The Federal Communications Commission received 3,829 comments on its proposal to bar the import and sale of foreign-made drones that carry thermal sensors, LiDAR, docking stations or spray equipment, or that weigh 55 pounds or more, and 16 of them support the plan as written. Pilot Institute read every filing in PS Docket 26-189, including 686 attachments and 22 scanned letters run through OCR, and coded each one against the same rubric. Of the 3,824 with readable text, 3,770 oppose the prohibition as proposed. That is 98.6%.

The record closed at midnight Eastern on September 2. More than a quarter of it, 1,064 filings, arrived in the final three days, after the Public Safety and Homeland Security Bureau refused to extend the deadline. The sixteen supporters include one trade group, two venture investors, a think tank and a handful of domestic manufacturers that compete with the aircraft it targets.

I have covered this docket since the Bureau opened it on July 21, and DroneXL’s own comments are one of the 3,824 filings in the dataset. Pilot Institute has now published the whole coded record as a free, filterable page where anyone can sort the filings by sector and position, and pull the original from the FCC’s system by docket ID.

Pilot Institute Coded Every Filing In Docket 26-189

Pilot Institute exported the complete docket from the FCC’s comment system and coded each filing for position, filer type, an answer to each of the Bureau’s five question clusters, and up to eight arguments from a closed list of 45. Questions a filing skipped were marked not addressed, never inferred.

That last decision matters for reading the numbers. Most filers answered only the one or two questions that touched their own operation, so each question is scored against the filings that engaged it, and the denominator changes from question to question. The headline 98.6% is scored against all 3,824.

The 202 quotations on the page were string-matched against the filed documents, and any that did not match exactly were dropped. Pilot Institute filed its own comment in the docket, coded as opposing, and it appears in the organization table like every other filer. The Drone Service Providers Alliance leaned on the organization’s January survey of 8,056 operators in its own filing.

The full interactive record is at hub.pilotinstitute.com/fcc-comment-record. DroneXL promised this deeper look on Monday, when Greg Reverdiau told the Commercial UAV Expo audience that roughly 2,600 comments were on file. The final count came in nearly 50% higher.

The Definition Question Drew 1,584 Answers And Nine Defenders

The Bureau’s first question asked whether its seven capability categories adequately capture military-grade aircraft. Of the 1,584 filings that engaged the definition, 1,575 called it overbroad. Five called it adequate and four said it was too narrow. Pilot Institute scores that at 99.4%, the most lopsided answer on the docket.

The arguments cluster. According to Pilot Institute’s coding, 1,148 filings argue that thermal and LiDAR are ordinary commercial sensors, 990 ask the Commission to rewrite the definition around weaponization, electronic warfare or hostile autonomy instead of hardware, and 822 say the categories sweep in ordinary consumer aircraft. DroneXL laid out that overlap on August 16: a short-range LiDAR sensor for obstacle avoidance puts the DJI Air 3S, Mini 5 Pro, Avata 360 and Neo 2 inside the definition.

The 55-pound threshold drew 288 challenges, most of them driven by an Academy of Model Aeronautics letter on behalf of its 150,000 members. Autel Robotics put it in one sentence: “A 55-pound aircraft is not military because of its weight.” Reuters, filing as a news organization, commented only on the LiDAR category, arguing it is the one criterion with no threshold at all.

On the security question itself, 1,055 filings engaged. Thirty agreed the risk is acute as the Commission described it. Another 298 said the risk is real but can be mitigated, 727 said it is overstated, and 415 argued that no documented exploitation has been shown on the record. A further 176 questioned whether the Commission has statutory authority to do this at all, which is the core of DJI’s filing and of Autel’s.

One Filing Agreed The Economic Impact Is Minor

The Bureau tentatively concluded that the economic impact would be relatively minor and contained, and asked whether commenters agreed. It became the docket’s most-answered question. Of 1,701 filings addressing it, 1,686 described severe harm, fourteen argued the rule would produce a net economic benefit, and one agreed with the Bureau.

