

That is not an area on which I am as well informed but, yes, I saw several references to SPIs. I urge you to use the USUA/LAMA study guide and use its search capability to look up that part more fully yourself. Then, please comment

These are among the topics on which I will personally be commenting. I remain unsure if exceeding 54 knots is necessary. [Credit: Dan Johnson]

Are you still saying that, assuming no change in the 90-day comment window, this will not go live until the end of 2024 or early 2025?

Yes, although an extension may be granted to a group of maintenance companies in which case the rule will be pushed back at least an additional 90 days.

If multi-engine is being allowed, how do you qualify for that?

This is another of those clues that this NPRM seems a bit rushed to market. FAA Aircraft Certification will permit multiple engines/motors, but the Flight Standards Group did not address pilot qualifications. A conventionally-acquired multi-engine rating is far less applicable today because designs include multiple electric motors, advanced computer controls, and many other technical capabilities the FAA never confronted.

What do you mean by “equal work” for powered parachutes or weight shift?

This refers to NPRM language that effectively discriminates against those aircraft types. A pilot cannot take advantage of the opportunity to use LSA for aerial work because a commercial pilot certificate is required and none is available for those aircraft types. They should have equal opportunity to perform aerial work; they may be perfectly suited to some tasks.

How fixed is the FAA on one passenger only? Could the agency be convinced otherwise?

First, the restriction is on the pilot not the aircraft. A private pilot with a medical could use a four-seat mLSA with four people on board, assuming weight and balance allows. Regarding the FAA’s flexibility on this, given its tight cling to medicals even though the evidence for them is weak, I suspect convincing the agency to let sport pilots fly three passengers is a long shot, but you can certainly comment if you have reasons to believe this is wrong.

What was the YouTube address for the MOSAIC Masterclass videos?

A series of videos may be found here.

Maintenance

Could you take two seats out of a six-seat legacy GA airplane, so it only has four, assuming it has a clean stall of 54 knots or less?

This is a “What if”-type question that can go on too long, but essentially if the aircraft has four seats and a clean stall of 54 knots, it can qualify to be flown by a pilot using sport pilot privileges, although only with two persons on board. In order to modify a Part 23-certified aircraft, however, you’d have to get a STC and your local FSDO or MIDO will not be up to speed on MOSAIC initially, so they may not understand the request.

Can a second owner of a LSA take a course to do maintenance on that aircraft?

This can happen today but some questions have been raised under MOSAIC. Rainbow Aviation expressed reason for concern on this. It is more expert on maintenance and I deferred to the company’s knowledge

Rainbow Aviation Services is a premiere provider of mechanic training and found several problems with MOSAIC. [Credit: Dan Johnson]

It appears it will be more restrictive, will take more effort to get LSRM credentials. Any such action will reduce mechanics, already in short supply. Existing A&Ps don’t have enough experience or training on Rotax or Jabiru.

You appear to understand correctly. This is an area where I defer to those with greater knowledge so I have been recommending the Rainbow Aviation YouTube channel as it has been outspoken on this.

Are We About Done with MOSAIC?

Yes! Of course, I will continue to report on MOSAIC developments and news but now it is time for me to formulate my own comments to the FAA. I hope you found all the MOSAIC information useful. I hope you will comment.

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A MOSAIC Study Guide https://www.flyingmag.com/a-mosaic-study-guide/ Fri, 18 Aug 2023 18:05:51 +0000 https://www.flyingmag.com/?p=177835 Here is a step-by-step approach to quickly understanding the FAA's Modernization of Special Airworthiness Certification regulation rulemaking.

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Editor’s Note: This story originally appeared on ByDanJohnson.com.

FAA proposed regulation has powerfully captured the attention of many pilots. Pilots have tons of questions. We have some answers. Everyone has a lot to read.

Overall, FAA’s Modernization of Special Airworthiness Certification (MOSAIC) regulation proposal has been warmly received as it opens the door to more capable aircraft that a sport pilot can fly. That’s good, but the document has problems, too. Following are four examples.

MOSAIC’s language invigorated many readers when the Notice of Proposed Rule Making (NPRM) expressed support for a sport pilot certificate holder to fly at night, with proper training and a logbook endorsement. Yet the proposal refers to other FAA regulations requiring BasicMed or an AvMed. If you must have a medical, you are not exercising the central privilege of a sport pilot certificate. Why suggest that a sport pilot can do things that are blocked by other regulations? This conflict should be resolved.

