MOSAIC enables towing with LSA

[David S]

As mentioned in an earlier thread, the final rule for Modernization of Special Airworthiness Certification (MOSAIC) is out, and it removes an obstacle to towing.   Here's an excerpt from page 55 of the 717 page document:

The ability for light-sport category aircraft to tow gliders, per § 91.327, has existed since the 2004 final rule. However, because the tow-hitch and installation requirements in § 91.309(a)(2) require Administrator approval, but light-sport category consensus standards for towing have only gained FAA-acceptance, this gap has deterred use of light-sport category aircraft in towing operations. This situation was explained in section IV.H.6 of the NPRM. This final rule resolves this issue with new requirements in § 91.309(a)(2) that allow for Administrator acceptance or approval of a tow-hitch and its installation. This topic is further discussed in section IV.K.1.b.

https://www.faa.gov/newsroom/MOSAIC_Final_Rule_Issuance.pdf

So it would appear that the Eurofox (imported in North America as Aerotrek, aerotrek.aero), and AEROPRAKT (heavenboundaviation.com), and others can now be used for glider ops.  Aerotrek's web page says $130k new.  Looks like $180k for a AEROPRAKT.  I can't tell if these prices include tariffs.

Compared to a Pawnee, they burn half as much fuel, are quieter, and have liquid cooling so they can get down faster for the next tow.

But it's not all roses.  For starters, by definition they are light, so I imagine they are more easily upset by a kiting glider, and sooner or later you will need to find a full-service shop for the Rotax engine.

And I'm not a power pilot, so I expect there are even larger issues to consider.  

Cheers,

   ...david

[Ian Molesworth]

We tow up to an Arcus M with 2 aboard with a Eurofox 915 is out of Denbigh in North Wales. Denbigh is a wave site and it can get *very* sporting as our field has some epic curlover and wind gradients around the field. Yes, the Eurofox can be upset by a kiting glider but to be brutally honest, training should instill attentiveness on tow. Getting that far out of position shouldn't be allowed whatever the tug is. 

We have the retractable tow line winch and a very effective guillotine that rhe tuggie will not ( and has not ) hesitate to use if you take it in mind to try to kill him. ( or her )

A badly kiting glider will kill even a Pawnee pilot, it should never happen!

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[Mike Koerner]

Facilitating the installation of a tow hook is certainly a step forward and it may be a significant benefit to some clubs. Is there anything in this rule, or any interpretation of previous rules, that would allow a commercial operator to charge for a tow using an LSA?

[Mike Koerner]

Here is an AI generated answer:

A commercial glider operation in the US can now use a Light-Sport Aircraft (LSA) for towing, due to regulatory changes finalized under the FAA’s MOSAIC rule, which was announced on July 22, 2025 and takes effect 90 days after its publication in the Federal Register.

Previously, LSAs were generally prohibited from most commercial activities (including glider towing for hire) except in very limited cases, and regulations like 14 CFR §91.327 strictly circumscribed compensated operations. However, the new MOSAIC rule significantly expands the scope of allowable commercial activities for LSAs to include various aerial work operations—explicitly including glider towing, as long as the activity is in accordance with both the aircraft’s Pilot Operating Handbook (POH) and the manufacturer's statement of compliance.

For a commercial operation to use an LSA for glider towing, the following key conditions must be met:

• The LSA must be equipped and certified for glider towing per its POH and manufacturer's documentation.

• The operation must comply with the new MOSAIC rule’s requirements and revised 14 CFR §91.327.

• The pilot-in-command must meet all FAA certification and endorsement requirements for glider towing under §61.69, including holding at least a private or commercial pilot certificate with the required endorsements for towing.

• All equipment (such as tow hitches and towlines) must meet FAA standards for glider towing.

This regulatory overhaul reflects a major industry shift and is intended to enable more practical, cost-effective aircraft to be used in gliding operations as well as other aerial work.

In summary, as of late 2025, commercial glider operations in the US will be permitted to use qualified LSAs for towing, pending compliance with all relevant FAA certification and operational requirements

[Moshe Braner]

Thanks Mike.  But, did that "AI generated answer" include a link to an actual source?  I don't otherwise trust "AI" for anything.  It often clearly misinterprets my questions.  The language quoted here seems reasonable, but still.

[Mike Koerner]

Moshe,

It gave just these 5 references (two from the SSA) which were stripped off when I cut and pasted the AI response to this forum:

https://www.dlapiper.com/en-us/insights/publications/2025/07/faa-issues-final-mosaic-rule

https://downloads.regulations.gov/FAA-2023-1377-0839/attachment_2.pdf

https://www.flyingmag.com/faa-finalizes-major-overhaul-of-light-sport-aircraft-rules/

https://www.ssa.org/federal-aviation-regulations-for-tow-pilots/

https://www.gleim.com/aviation/faraim/index.php?leafNum=91_309

Mike

[Moshe Braner]

OK.  Those reference links (as I checked them now) are either broken, or to irrelevant pages, or ("attachement_2") to what the SSA requested MOSAIC to include (whether included in the actual rule or not).  The so-called "AI" generated text may have copied and pasted bits of all of them into one plausible-looking whole.  I would not take it as authoritative until a real source is found.

[Bill Tisdale]

https://www.federalregister.gov/documents/2025/07/24/2025-13972/modernization-of-special-airworthiness-certification

The Federal Register document is 189 pages. It includes all of the topics, responses from reviewers and the FAA response to those items.

The rule becomes effective Oct 22, 2025 with some items not becoming effective until July 24, 2026.

MOSAIC impacts 14CFR PArts, 1, 21, 22, 36, 43, 45, 61, 65, 91, 119 and 147

Bill

[Paul Agnew]

I'm trying to determine if there a distinction between L-LSA and E-LSA for towing under the new rules.  

L-LSA could be used for commercial purposes, but E-LSA could not under the old rules.  

PA

[Bud Shaw]

Another clarification, backed up with ChatGPT

Before MOSAIC, under the FAA’s Sport Pilot / Light-Sport Aircraft rule, there were two main categories of LSA:

1. SLSA (Special Light-Sport Aircraft) – factory-built, meeting ASTM consensus standards, issued an airworthiness certificate in the “Special” category.
   
• May be used for certain commercial purposes, such as:
  
• Flight training for hire (when operated by a flight school or CFI)
• Rental
• Towing a glider or unpowered ultralight (if appropriately equipped and authorized)
• Cannot be used for general commercial operations like Part 135 air taxi or carrying passengers for hire.
  The “commercial use” allowance is narrow — it’s essentially for training, rental, and towing under Part 91.
2. ELSA (Experimental Light-Sport Aircraft) – can be:
• Amateur-built to LSA specs, or
• Converted from an SLSA (often for owner modifications)
• Issued an Experimental category airworthiness certificate
• Cannot be used for hire, except in very limited circumstances like instruction in the aircraft by its owner (if it meets certain exemptions, usually tied to transition training). No rental or flight-for-hire allowed.

So yes — your statement is essentially correct: SLSA can be used for certain commercial purposes; ELSA cannot. But “commercial” for SLSA is not unlimited — it’s mostly training, rental, and towing within the FAA’s rules.

If you want, I can give you the exact FAA regulation citations that spell out those allowed uses so you have a primary source. That way there’s no ambiguity.