Post-MOSAIC guidance for sport pilots updated

The first phase of the Modernization of Special Airworthiness Certification (MOSAIC) final rule established a suite of new sport pilot privileges—including flying at night and flying aircraft with constant-speed propellers and/or retractable gear—that sport pilots may gain with an instructor's endorsement, and the updated Advisory Circular 61-65K includes sample sport pilot endorsements that instructors may issue. Advisory Circular 61-146, also published November 14, is MOSAIC-specific, detailing many aspects of the practical application of the rule, including how sport pilots may earn endorsements to fly helicopters with simplified flight controls (which have not yet entered service).

Together, the circulars answer many of the same questions that AOPA has answered for members (our MOSAIC FAQ continues to be updated, and the Pilot Information Center fields MOSAIC questions from members regularly). The new rule cut the ties between sport pilots and sport-category aircraft (known as light sport aircraft from 2004 until July 2025, when the definition of an LSA was stricken from the FARs), and eliminated restrictive limits on aircraft weight and operating speed in the 2004 rule that created LSAs—and inspired a cohort of aircraft capable of flying two people on short trips, none of which ultimately left the factory for anything less than $100,000, as had been hoped.

As of October 22, sport pilots (and pilots with higher certificates exercising sport pilot privileges, which may be exercised without a medical certificate or BasicMed) are allowed to fly most single-engine, four-seat airplanes in service, including Cessna 172 and 182 models, most Piper PA–28 series aircraft, and many others. That is a safe statement to make, primarily because the Cessna 172 is the most-produced aircraft in history, and is comfortably within the sport pilot stall speed envelope.

While the FAA reiterates the new regulations in AC 61-146, defining aircraft that sport pilots may fly based on a clean stall speed (V_S1) at or below 59 knots calibrated airspeed, the agency has not yet produced a list of qualified aircraft based on the new criteria. Members have asked, and AOPA has contacted several manufacturers and type certificate holders of single-engine aircraft with up to four seats, seeking V_S1 data in KCAS.

That is a taller order than you might think. While the pilot's operating handbook or airplane flight manual usually contains stall speed data, airspeed calibration data is not published in all cases. Maule Air, a family-owned Georgia airplane maker founded by B.D. Maule in 1941, delivered its first aircraft in 1962, and has produced many certified aircraft since, none of which are LSAs and nearly all of which are likely to fall below the new sport pilot stall speed limit. Brent Maule, grandson of the founder, emailed a spreadsheet listing stall speeds for 40 Maule models, of which only the M-5-235C is close to or over the new sport pilot limit, depending on serial number. But those are also indicated airspeeds, and Maule referred questions about calibration data to contract test pilot Lawrence West, who said it would take time to dig up those flight test reports, and pointed out a limitation on that definitional limitation itself: Airspeed indicators must be calibrated within 30 days of a test flight to be considered accurate, and the number on the flight test report may vary from what an actual aircraft would produce if tested years—or decades—later.

The FAA does make it clear in the new circulars that modifications such as vortex generators that reduce the stall speed of a given aircraft don't count— the V_S1 KCAS must be based on the aircraft as it was originally certified.

West said there are likely to be many cases—including Maule models—where that calibration information—such as a table or a graph—just isn't in the POH (or AFM, as the case may be). Aviat Aircraft supplied a series of mathematical formulas to calculate calibrated airspeed, noting that indicated and calibrated airspeeds will almost always be close. If the owner of an aircraft, particularly one that is close to the limit, wants to establish that their aircraft may be flown with sport pilot privileges, West said, they might have to put on their test pilot hat: "They're going to have to go out and do their own chart, I would suppose."

The FAA does have advice on that, in another advisory circular written for kitplane builders: AC 90-89C published in 2023 details in 130 pages flight testing procedures for ultralight and amateur-built aircraft, including stall speed test procedures.

Maule called back to confirm there is actually no difference between indicated and calibrated V_S1 speeds for the M-7 series models (12 of the 40 Maule variants), confirming each of those speeds ranges between 53 and 55 KCAS, as well as KIAS. The rest of the four-seat Maule models (the five-seat M-9-235 appears to be excluded based on a rear bench that seats three) also appear sport-pilot eligible, though Maule pledged to continue digging for additional calibration confirmation.

Piper Aircraft produced (within days of AOPA's request) a list of Piper models dating back to the J–3 Cub that cites company records and lists calibrated V_S1 speeds to the tenth of a knot. Based on this information, nearly every model of Piper with up to four sets qualifies for sport pilot use, up to the PA–24-180 Comanche 180 (V_S1 of 58.2 knots KCAS); the four-seat Cherokee 235 (PA–28-235) falls just over the line, according to Piper's data, with a V_S1 of 60.8 KCAS.

While Maule and Piper took pains to cooperate, Textron Aviation declined to provide relevant information, or any information at all pertaining to out-of-production aircraft such as the Cessna 210, which was first introduced in the 1950s with a Cessna 182 airframe and a fuel-injected 260-horsepower Continental engine. Over the years, the 210 was stretched, and in 1970 it gained two seats, pushing those later models out of the new sport pilot envelope, though early models might well be in it: AOPA's aircraft fact sheet for the Cessna 210 lists a clean stall speed of 57 knots for the 1960 version, increasing to 65 knots in 1972.

It is unlikely that AOPA will ultimately be able to produce a comprehensive list of every aircraft currently in service that can be flown with sport pilot privileges based on verified data, given the complexity of the task and the limitations on available information, though aircraft owners are invited to email the stall speed and calibration data they may have in a POH or AFM for possible inclusion in such a list as may eventually be achievable.