Another opportunity gap involves aerial work. We’re pleased the Light Aircraft Manufacturers Association (LAMA’s) request was included, but it requires a commercial certificate to fly for compensation, and this requirement eliminates powered parachutes and weight shift trikes, for which no commercial certificate is available. This is discriminatory and should be fixed.

Maintenance experts have lots of questions; see the video at bottom.

ASTM standards writers raised questions about the value of noise regulations included for no present gain, “requiring solutions before the problem exists.” This appears to have political motivations.

You may find other aspects of MOSAIC that urge you to comment. If so, you may find the following helpful.

MOSAIC Study Guide

I can’t imagine anyone genuinely enjoys reading MOSAIC. The NPRM encompasses many pages in dense language; it’s tedious to review.

It just got a lot easier, thanks to Roy Beisswenger. [Beisswenger is founder and proprietor of Easy Flight]

Beginning in 2014—well before MOSAIC existed—Beisswenger and I spent years advocating on behalf of the LSA industry and the pilots that fly those light aircraft to the FAA. Beisswenger was the lead author on several white papers LAMA submitted to support each of its requests. They went over so well with the FAA that they are mentioned in the footnotes.

Bookmarks help you jump around the lengthy document. This view is from an Apple iPad using Adobe Acrobat Reader (free download). [Courtesy: Dan Johnson]

As you will see in the attached PDF study guide, Beisswenger has done a monster amount of work in reformatting the documents so that you can walk through it and find what you want much easier.

Bookmark icons may differ by platform and software but make navigating the document easier. Here are the sections Beisswenger isolated so you can focus on areas of interest. Triangles appear when more information is available. [Courtesy: Dan Johnson]

Beisswenger also addressed specific comments I had, whereupon reading one section, the FAA refers to another, and then to another. Before long, you forget where you started and struggle to retrace your steps. You also need internet access to study the FARs published outside the NPRM. The continuous back-and-forth makes studying the document slow, yet the clock is ticking on public comments. At this writing we have just over 60 days left.

Reviewing the NPRM is far easier with this PDF study guide because of the bookmarks, links, and backlinks, plus already-highlighted text which shows what current FARs could be changed plus some lightly-colored text that illustrates where the FAA will insert new language.

MOSAIC will still take a significant effort to review carefully, but Beisswenger made the task much easier and faster.

The Magic of Bookmarks

If you open the study guide with Adobe Acrobat on almost any device or computer—or if you use Preview on Apple laptops/desktops—you will gain access to the bookmarks (look for a small icon in the upper right of a tablet or a smart phone; in Preview, show the Table of Contents. On both, use the triangles to drop down further and further). Bookmarks are your navigation friend, helping you jump to places of interest or study.

To find more about night flying by Sport Pilots, you can click or tap the triangle on this FAR (Part 61). [Courtesy: Dan Johnson]

Beisswenger even embedded back buttons on some pages when reviewing the FARs. This helps readers not get lost in their investigations.

Within the FARs menu, you may have to scroll down for more topics. This example is for night operations. [Courtesy: Dan Johnson]

Of course, within Acrobat (or Preview), you can search for specific text.

I observe for you that such ease of review was not possible when the SP/LSA regulation was released in 2004 (three years before the iPhone was introduced).

Links within the Study Guide let you look up the many FAR references made in the NPRM. No Internet is needed for this link. The magenta-colored text shows where the FAA will insert new text. [Courtesy: Dan Johnson]

When reviewing MOSAIC I recommend you follow aspects of particular interest to you rather than try to absorb the whole thing.

However deep you go, Beisswenger made it much easier. 

To help you not get lost in the FARs, Beisswenger embedded “Back” buttons in strategic locations (circle). Yellow-highlighted text denotes current-day FARs that would be changed by MOSAIC. [Courtesy: Dan Johnson]

When you are ready to comment to FAA, use this link. We’ll have more advice on commenting as soon as possible but here’s some basic tips:

  • Keep your remarks to a purpose; ask for something.
  • Make specific requests.
  • Reference language when changes are needed.
  • Be constructive; no ranting.
  • Be original; use your own words.

To see MOSAIC comments already made, use this link.

