SSA responds to ANPRM

I am in the "no transponder needed" group.
Reasons why:
1. I don't trust my safety to a sleep-deprived AT controller.
2. I take responsibility for my safety via a PCAS device which does not take any system power as it has it's own battery.
3. Gliders have been flying for over 100 years, mostly without them.
4. Glider pilots look out the window much more than power pilots.
5. Hang gliders and paragliders are not considered in this ruling and they often fly XC every chance they get, staying as high as we do and traveling far.
6. Most glider flying takes place over rural areas with minimal traffic.
7. Add your contribution here! I didn't think of them all.