It’s the stuff of science fiction: walk out to your airplane, strap in, and, instead of a control wheel and assortment of dials and levers, you are presented with a slender device resembling an iPad. Touch “takeoff” on the screen and the airplane flies itself safely from the ground and navigates to the destination, applying sophisticated automation as a virtual guardrail to avoid hazardous situations along the way, and then on arrival you simply touch “land” to complete the flight.
This is neither fiction nor the future — it is now. The FAA has embraced the concept of simplified flight controls and featured it in its forthcoming refresh of regulations governing light sport aircraft and sport pilot certificates.
Background
In 2004, the FAA issued regulations that established a new aircraft class, the light sport aircraft (LSA).[1] As originally conceived, LSA were small aircraft that were easier and cheaper to certify than traditional aircraft and could be used for basic recreational purposes and flight training.
The certification process was simplified for LSA as compared to traditional aircraft. The FAA published general performance-based requirements and the industry developed specific voluntary consensus standards to which LSA were required to conform. With this approach, the FAA sought to encourage innovation and the more rapid adoption of safety enhancements that kept pace with new technology.
The FAA also created a new kind of pilot certificate, the sport pilot certificate, which allowed people to fly LSA without needing to satisfy the stricter standards of traditional pilot and medical certificates. Sport pilots were, however, subject to additional limitations, such as prohibitions on night operations and flying in return for compensation.
These changes were intended to support general aviation by reducing the cost of entry to private flying, encouraging more pilots to start flight training, and laying the foundation for a resurgence in manufacturing. In practice, these goals were not quite achieved, for reasons attributed by some to inherent limitations of LSA that held back their utility.[2]
In the years since the rulemaking, the industry advocated for changes that would enlarge the scope of aircraft that can be classified as LSA and expand their permitted uses. For its part, the FAA studied data on LSA operations and their safety record, and, in 2023, decided that the time was right to update the regulations.
Enter the MOSAIC
In July of 2023, the FAA issued a notice of proposed rulemaking, Modernization of Special Airworthiness Certification, known as “MOSAIC,” which was intended to modernize its approach to LSA by embracing technological advances and enlarging the scope of their permitted operations.[3] It removed weight and top cruise speed limits, as well as restrictions on advanced features like retractable landing gear, controllable speed propellers, and multiple engines. The proposal also expanded LSA to include helicopters and powered-lift aircraft.
The proposal increased the privileges of sport pilots, allowing them to conduct operations at night and under instrument flight rules, engage in some commercial flying like aerial photography, surveys, agriculture, and pipeline patrol, and fly some non-LSA airplanes with four seats provided that they abide by limitations such as only carrying one passenger at a time.
In the NPRM, the FAA noted that “rapid advances are occurring in aircraft automation and flight control technology,” including interfaces and flight controls that “no longer resemble those found in traditional aircraft cockpits” and “highly automated systems for controlling the flight path, speed, and configuration of the aircraft. . . .”[4] The FAA’s proposed regulations would facilitate development of such highly automated aircraft by proposing a path for their approval as LSA.
Further, the FAA proposed to allow sport pilots who had not received training or experience necessary to operate traditional aircraft to operate qualifying LSA with simplified flight controls.
Indeed, the MOSAIC proposal amounts to an innovation in product certification because it announced a formal process supporting the approval and use of advanced technology aircraft with simplified flight controls. Although starting with LSA, the FAA’s approach could have significant impacts on the certification and operation of other kinds of aircraft in the future.
Simplified Flight Controls in the MOSAIC Rulemaking
The framework proposed by the FAA is straightforward. A LSA that satisfies specific design criteria can be designated by its manufacturer as having simplified flight controls, and a pilot must receive model-specific flight training in order to operate that aircraft.
In order to receive a simplified flight controls designation, the aircraft must:
- Allow the pilot to control only the flight path of the aircraft or intervene in its operation without direct manipulation of individual control surfaces or power adjustment;
- Be designed to inherently prevent loss of control, regardless of pilot input; and
- Have a means to enable the pilot to quickly and safely discontinue the flight, with safeguards to prevent inadvertent activation of it.[5]
A key feature that the FAA requires is that the design “inherently” prevent loss of control “regardless of pilot input,” which the Agency explained as follows:
“The FAA considers that a design inherently prevents loss of control if the design includes built-in features such as automation which prevent the pilot from inputting a flight command that would be hazardous to the aircraft or its occupants. Additionally, the aircraft design would need to include features so that the aircraft could only be operated within its designated flight envelope and within its prescribed operational limitations.”[6]
This describes something akin to sophisticated automation capability found in airliners like flight envelope protection, which prevents an aircraft from getting into an undesirable attitude or corner of the performance envelope regardless of pilot input, and also takes into account abnormal conditions, such as engine failures:
“If used in the design, automation would have to prevent loss of control of the aircraft under all circumstances, even to the point of overriding erroneous or hazardous pilot inputs or only permitting the input of certain commands in specific flight conditions.”[7]
Such an advanced system ensures that safe control within operating limitations is always maintained. It has the added benefit of reducing pilot workload and affording pilots more time to focus on decision making and flight management in all situations, including emergencies.
The proposal also required the system to afford the pilot a quick, automated means to discontinue a flight to address an imminent hazard or other situation. In this context, discontinuing the flight could encompass “an immediate landing, a return flight to the aircraft’s point of departure, a diversion to an alternate landing site, a course change, or initiation of a low altitude orbit or in-place hover until any hazards have passed.”[8]
In the MOSAIC rulemaking, the FAA also proposed for the first time to allow holders of sport pilot certificates to operate helicopters newly designed as LSA, but only those with a simplified flight controls designation.[9] This demonstrates the FAA’s belief in the meaningful enhancements that simplified flight controls offer over traditional flight control systems.