More About MOSAIC

John Zimmerman, president of Sporty’s, thought our conversation in this edition of the “Pilot’s Discretion” podcast conveyed a lot of good information (audio—42 minutes). John was an excellent interviewer.

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GA Industry Celebrates FAA’s Proposed MOSAIC Rule https://www.flyingmag.com/ga-industry-celebrates-faas-proposed-mosaic-rule/ Mon, 24 Jul 2023 19:44:09 +0000 https://www.flyingmag.com/?p=176480 Under the agency’s new proposed guidelines officially published Monday, most of the current regulatory limitations on light sport aircraft would be removed.

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The general aviation industry is buzzing with excitement over the FAA’s recently unveiled rulemaking proposal for light sport aircraft.

The long-awaited Notice of Proposed Rulemaking (NPRM) for the Modernization of Special Airworthiness Certificates (MOSAIC), published Monday, boasts the potential to revolutionize the LSA market, bringing about a significant increase in their usefulness and creating new opportunities for sport pilots.

Under the FAA’s new guidelines, most of the current regulatory limitations on light sport aircraft would be removed, including the weight limit. As it stands, light sport is considered any aircraft under 1,320 pounds. The agency’s proposal would define fixed-wing aircraft as having a clean stall speed of 54 knots, a maximum flight level speed of 250 knots, and a maximum of four seats—all of which represent increases over the current regulations. As with present restrictions, a pilot exercising sport privileges may only take one passenger along.

The Experimental Aviation Association (EAA), with members who make up GA’s most passionate light sport pilots, has largely led the way when it comes to the MOSAIC initiative. 

“MOSAIC had its genesis with a conversation between EAA and FAA officials nearly a decade ago, as we focused on safely creating more aviation opportunities for those who wanted to participate,” said Jack Pelton, EAA CEO and chairman of the board. “Now that the NPRM has been released, we will study it closely and supply focused comments to ensure that the goals of this EAA-inspired initiative remain in the final language developed by the FAA.”

Other GA groups, including the Aircraft Owners and Pilots Association (AOPA), advocated strongly to broaden the definition of LSA, ease operational restrictions, and permit operations for hire that were previously restricted to certified aircraft.

“Modernizing the light-sport category for the thousands of our members that fly these aircraft is something we’ve been long pushing for, and it just makes sense,” said AOPA president Mark Baker. “We’re pleased to see the FAA take this first step to help modernize the general aviation fleet and provide more options for pilots.”

The rulemaking has also garnered the support of the Society of Aviation and Flight Educators (SAFE). 

“SAFE supports this carefully crafted FAA proposal as a creative method to expand the availability of modern, safe (and increasingly capable) aircraft to a wider audience of pilots,” executive director David St. George told FLYING. “SAFE also respects the FAA’s trust in our professional flight instructors to safely extend these new flight privileges to current and future sport pilots within this new performance-based standard.”

Zenith Aircraft, a leading light-sport manufacturer, applauded the FAA’s proposed changes, calling the NPRM “a promising initiative that could enhance the affordability, the capability, and new design choices of light aircraft for recreational pilots.” 

The company also acknowledged its plans to capitalize on the benefits of the proposed changes by enhancing its aircraft designs and kits for recreational pilots.

“We support all rules that make it easier for our existing customers to continue to enjoy building and flying their airplanes,” said Sebastien Heintz, Zenith’s president. “The MOSAIC NPRM proposes rule changes and new rules that will allow just that, as well as recognizing new technologies, such as electric propulsion. Such new rules may make it feasible to not only continue to invest in airplane kit manufacturing but to pursue new aircraft certification and production in the U.S.”

Textron Aviation-owned Pipistrel and other manufacturers of electric light aircraft have also voiced support for MOSAIC. In a tweet, the company noted, “Pipistrel’s team is excited by @FAANews’ MOSAIC proposal for light sport aircraft. Recommendations in this document will benefit Pipistrel’s aircraft and our customers. A great way to kick off EAA AirVenture!”

The FAA’s comment period for the MOSAIC NPRM will close on October  23.

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Gulfstream Marks First Flight of Its Second G800 Test Aircraft https://www.flyingmag.com/gulfstream-marks-first-flight-of-its-second-g800-test-aircraft/ Mon, 24 Jul 2023 14:21:05 +0000 https://www.flyingmag.com/?p=176438 Gulfstream began flying its second G800 test aircraft as it continues the certification program for the new model.