Direct harm to a small business is the single most common argument in the record, coded in 1,570 filings. Another 988 say no domestic aircraft can do their job, 653 say the rule strands fleets they already bought under valid authorizations, and 502 say the American equivalents cost substantially more. Pilot Institute’s own filing framed the gear at issue this way: “It is the operating base of the American civil drone economy.”

The Bureau asked for dollar figures and 406 filings supplied one. The median firm-level figure is $16,464, typically a fleet that would be grounded or the cost of replacing it. The big numbers are institutional. The American Drone Data Protection Coalition used FAA data obtained under FOIA to put the replacement cost of the 83,972 DJI drones registered in 2023 alone at an additional $1.12 billion. A public-safety filer pointed to Florida’s state-level ban as the natural experiment: roughly $200 million of working equipment grounded against $25 million in replacement funding.

Several filers also flagged the collision with the Section 232 tariffs that took effect today, which raise the price of the same thermal aircraft the FCC proposes to pull from the market. The 180-day implementation window drew 443 responses. Two called it adequate, two wanted the ban immediate, and 439 asked for a longer runway through a phase-in, grandfathering, a sell-through window or a waiver process. Volitant Technologies, which distributes the Talos T60X agricultural drone, put it plainly: “A 30-day marketing cutoff would function as an inventory forfeiture in economic substance.”

Sixteen Filers Back The Ban, And Only One Is A Trade Group

The case for the rule rests on sixteen filings. The Foundation for Defense of Democracies files the fullest defense: capability, not paperwork, is the test, and heavy-lift airframes built by an adversary state are the same class of machine now flying in combat. It wants the Commission to go further.

FDD cites the Mavic 3 Enterprise in Ukrainian reconnaissance and the Agras T100’s 386-pound takeoff weight as evidence the categories track real military function, and it wants the Commission to revisit authorizations already granted to older models.

The Agricultural Drone Initiative, a coalition of American ag-drone manufacturers and the wholesalers and farmers who buy from them, is the only trade association on that side. It frames Chinese software control over spray aircraft as a food-security risk, says PRC dumping of up to $30,000 per unit has already put two American ag-drone makers out of business, and breaks with nearly everyone else on timing: “The 180-day window strikes a sound balance.” Three domestic ag-drone companies, Ceres Air, Elevon Aerial and Exedy Drones, filed near-identical text supporting a ban on named Chinese competitors.

Craft Ventures, an investor in drone and autonomy startups, and HYFIX Spatial Intelligence argue the restriction is what makes a domestic sensor and motor supply chain financeable. Catapult Ventures filed a single sentence. Obsidian Sensors, a San Diego thermal-sensor maker, supports the rule as written and opposes any waivers. Swarm Defense Technologies backs the swarming category and proposes closing evasion loopholes.

Skydio is coded as a supporter, and Pilot Institute’s own note on that coding is worth reading. Skydio’s filing is an ex parte notice describing its SkyForge manufacturing build-out, and it urges the Commission to calibrate any measures and allow reasonable transition periods. That is closer to the opposition’s ask on timing than the label suggests (and closer to what the public-safety agencies on the docket filed).

Small Businesses And First Responders Wrote Most Of The Record

Individual remote pilots filed 1,217 comments and commercial drone-service companies filed 1,068, together nearly 60% of the docket. Public-safety agencies are the third-largest bloc at 298. Media and film account for 215, agriculture for 175, survey and construction for 119, and education for 98. Nineteen government bodies filed.

Manufacturers and dealers filed 85 comments, trade associations 38, and utilities 29. Another 256 could not be attributed to a sector.

The public-safety filings are the ones the Bureau’s own public-interest balancing has to weigh most directly, and they are not subtle. Of the 783 filings that struck the balance between security and cost explicitly, 771 said the harm outweighs the benefit and twelve said the reverse. Among them, 598 raise search-and-rescue or firefighting capability, and 513 argue the rule costs lives in emergency response. Weber County Search and Rescue’s Kyle Nordfors made that case to the FCC in writing, and his filing sits in the dataset alongside those of the New York State Police, the Law Enforcement Drone Association and 64 filers asking for the same carve-out federal agencies already have. The National Sheriffs’ Association, for 3,081 sheriffs, asked the Commission to preserve current inventories or grant a temporary state, local and tribal exemption if domestic alternatives cannot be confirmed adequate.