Pilot Privileges and Authorizations
In order to operate aircraft with a simplified flight controls designation, the pilot-in-command must receive model-specific training in each specific aircraft and a logbook endorsement from an instructor finding the applicant proficient in the safe operation of that model.[10]
This requirement will apply to any pilot, regardless of their certificate level.[11] Thus, a pilot holding a commercial certificate (which has heightened standards over a sport pilot certificate for experience, training, and proficiency) will be required to receive training and a logbook endorsement for a specific model aircraft with simplified flight controls. The endorsement is not transferrable, meaning that a pilot with an endorsement in a particular make and model aircraft will be required to receive training and a separate endorsement if they desire to fly a different make and model with simplified flight controls.
A wrinkle in this framework is that, if a pilot seeking a new certificate, rating, or privilege desires to take the practical test in an aircraft with a simplified flight controls designation, on passing the test the pilot will receive a certificate with a limitation to that specific make and model. If they desire to fly a different make and model in the same category and class, they will be required to receive training and a model-specific endorsement for the different aircraft.[12]
A pilot could, therefore, receive a sport-pilot certificate that authorizes them to fly a specific model LSA with simplified flight controls and no other kind of LSA.
Open Items, a Paradox, and the Future
As a measure of the MOSAIC rulemaking’s significance, over 1,300 public comments were filed before the January 22, 2024, deadline. It appears likely that key aspects of the proposal will survive the FAA’s responses to comments, but it is unclear how long the Agency will take to issue the final rule.
Numerous unknowns about simplified flight controls in LSA, as well as their introduction into other kinds of aircraft, remain. Matters that the MOSAIC proposal leaves open but which merit further consideration include:
- The proposal allows sport pilots to operate light-sport helicopters with a simplified flight controls designation but not powered-lift LSA such as eVTOL designs. With appropriate simplified flight controls and other systems, there is no reason why a sport pilot could not operate a powered-lift LSA just as safely as a helicopter.
- The proposal does not address whether or through what mechanism derivatives of existing type certificated aircraft that are comparable in size and performance to LSA could be modified and then approved as LSA. Manufacturers of existing type certificated aircraft should have a straightforward path to entering the LSA market so that benefits of the LSA category are spread as widely as possible.
- Similarly, aftermarket modifications to existing type certificated aircraft, such as by adding simplified flight control systems through a supplemental type certificate, could render them equivalent in performance to clean-sheet LSA designs. The proposal does not address this scenario.
- More generally, the proposal leaves open how the FAA will address the incorporation of simplified flight controls into Part 23 airplanes and Part 27 rotorcraft, as well as how pilots will be trained and approved to operate such systems.
In addition (and this will seem like heresy to some), reliance on voluntary industry consensus standards without exception could potentially have a negative impact on the timely introduction of cutting-edge enhancements like simplified flight controls. This is because, for truly novel technology, manufacturers may be reluctant to share their innovations – the “secret sauce” of their designs – with competitors for purposes of developing consensus standards. In addition, companies may block or slow the development of standards that could help their competitors get to market faster.
Thus the paradox: consensus standards for truly novel technology may not be available on a reasonable timeline, thereby potentially slowing or limiting introduction of innovative enhancements to operations and safety.
To be sure, the use of industry consensus standards in aircraft certification generally does support adoption of new features in a more rapid manner than traditional airworthiness standards issued through regulation. Nevertheless, the FAA should not ignore the commercial realities of putting competitors in positions to act as gatekeepers to the approval and introduction of truly novel technology.
Enlarging the scope of LSA and their operations is a significant initiative, and the FAA’s engagement in developing means to approve the incorporation and use of simplified flight controls is valuable and welcome.
Next, the safety and operational benefits associated with simplified flight controls and advanced automation should be brought to the world of type certificated general aviation aircraft as soon as possible, under a coherent and consistent regulatory framework that rewards innovation and progress.
Notes
[1] Final Rule, Certification of Aircraft and Airmen for the Operation of Light-Sport Aircraft, 69 Fed. Reg. 44,771 (Jul. 27, 2004). LSA were defined as aircraft weighing less than 1,320 pounds, with a maximum stall speed of 45 knots, cruising speed no greater than 120 knots, and equipped with no more than two seats and fixed landing gear.
[2] Perhaps another reason for lukewarm acceptance of LSA was more mundane: the average person with resources sufficient to take up recreational flying would compare a small, two-seat LSA to a larger, faster traditional aircraft and decide to invest in the option that appeared more capable.
[3] NPRM, Modernization of Special Airworthiness Certification, 88 Fed. Reg. 47,650 (July 24, 2023).
[4] Id. at 47,674.
[5] Id. at 47,728 (proposed § 22.180).
[6] Id at 47,674 – 47,675.
[7] Id. at 47,675 (emphasis added). For multi-engine aircraft, the proposal requires that “the aircraft would need to be able to safely respond, using the aircraft’s automation, to asymmetric power situations due to loss of engine power.” Id.
[8] Id. at 47,675.
[9] Id. at 47,733 (proposed § 61.316(a)(8)).
[10] Id. at 47,730 (proposed § 61.31(l)).
[11] Id. at 47,685
[12] See id. at 47,730 (proposed § 61.31(h)).
