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It's nearly impossible for the government to have detailed knowledge of every aspect of your businesses and how you operate aircraft. What's included in any regulatory proposal is an educated determination of the solution the government believes will address a specific problem. Often, there are alternatives to achieve the outcome desired by the regulator while reducing the burden on you.
Your comments should spend a little time focusing on any possible alternatives that you feel could achieve the same outcome while reducing your costs. Sometimes there simply are no alternatives that make sense. But where there are, suggesting rational alternatives that make sense and cost less often results in a final rule with reduced burden.
Alternatives should include any specifics of how it would achieve the goals defined by the proposed rule, financial details, any identified benefits and why your alternative is better for your company and the public. An alternative that costs less – for you and/or the government – than the proposed regulation is especially difficult for the agency to defend its proposed position against. Remember, an agency has to justify the costs associated with each proposed rule. Any financial information you provide that is contrary to the agency's figures or presents a more financially sound alternative is particularly valuable to the process.