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MOSAIC and Vintage Aviation

If you regularly hang around a circle of general aviation or vintage aviation enthusiasts, you might have heard the term ‘MOSAIC’ thrown around in casual conversation following its announcement at the EAA’s 2025 Oshkosh Airventure. MOSAIC, short for Modernization of Special Airworthiness Certification, is an effort by the Federal Aviation Administration to expand the privileges of the sport pilot, change the certification standards of Light Sport Aircraft, and update the capabilities of the repairman certificate holder. Taking effect on 22 October, 2025, updates for the sport pilot include flying at night, flying rotary-wing aircraft, flying aircraft with retractable gear, flying aircraft with constant-speed propellers, and many other changes that were previously nonexistent in the sport aviation realm. In other words, MOSAIC aims to separate Light Sport Aircraft from sport pilots and overhaul their relationship and individual privileges. 

This regulatory update by the FAA allows vintage aviation lovers across the country, who are sport pilots or intend on operating under sport pilot privileges, to potentially fly their favorite vintage machines. In this article I aim to make MOSAIC digestible and easy to understand for those interested in pursuing the path of sport pilot or repairman in the world of pre-war aviation to the Golden Age. 

Here it what MOSAIC means for:

The flyer:

The MOSAIC ruling expands the types of aircraft sport pilots can fly. This regulation will still be 14 CFR § 61.316 but will be overhauled to reflect the new performance and design requirements that must be met for a sport pilot to operate the machine and will replace the current Light Sport Aircraft definition found in Title 14 CFR § 1.1. It is also worth noting that if you have a higher certificate than a sport pilot but still aim to fly under sport pilot privileges in the same category and class, you can have a blast up in the air but shall comply with the sport pilot regulations found in 14 CFR part 61! 

So, what has changed under MOSAIC for the flyer?

-There is no longer a 1,320lb weight limit! As long as your aircraft meets the performance requirements outlined in FAR 61.316, you are eligible to fly that aircraft.

-Flying at night is a possibility! MOSAIC allows sport pilots to fly at night after they receive the appropriate training and endorsements, the details of which can be found under 14 CFR § 61.329. Hint: it’s a total of three night hours! So, if you want to relive the days of flying Air Mail biplanes over the Alleghenies, you could!

-A sport pilot may act as PIC in an aircraft with a seating capacity of up to four persons, however the limitation of one passenger has not changed. Want to take up that three-seater biplane with a passenger up front? Go for it! Unfortunately, it still cannot be for compensation unless the sport pilot is a certified instructor and actively instructing.

-Stall speeds help determine which aircraft you can fly! This new ruling permits sport pilots to fly an aircraft with a maximum stall speed (VS1) of 45 KCAS. That being said, airplanes specifically are subject to a different VS1: 59 KCAS. Now, you might be asking yourself “what if my airplane has vortex generators or aftermarket additions that help lower the stall speed?” Well, the FAA has an answer for that too! These aftermarket devices cannot be used in the original certification of the aircraft regarding the stall speed reference for a sport pilot to follow. They are, however, allowed on the aircraft after the certification of the aircraft and its official VS1 number is calculated. In other words, a STOL kit or vortex generators cannot be on the aircraft when the aircraft is certified and its VS1 speed calculated. 

-Maximum Continuous Power (VH) of 120 KCAS is no longer a limitation; it is now ≤250 KCAS. Although that restriction has been lifted, the FAA is retaining their regulations for a VH of 87 KCAS for sport pilots. What that means, in short, is that you need proper training and endorsements to operate an aircraft with a VH of at or below 87 KCAS and at or above 87 KCAS. More of this interesting regulation is detailed in FAR 61.327. Essentially, ensure you have the proper endorsement and training for the aircraft that fits into one of those categories before you go flying that bus. It is worth noting that this was notated in Advisory Circular 61-146 which is still in the draft phase.

-The traditional powerplant limitation is gone! To elaborate, the FAA says a sport pilot can fly an aircraft with any powerplant as long as it does not require a type rating and still complies with the aircraft performance limitations.

-Many vintage biplanes and Golden Age aircraft are not equipped with a controllable-pitch propeller, but if you are looking into flying one that indeed meets the MOSAIC limitations outlined in FAR 61.316, you can fly it! That is, of course, only after you obtain the proper training and endorsements. 

-Interested in flying that Mooney Mite as a sport pilot? Go for it! Aircraft with retractable landing gear have been approved under MOSAIC. Of course, proper training and endorsements must be obtained prior to acting PIC in such a machine.

