Comment Submitted by Robert J. Preston

I think these new requirements are overly burdensome to small owners of private aircraft. First, there are many places in Canada and in the South of our border where internet access is not available nor is phone service with many US carriers. Placing this burden on other known people to supply the information for you is merely shifting the burden to that person. In addition, I am reluctant to supply private information about myself (passport number for example) to unknown individuals to supply this information for me due to identity theft concerns. Second, you are proposing to require additional information about the flight 60 minutes before departing. When you file a flight plan, in most cases you can not pick up the flight plan before 30 minutes before departure and in most cases you are sitting in the aircraft ready to depart. In addition, the flight plan is time limited. How then will you be able to provide a transponder code and file it electronically while sitting in your aircraft? This makes no sense and just confirms the information you are requesting is not needed for small aircraft with 4 seats and less. In these aircraft, the passengers are already known by the pilot. If for example my wife and I decide to go to Montreal for a long weekend, the amount of information required to return is not needed and ridiculous in my opinion. This would also require me to bring along a Laptop computer to fulfill your electronic filling requirements. That will only work if I can get access to the internet which is tenuous at best. I also dispute your financial analysis of the costs involved with complying with these requirements. If I must pay an additional amount for internet access for each time that I must file, it will add to the financial costs. Overall, I find this proposed rule unneeded and costly and an additional burden placed upon Pilots and owners of small aircraft that can least afford it when the same requirements are not being considered for small cars crossing the borders. In my view cars and trucks are where most terrorists attempting to come across our borders will succeed