Comment Submitted by Robert C. Newman

I am categorically opposed to this burdensome regulation and the impact it imposes upon my freedom. Never before has the Federal government had the authority to require its permission if I should chose to depart the US by private transportation. All requirements applicable to departure should be removed. The arrival process is impractical, and onerous. The form requires the pilot to repeat information readily available from the aircraft registry database and already included on the required International Flight Plan. If DHS is to require a manifest, why not just have pilots add the passenger list in the comments section of the flight plan? Numerous foreign airports frequented by private pilots such as the Bahamas and Mexico, there are no practical communications facilities available to relay this information and receive a reply from DHS. This is glossed over in the proposal. If only voice communication such as a pay phone is available, I cannot file this form, nor can I receive a reply. The information collected is essentially the same information collected on the international flight plan and by Customs at the entry point today. Requiring an additional separate "permission form" prior to flight serves no purpose. It adds no security. It simply impacts law abiding citizens. None of the information supplied can be verified as complete; a pilot can simple leave anyone they care to off the list. The existing system where Customs verifies the credentials upon landing works. There is no known scenario in private transporation where having the proposed UNVERIFIED advance information would avoid an entry breach or other undesired act. The regulation is nothing more than window dressing that attempts to emulate the new manifest requirements applied to airlines. That scenario cannot be compared to this. Operators of small private planes know their passengers and therefore are inherently secure. Airlines know nothing about their passengers, thus greater scrutiny is appropriate. The place for all required information prior to flight is the internal Flight Plan. A comments section on it can be used for communicating a passenger list. Another form and another communication channel just for DHS makes no sense. DHS can review the flight plan submissions electronically. Last, the proposal has no details about what happens if the DHS computer does not approve somebody on my passenger list. Am I suppose to be stuck in the Bahamas forever or for weeks while I hire a lawyer to contact DHS and find a solution? I don't think so. This proposal is full of unintended consequences that will without a doubt result in a hugely embarrassing public outcry against DHS if it is implemented. Thank you for the opportunity to comment upon this bold faced slam upon my freedom as a US citizen.