NAAA Comments on FAA’s Proposed Changes Aircraft Airworthiness Certification to Address Potentially Unnecessary Regulatory Burdens to Certify Ag Aircraft

To ensure that ag aircraft manufactures aren’t unnecessarily burdened by the regulatory approval process, NAAA submitted comments this week to FAA’s notice of proposed rulemaking (NPRM) for amendments to the Modernization of Special Airworthiness Certification (MOSAIC), specifically the part related to the certification of restricted category aircraft.

There were three main points made in the comments:

• Language regarding issuance of a restricted category type certificate to former military aircraft needs to be written to ensure that aircraft originally produced for civilian use before being modified for military use are eligible for a restricted category type certificate following their release from the military.
• FAA’s new list of proposed special purpose operations for restricted category aircraft should include all possible types of operations assigned to agricultural aircraft to avoid future issues where a specific type of ag operation is covered under Part 137 but is not listed as a special operation in MOSAIC.
• Due to the important nature of agricultural and firefighting aircraft, both should continue to be exempt from noise requirements.

NAAA also reached out to FAA personnel familiar with the NPRM, who indicated the goal for the list of special purpose operations is to expand, not reduce, the list of operations that a restricted category aircraft can be used for. They also stated they do not intend to require agricultural aircraft to be subjected to noise requirements. Click here to read NAAA’s full comments.