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Gulfstream Aerospace Corp. announced the first flight of its second Gulfstream G800 flight test aircraft. During the flight, which began at the company’s Savannah, Georgia, headquarters, the airplane flew for 3 hours and 26 minutes and reached a top speed of Mach 0.935 while running on a 30/70 blend of sustainable aviation fuel.

Gulfstream said the flight marked a new phase of testing aimed at certifying the G800 and beginning deliveries to customers.

“Gulfstream’s flight test team continues to make advanced strides forward for our company,” said Mark Burns, president of Gulfstream. “The G800 will bring the industry’s longest range to customers around the world, and we are seeing strong demand for this capability alongside the cabin comfort and quality Gulfstream is known for.”

The evaluation program for the second G800 flight test aircraft focuses on environmental control systems, avionics and flight controls, expanding on the areas covered by the first test aircraft, the company said. 

“Thanks to the design philosophy behind our next-generation fleet, the G800 is also benefiting from the excellent progress we continue to make in the Gulfstream G700 flight test program,” Burns said. “This commonality helps us enhance efficiency and reliability for our customers, who are already seeing firsthand how well these aircraft perform.”

The G800 can fly 8,000 nm at Mach 0.85 and 7,000 nm at Mach 0.90. The company attributed the aircraft’s performance to its high-speed wing and winglet design and new Rolls-Royce Pearl 700 engines. The G800 is designed to seat up to 19 passengers and can be configured with as many as four living areas.

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How to Comment on a Proposed FAA Policy https://www.flyingmag.com/how-to-comment-on-a-proposed-faa-policy/ Fri, 21 Jul 2023 17:22:26 +0000 https://www.flyingmag.com/?p=176311 Following a few guidelines for simple do’s and don’ts can help ensure your comment makes the impact you desire.

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Editor’s Note: This first appeared in Plane & Pilot.

When a federal agency, such as the FAA, seeks public input on a proposed policy, providing a substantive comment is an essential way to voice concerns, offer suggestions, and contribute to the policymaking process. With Modernization of Special Airworthiness Certificates (MOSAIC) on the horizon, you may be looking to add your thoughts to the process but aren’t sure how to create a comment that will have the effect you want.

A well-structured and thoughtful comment can significantly impact an agency’s final decision. In this guide, we will explore the key components of making a substantive comment to the FAA, highlighting examples and offering do’s and don’ts for effective commenting.

Do’s for Making a Substantive Comment

Take Time to Understand the Proposal

Thoroughly read and comprehend the FAA’s proposal to grasp its objectives, implications, and intended outcomes. You can read the MOSAIC proposal and take notes on how it may impact your personal or professional role in aviation. 

Analyze the potential effects on safety, the environment, and industry. You may want to think about composing a comment that addresses a specific impact. Make notes that reflect your observations. Your note may not be your final comment, but you can use it to help construct the one you send to the FAA.

Example of a reflective note: “In the FAA’s proposal for implementing new air traffic control procedures, there is a potential impact on small airports and general aviation pilots, as they might face increased congestion and altered flight paths.”

Provide Specific Evidence and Data

When you’re ready to craft your comment, support it with factual data, research, and evidence to strengthen your argument. If you can, use statistics, studies, and case examples to back up your assertions and bolster your position. 

Example: “I recommend that the FAA review the recent study by XYZ research group, which highlights the safety benefits of the proposed runway extension at ABC airport.”

Offer Constructive Suggestions

If you are opposed to a potential rule or aspect of one, try to present viable alternatives or solutions to address concerns and improve the proposed policy.

Consider the feasibility and practicality of your suggestions.

Example: “Instead of imposing a blanket curfew on all flights, the FAA should consider implementing noise reduction measures for late-night operations at major airports.”

Be Clear and Concise:

Articulate your points in a well-organized and coherent manner. Avoid jargon or technical language that may confuse readers. Keep your comment short so that it can be quickly read and digested.

Example: “I strongly advocate for the FAA to prioritize the implementation of bird strike prevention measures at airports with a history of avian-related incidents.”

Don’ts for Making a Substantive Comment

Avoid Emotional Language

Refrain from using emotional or inflammatory language that may undermine the credibility of your comment. Focus on rational arguments and evidence-based reasoning.

