This NPRM provides no benefits to general aviation and is extremely costly.
Eliminate the mandate to equip for any but Class A airspace. ADS-B has not
been shown to provide any safety nor reduction in costs. No quantifiable cost
savings in time or monetary benefit has been demonstrated to the flying public.
The analysis that 30 seconds may be saved on a commercial flight is absolutely
rediculous in comparison to a recommend arrival for passengers two hours before
their flight or thirty minutes to retrieve luggage.
GA is in a sharp decline with no foreseeable growth in the future. GA is currently
over-regulated and costs are prohibitive. Not only have GA aircraft prices
skyrocketed, but GA fuel costs are outrageous. Regulations pose a huge threat of
punitive action against GA for inadvertant errors.
Terry W. Adams
This is comment on Rule
Revised Initial Regulatory Flexibility Analysis
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