The 311 filings framing the proposal as protectionism for a small number of incumbents sit in this cluster too. So do the drone light-show operators, who DroneXL reported were swept in by the swarming category and who filed as a bloc through the American Drone Entertainment Coalition.

Late Filings Changed The Mix, Not The Verdict

Three parties moved to extend the comment window. The Bureau denied all three in Order DA 26-892, writing that “extensions of time shall not be routinely granted.” The denial shaped the record. September 1 was the single busiest day, and the last three days carried 28% of everything filed.

That is when the heavyweights arrived: DJI, Autel, the Commercial Drone Alliance, the National Sheriffs’ Association and a joint filing from the Edison Electric Institute, the American Petroleum Institute and five other energy and chemical trade groups. Their arrival moved one number. The share of the record that accepts the security premise while rejecting the scope rose from 17% to 21% over the final four days. Overall opposition held at 98.6%. A further 83 comments arrived after the deadline and are counted in the total.

Pilot Institute is candid about what the analysis cannot support. The line between opposing the ban outright and backing the goal while rejecting the scope is a judgment call, and coding it across 3,824 filings produced visible variance; the organization says to read the 77-to-21 split as a range rather than a measurement, while the overall opposition figure holds up. About 5.7% of filings, 218 of them, reuse template language, chiefly the AMA letter and a set of filings from employees of one drone company. And a docket is not a survey: the 98.6% measures who showed up, not what the country thinks.

DroneXL’s Take

Sixteen filings support this proposal and 3,770 oppose it. I have covered the FCC’s move against foreign drones since last fall and have not seen a record this one-sided from the people it would govern. The Bureau asked whether its economic premise held. The public answered 1,686 to one.

That is not an industry disagreeing with a regulator about degree. That is a premise with no evidentiary support left in the record that was built to test it, and the one filing that backed the premise is outnumbered by the fourteen that argued the ban would produce a net economic benefit.

I will concede the strongest point on the other side, because the record contains it. The Agricultural Drone Initiative says Chinese dumping killed two American ag-drone makers, and the domestic sensor companies filing in support are describing a real problem: you cannot finance a US thermal-core supply chain against a competitor selling below cost. DroneXL’s position has not moved: we oppose unfair competition from Beijing as firmly as we oppose protectionism from Washington. But the remedy for dumping is a dumping case, and the remedy for a data-security risk is a data-security standard applied to every manufacturer. Neither of those is a hardware ban that catches a volunteer fire department’s thermal camera and a fourteen-year-old’s Neo 2 in the same net, which is the argument I made in DroneXL’s own filing, and one that 990 other filers made in some form.

My read on the Skydio coding is that it tells you more about the politics than the label does. The company that stands to gain most from a DJI-free market filed an ex parte asking for calibration and transition time, while public-safety agencies from Perth Amboy, New Jersey, to Tualatin Valley, Oregon, filed to say the approved alternatives are beyond municipal budgets, and a dealer that sells mostly to those agencies used its own sales quotes to show a Skydio X10 costs two to four times the foreign thermal aircraft it would replace. When your prospective customers are on the docket explaining why they cannot afford you yet, you do not file a cheerful endorsement of the deadline.

What the Bureau does with this is the open question, and it is a precise one. The bureaus are acting on delegated authority, so no Commission vote is required, and nothing in the record forces them to count filings. What they cannot do is repeat “minor and contained” without engaging 1,686 filings that put dollar figures and replacement quotes on the record, because that record now exists in the docket the Bureau itself opened to build it. Whether the eventual order engages the ADDPC’s $1.12 billion figure or the National Sheriffs’ Association’s carve-out request, or restates the July premise as if September never happened, is how we will know whether this docket was a consultation or a formality.

Go read the filings yourself. Pilot Institute built the page so you can filter by your own sector and see what the people who do your job told the government. Then bookmark it, because when the order comes, the argument over what the record said will start immediately, and the record is right there.

Source: Pilot Institute, The 26-189 Comment Record

DroneXL uses automated tools to support research and source retrieval. All reporting and editorial perspectives are by Haye Kesteloo.