Example of an emotional claim: “The FAA’s proposal is a disaster! It will destroy our neighborhoods and ruin our quality of life!”

Steer Clear of Generalizations

Be specific and avoid making broad, unsubstantiated claims that lack evidence.

Example of an overgeneralized claim: “This proposal will lead to disastrous consequences for the aviation industry.”

Don’t Rely on Form Letters or Boilerplate Phrases

While form letters can show collective concern, personalized comments carry more weight. If many commenters send the same text, those responses may be lumped together rather than considered individually. 

Customize your comment to include personal experiences or perspectives.

Example: “Although I support the general premise of the proposed air traffic control reform, I believe it should incorporate more considerations for rural airports like the one I operate.”

Avoid Confrontation

If you want to ensure your comment will be read and make an impact, it’s important to maintain a respectful tone, even if you disagree with the proposal or other comments. Promote a constructive and collaborative discussion.

Example: “While I understand the concerns raised by other commenters, I believe that we can find common ground by enhancing safety protocols and ensuring continued airspace access for all stakeholders.”

Engaging in the rulemaking process with substantive comments is a great way to actively participate in shaping federal policies like those proposed by the FAA. By adhering to the do’s and don’ts outlined in this guide, you can create impactful and persuasive comments that contribute to the agency’s decision-making process and help achieve better policies for aviation safety, efficiency, and fairness. Remember, your voice matters, so use the opportunity to make a difference through thoughtful and well-informed commenting.

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Light Sport Category Could Expand Under Proposed FAA Rule Changes https://www.flyingmag.com/light-sport-category-could-expand-under-proposed-faa-rule-changes/ Thu, 20 Jul 2023 21:38:53 +0000 https://www.flyingmag.com/?p=176211 Agency is considering allowing heavier and faster aircraft into popular classification.

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If the buzz of pilots chatting at your local airport seems louder than usual, it probably has something to do with the FAA’s Modernization of Special Airworthiness Certification (MOSAIC) program.

The agency released a preview of its notice of proposed rulemaking (NPRM) for the program, which is aimed at reworking some of the rules governing the light sport category of aircraft.

The 318-page document details the FAA’s proposed changes to rules regarding the manufacture, certification, operation, maintenance, and alteration of light sport aircraft (LSA). The agency emphasizes how the proposed changes would improve safety and other aspects of light sport operations. However, the three elements that so far seem to excite pilots most are maximum takeoff weight, maximum speed, and stall speed.

Under the light sport rules established in 2004, aircraft in the category could weigh no more than 1,320 pounds at takeoff and fly no faster than 120 knots calibrated airspeed, with a stall speed of 45 knots or less. Proposed changes would increase takeoff weight to around 3,000 pounds, raise maximum speed to about 250 knots, and boost the maximum stall speed to 54 knots, depending on a number of factors.

The potential change is significant and could send pilots scrambling for operating handbooks to find out which aircraft could soon qualify for a revised, less-restrictive light sport classification.

The large swath of pilots with affection for the Cessna 140 and 150, along with other aircraft that come close to qualifying for light-sport duty, might be celebrating already. For years they have hoped for changes that might open up the LSA category to these small two-seaters, putting them in the same group with the Aeronca Champs. Piper Cubs and other LSAs, many of them antiques, already qualify. Such aircraft offer an especially economical light sport option. And not to mention the body of new near-LSAs that have come onto the market in the last 20 years.

The possibility of much higher limits also potentially opens the door to larger aircraft, such as Cessna 172s and Piper PA-28s, entering the light sport category, though even as four-seaters they would be limited to two occupants if flown under LSA rules. Essentially any airplane a pilot might have trained in probably would qualify under the proposed rules. Beechcraft Skipper, anyone?

Some aircraft we would not necessarily consider “light” could wind up qualifying. I imagine owners of certain high-performance models checking their V-speeds very closely. Indeed, I wondered about Annie, our Commander 114B. She can fly remarkably slowly, but 54 knots might be just out of range. Still, there might be modifications I could try, like vortex generators, or maybe a STOL kit. I’ll look up the list of STCs.  

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What This MOSAIC Preview Means https://www.flyingmag.com/what-this-mosaic-preview-means/ Thu, 20 Jul 2023 14:36:53 +0000 https://www.flyingmag.com/?p=176158 The FAA has released a preview to the ASTM committee, F37, on LSA, publicly available in the Federal Register ahead of the planned NPRM publication of the MOSAIC.