Many historic biplanes and vintage aircraft that we know and love unfortunately exceed some limits of the current Light Sport Aircraft regulations, making it impossible for sport pilots to fly them. However it appears MOSAIC will make most of our favorite vintage machines available to the sport pilot or a pilot exercising sport pilot privileges. Some common Golden Age airplanes you could potentially fly once MOSAIC takes effect are:

-Early Waco open cockpit biplanes (GXE, 10, 9) and similar open cockpit biplanes

-Fleet Biplanes such as the Model 2 or Model 7

-Airdrome Airplanes aircraft (Sopwiths, Newports, Fokkers, Bleriots)

-Curtiss-Wright Junior CW-1

-Aeronca C3

-Cessna 120

-Luscombe 8E/F

-Ercoupe

-Piper J-2/J-3

-Pietenpol Air Camper

-Taylorcraft BC-12D

-Great Lakes biplanes 

-Travel Air 2000 and 4000

-PT-17 or later Waco open cockpits

…and many others that meet the requirements of MOSAIC outlined in 14 CFR § 61.316!

The maintainer:

Regulations regarding the repairman certificate are also proposed to change under the FAA’s new MOSAIC ruling, and are aimed at providing more people with legal authority to maintain and inspect the aircraft they build, own, or operate with fewer hoops to jump through. Under this new ruling, the repairman certificate is retained but is expanded to include new Light Sport Aircraft. Here is what those changes looks like:

-With MOSAIC’s larger universe of aircraft (faster aircraft, four seaters, and even helicopters), category and class restrictions of the individual’s repairman certificate will need to be followed closely. A light-sport airplane repairman cannot work on a light-sport helicopter!

-Terminology has changed: What was a Repairman Certificate (light-sport aircraft) is now a Repairman Certificate (light-sport) under MOSAIC to comply with the new FAR.

-The repairman certificate is still training based but far more accessible than an A&P certificate. For example: You could take a course and become certified to perform inspections on your 4-seat, 2-seat-used LSA biplane under MOSAIC.

-MOSAIC may allow you to perform maintenance on your aircraft even if you are not the builder!

Flow chart explaining if a sport pilot can fly a certain aircraft under MOSAIC:

Step 1: Have an aircraft you want to fly?

Question 1) Does it already have an airworthiness in Special-Light Sport Aircraft (S-LSA), Experimental-Light Sport Aircraft (E-LSA), Experimental Amateur-Built (E-AB), or Primary Category? 

If Yes: Proceed to Step 3

If No: Proceed to Question 2

Question 2) Is this an aircraft in the Standard Category?

If yes: Proceed to Step 2

If No: Not eligible for sport pilot operation under MOSAIC unless properly certified 

Step 2: Standard Category Aircraft Check

Question 3) Does the aircraft’s performance meet MOSAIC’s limits?

  • VS1 (clean stall): ≤ 59 KCAS
  • VH (max level flight speed): ≤ 250 KCAS
  • Seats: ≤ 4 total, but the sport pilot can still carry only one passenger
  • Meets handling/structural criteria 

If Yes: Sport pilot can operate without recertification if within privileges

If No: Needs manufacturer-driven recertification (TC amendment, Primary Category, or S-LSA declaration) before a sport pilot can fly it. 

Step 3: Already in Sport Pilot-Eligible Category

Question 4) Does it meet MOSAIC performance and operational limits?

If Yes: Sport pilot can fly the aircraft once MOSAIC rules take effect in late 2025

If No: Needs modifications or is ineligible

The FAA’s Modernization of Special Airworthiness Certification, widely called MOSAIC, greatly expands the authority and abilities of sport pilots and light-sport repairmen; although sport pilots and the certification of Light Sport Aircraft were the main focus of the regulation change. It opens doors for sport pilots that were concretely closed for over two decades by allowing them to fly a wider range of aircraft with increased cruising speeds, retractable landing gear, more seats, and many more notable updates. This will play a tremendous role in the vintage aviation community as many barnstorming biplanes, WWI machines, and Golden Age aircraft were off limits until now. If you are a sport pilot or seek to exercise sport pilot privileges, this ruling is certainly worth your time and understanding. Because the chances are once this ruling takes effect on 22 October, 2025, your favorite vintage aircraft at the local airport might be flyable by a sport pilot!

Sources:

-AC 61-146 (draft), Modernization of Special Airworthiness Certification, Code of Federal Regulations

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