AOPA says NO to applying proposed transponder rule to GA

March 20, 2003

Docket Management System
U.S. Department of Transportation
Room Plaza 401, 400 Seventh Street, S.W.
Washington, D.C. 20590-0001

REF: Docket No. FAA-2002-14081; Notice of Proposed Rulemaking (NPRM);
No. 03-02
Transponder Continuous Operation for Part 121 Air Carrier Operations

To Whom It May Concern:

The Aircraft Owners and Pilots Association (AOPA), representing the interests of over 390,000 pilots and aircraft owners, submits the following comments for the Federal Aviation Administration (FAA) rulemaking contained in Docket No. FAA-2002-14081:

AOPA is strongly opposed to applying the requirements of this proposed rule to general aviation operations and recommends that the FAA not undertake similar future rulemaking action for general aviation operations conducted under Part 91.

Unlike commercial air carrier operations, the general aviation pilot knows the passengers on board and what they are carrying. Furthermore, general aviation aircraft are used for personal and business transportation, just like an automobile, and the nature of these operations makes application of this rule to Part 91 operators unnecessary.

Sincerely,

Melissa K. Bailey
Vice President
Air Traffic, Regulatory and Certification Policy

March 13, 2003