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The news landed with a collective “Really? They’re early?”

The deadline for the release of the FAA document—the notice of proposed rulemaking—that sets in motion the much-needed update to aircraft certification processes and guidance was set last year around this time for August 2023. As recently as a few weeks ago, colleagues in the industry agreed that it wasn’t likely that we’d see the NPRM for the Modernization of Special Airworthiness Certification (MOSAIC) before Oshkosh. The hangars and flightline at EAA AirVenture would be filled with folks speculating on whether the FAA would make its target or let another one pass.

Who could blame them, in a way? It’s a big task to overhaul the regulatory basis by which we define light sport aircraft and others in the limited category.

But word got out on Wednesday that the FAA had released a preview to the ASTM committee, F37, on LSA, publicly available in the Federal Register ahead of the planned NPRM publication.

All 318 pages of it.

I’ve never been so excited to curl up with an FAA document in my life. When I cracked it open, I went straight to the point where the meat of the proposal began. And, yes, within this document, indeed, the FAA proposes to amend rules “for the manufacture, certification, operation, maintenance, and alteration of light sport category aircraft.”

We’ll get into more of the nuances as we dissect the NPRM as a team, but I needed to get a sense of what gems lay within.

The first thing I had to know? The weight limit.

The Weight Limit?

As in, what are they doing with the artificial—and seemingly arbitrary, though it was ostensibly based on the European Union Aviation Safety Agency (EASA) ultralight category of 600 kilograms—weight limit of 1,320 pounds for light sport airplanes?

In a fit of common sense—that would be just one of many I’d find last night as I read into the late hours—the proposal gets rid of that intensely limiting parameter:

“Consistent with the FAA’s analysis of the safe operations accomplished under those exemptions, this proposal would eliminate the weight limits for light-sport category aircraft…[and] eliminating weight limits for light-sport category aircraft would provide manufacturers opportunities to:

• Incorporate additional safety-enhancing designs and equipment,

• Design airframes that are more rugged for the flight-training environment,

• Increase fuel load and aircraft range,

• Allow for greater cabin size to enable greater occupant heights and

weights,

• Improve aircraft handling in gusts, turbulence, and crosswinds, and

• Increase the suitability of light-sport category aircraft for other intended

operating purposes, including recreation, personal travel, and certain aerial

work.”

Instead, aircraft will be limited by VS1 (more on this in a moment), which will produce, according to the NPRM, an upper limit of around 3,000 pounds max gross weight. Whew. That’s a huge change. When Cessna was developing the Skycatcher 162 for the LSA and training market, so many decisions were made that were real compromises because of that 1,320-pound rule. My kingdom to have had that limit taken away…

One other immediate benefit to the change? This will allow for a four-seat aircraft to qualify, according to further verbiage in the doc. A pilot exercising sport privileges will only be able to take one passenger along, just like today, but those operating with higher certificate levels can utilize the aircraft to the max.

Stall Speed Updated?

Next up for revision, the maximum stall speed. To me, stall speed was always the best way to define the category because of all of the natural parameters a given stall speed would impose on the design. Put simply, an airplane that stalls at a lower indicated airspeed also lands at a slower speed and thus is easier for most pilots to manage. 

The NPRM recognizes this in clear argument, and puts forth 54 kcas as the target upper limit for airplanes, expanding this by a modest 9 knots from the previous 45 kcas set in the current LSA definition. 

What the increase does, however, is recognize the large body of heavier airplanes that otherwise fit the mission and prove easily managed by student pilots during flight training, such as the Piper PA-28 series.

What About Max Speed?

Stall speed naturally limits maximum speed in level flight (defined as VH in the LSA guidance), so the NPRM proposes to remove the max VH of 120 kcas under standard conditions and instead leave a natural upper parameter of around 250 kcas. Another “wow” moment. You mean we can go twice as fast? This alone will unlock a ton of potential from currently limited SLSA in the U.S. that are certificated under EASA CS 23 with faster cruise speeds.

And the list goes on. Restrictions on controllable-pitch props, retractable landing gear, and power sources for engines would be removed under the NPRM’s language. Expansion into IFR ops becomes a path for manufacturers to pursue. Sport pilot privileges for helicopters becomes reality. So. Many. Things.

