13 August 2008 File: 2.1.5.3(kp08091)

Ms. Lynn Doucet

Acting Chief, Regulatory Affairs (AARBH)
Transport Canada
Place de Ville, Tower C
Ottawa, Ontario
K1A 0N8

Dear Ms. Doucet:

This letter and attachment contains COPA’s response, on behalf of 18,000 pilots and aircraft owners, to Gazette Part I for the amended regulation concerning Emergency Locator Transmitters.

Our response is in the form of specific comments against statements made in the Gazette. For clarity, we have chosen to reprint the Gazette wording in Word format and insert comments in that document.

COPA remains firmly of the belief that this regulation, which effectively mandates 406 ELTs for our sector of aviation, is unjustified. The benefit-cost analysis fails to consider some very significant details that will likely make the net benefit negative, not only in financial terms, but in lives saved.

As we have stated many times, COPA is not opposed to 406 ELTs. When they work, they are a good means to alert and locate. However, a one-size-fits-all approach in this age of technology advancements with several viable alternatives is not the way to go. Owners should be free to determine what is best for their operation.

We strongly urge you to reconsider the effective mandating of 406 ELTs. COPA has made several proposals for a more realistic approach to this issue that will maximize compliance and balance benefits and costs for all parties involved.

Yours truly,

Kevin Psutka

President and CEO