"john smith" wrote in message ...

The Regs allow for operation within Class B without a transponder,
working or absent. Even under the Veil!

Yes, but it requires ATC permission. I've operated in and out of Dulles with
no transponder (doubly onerous because the primary radar at the Dulles Approach
was out at the time) but we were willing to do the "at or below 1500 runway heading
until clear" number to do it.