What’s Next?

Publication of the document should occur on Monday, just in time for everyone at Oshkosh to get together and talk about it. I recommend you set aside time to study the preview (and the NPRM when published)—or you can follow along as our team dives into the specifics.

James Newberger, Aircraft Certification Service  (AIR-632) in Washington, D.C., holds point on comments. Prepare yours thoughtfully.

I’m already working on mine.

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Helicopter Industry Group Urges FAA To Use Caution With 5G NPRM https://www.flyingmag.com/helicopter-industry-group-urges-faa-to-use-caution-with-5g-nprm/ Tue, 18 Apr 2023 15:51:05 +0000 https://www.flyingmag.com/?p=170242 New federal rulemaking taking aim at potential 5G interference of helicopter radio altimeters should balance safety and operations, according to Helicopter Association International.

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Any new rule targeting potential 5-G C-band transmission interference with radio altimeters in helicopters needs to balance safety with operational impact, according to Helicopter Association International (HAI).

HAI’s comments come days after the FAA issued a notice of proposed rulemaking (NPRM) regarding the impact of 5G C-band transmissions on helicopters equipped with radio altimeters, which are also sometimes called radar altimeters.

For years wireless communication companies have been pushing the need for 5G C-band transmissions to handle the increase in wireless communications. There has been concern that 5G transmissions can interfere with the operation of radio altimeters, a device on many aircraft that provides pilots with information about the proximity of the aircraft to the ground. Radio altimeters are critical in low-visibility situations.

On April 12, the FAA released the NPRM on a proposed airworthiness directive designed to protect some 1,100 helicopters in the United States from 5G interference. According to John Shea, director of government affairs for HAI, the association is carefully reading the NPRM, and looking for a way that supports both safety and the mission of helicopters.

“At HAI, we understand and appreciate the FAA’s responsibility to ensure safety of the national airspace system for all its users. We are committed to working with the FAA on maintaining aviation safety in a 5G environment,” Shea said.

“It is important to recognize that the degree of dependence on a radar altimeter for safe helicopter operation can vary significantly based on the type of operation,” he added. “The FAA acknowledged this fact when establishing flight restrictions in their initial [airworthiness directive] AD. The recently published NPRM further acknowledges this by presenting operators with the choice to retrofit or to continue operating under the flight restrictions.”

Shea added that HAI is in the process of reviewing the NPRM that would replace the 5G-related AD for rotorcraft, adding, “In the coming days, HAI will submit public comments on the NPRM in the federal register. At that time, we will also release a statement summarizing our positions.”

According to Shea, the NPRM “establishes an interference tolerance threshold for radio altimeters on rotorcraft. Operators who retrofit their equipment to meet the threshold will not be subject to the flight restrictions in the AD, whereas those who do not retrofit will be subject to restrictions throughout the contiguous United States.”

The challenge, says Shea, is that there needs to be a balancing act between safety and operational impact of regulatory action, as helicopters are essential support in critical industries such as law enforcement, construction, and national security.

“Therefore, any revisions to the AD must be both effective and reasonable. Any undue financial or operational hardships imposed on the helicopter industry could have substantial downstream consequences for the vital industries and emergency response entities we serve.”

Per the FAA, the AD is for all helicopters equipped with a radar altimeter due to the potential for 5G C-band interference.

“This proposed AD would supersede a 2021 AD because the FAA determined additional limitations are needed due to the continued deployment of new 5G C-Band base stations.” the FAA states. “It requires revising the rotorcraft flight manual to prohibit certain operations that require radar altimeter data. The AD would require the rotorcraft flight manual revision on or before June 30, 2023.”

As previously reported in FLYING, multiple airports have Notices to Air Missions (NOTAMs) warning pilots about the potential impact of 5G transmission in their vicinity. In January 2022, the wireless companies voluntarily reduced the power of the 5G towers near airports to help protect air traffic while the industry focused on developing protections against interference.

The FAA noted that both AT&T and Verizon agreed to keep their voluntary mitigations in place until July 2023 to give the aviation industry an additional year to retrofit their airplanes with radio frequency filters.

The airlines have until 2024 to make upgrades to comply with 5G per an FAA AD. The proposed AD requires passenger and cargo aircraft in the U.S. to be equipped with 5G C-Band tolerant altimeters by next February.

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