The FCC asked the public a set of questions about its proposed drone ban, and almost 4,000 of you answered them. We analyzed every single one of those comments. All of them. Every PDF, every scanned letter, every attachment. And here is a number that should stop everyone at the Commission cold: 1,701 filings talked about the economic impact of this rule. One agreed with the FCC. Just one.
Why I Am Saying 1,701 and Not 3,824
Before I go further, let me handle the obvious question. There were 3,824 comments. So why am I saying 1,701?
Because most comments are short, and most people write about just one thing. A sheriff’s office might write about a missing person it was searching for and never mention the economy. A farmer writes about spraying and never mentions the legal authority question. So when we scored this record, if a filing did not address a question, we marked it as not addressed. We did not guess. We did not put words in anybody’s mouth.
That means every question has its own denominator. 1,584 filings engaged on the definition. 1,701 engaged on the economics. 1,055 engaged on the security case. 443 engaged on the timeline. I could have used 3,824 for everything and gotten bigger, splashier percentages, but that would have been dishonest. That is not how we operate.
So when I say 1,701 to one, I mean 1,701 people chose to answer the FCC’s economic question, and exactly one of them agreed with the FCC.
What the FCC Actually Proposed, and What “Military-Grade” Means
If you are new to this, here is the short version. Back in July, the FCC proposed to ban the import and sale of certain foreign-made drones, mostly Chinese, and the stated reason is national security.
The rule targets what the FCC calls military-grade aircraft. If I say military-grade drone, you are probably picturing something with a missile on it. That is not how the FCC looks at it. Here is how the FCC defines military-grade: any covered drone that has a thermal camera, or a lidar sensor, or that uses a dock station, or can spray, or weighs 55 pounds or more on takeoff, or can be used as a swarm — think light show. Every drone capable of any of that is a military-grade drone.
Read that again. A thermal camera. A roof inspector uses a thermal camera every single day, and a search and rescue volunteer flies one on a three-pound drone to find a kid who has been lost since two in the morning. A lidar sensor. Your phone has a lidar sensor in it. Your car probably has one too. And most recreational drones use lidar for obstacle avoidance. Under this proposal, all of that becomes military-grade.
The comment period closed on September 2, and a lot of you filed to tell the FCC what you think of it.
What We Did With the Docket
I want to be direct about why we did this. When an agency puts out a proposal like this, it is supposed to read the record and weigh what people told it. That is the entire point of having a comment period. The FCC says it is going to do that. We decided not to wait.
We pulled every filing in the docket. There were 3,829 comments, and 3,824 of them had readable text. 686 had attachments — PDFs, Word documents, PowerPoints, spreadsheets. Then we scored every single one against the 11 questions the FCC actually asked. Not the questions we wish they had asked. The 11 questions in the public notice.
Then we published all of it: the full analysis, the method, and the raw data as a spreadsheet, one row per filing with a link back to the original FCC record. And I want to be clear about something. You do not have to trust us on this. Every number I am about to give you is verifiable, and every quote is matched word for word against the filed document. If a quote did not match exactly, we threw it out instead of paraphrasing it. Go check the work yourself if you doubt any of the data.
The Headline: 98.6% Oppose the Rule as Written
98.6% of filings oppose the rule as written. Breaking that down, 77% oppose it outright. Another 21% say they support the security goal but still reject how the FCC has drawn it.
Sixteen filings support the proposal as written, out of 3,824. That is 0.4%.
Let me get ahead of the obvious objection, because someone at the Commission will probably make it. Was this a campaign? Did somebody organize a form-letter blast? We checked. About 5.7% of the filings used template language, 218 of them, and that was mostly a letter from the Academy of Model Aeronautics about the 55-pound threshold. Which means 94% of the record is people sitting down and writing their own words about their own business.
Number one, that is awesome. Number two, this is an industry telling a federal agency that it got something wrong.
Question One: 99.4% Say the Definition Is Too Broad
The FCC’s first question was whether its list actually captures military-grade drones. 1,584 filings engaged on that question, and 1,575 said the definition is too broad. That is 99.4%. Five said it was fine. Four said it was too narrow.
Of those, 1,148 filings, or 72%, make the same very specific point: thermal and lidar are ordinary commercial sensors, and they are not weapons.
Here is the Ohio chapter of the Law Enforcement Drone Association: thermal imaging, lidar, autonomous flight and docking capabilities are all dual-use technologies employed every single day for lawful, life-saving and distinctly non-military purposes.
Here is Autel — and yes, I know Autel is a Chinese manufacturer, and no, that does not make the sentence wrong: “A 55-pound aircraft is not military because of its weight.”
And here is the Boulder Emergency Squad, a volunteer search and rescue team: a thermal sensor on a three-pound aircraft flown by volunteers on a sheriff’s callout is not a military capability.
990 filings, 62.5%, did not just complain. They proposed a fix — write the definition around what actually makes something military: weaponization, electronic warfare, targeting, hostile autonomous swarming. The industry handed the FCC a better rule, in writing, 990 times.
Question Two: The Security Case Does Not Hold Up in the Record
The FCC’s second question asked whether this equipment poses a notable, acute national security risk. 1,055 filings addressed it. Thirty, or 2.8%, agreed the risk is acute the way the FCC describes it. 727 filings, 69%, said the risk is overstated. 298, or 28%, said it is real but manageable with the tools we already have.
And 415 filings, 39%, make the point that there is no documented case on the record of any of this equipment being exploited the way the proposal implies.
Then there is the legal problem. 176 filings, 16%, question whether the FCC even has the authority to do any of this, and that includes DJI itself. DJI argues that the underlying determination never mentions the phrase military-grade and never mentions any of the seven categories the FCC built on top of it.
You might be frowning, because DJI is an interested party, so of course they say what they say. But then you have the Commercial Drone Alliance, which represents American manufacturers and is asking for an even stricter ban than the FCC proposed. And the National Sheriffs’ Association. And the Edison Electric Institute, the American Petroleum Institute, rural electric co-ops — all making the same point. At some point the argument stops being about who is making it.
Question Three: The Money, and the One Filing That Agreed
Now the part that matters most. The FCC’s tentative conclusion, in its own words, was that the economic impact would be relatively minor and contained.
1,701 filings addressed economic impact. 1,686 described severe harm. That is 99.1%. One agreed with the Commission.
Let me put a face on what severe means here, because this is not abstract. 24% of those filings put an actual dollar figure on the record, and the median is $16,000.
Sixteen thousand dollars. That number tells you exactly who is filing in this docket. These are not corporations with legal departments. These are one-truck, one-drone, one-person businesses.
Here is Phoenix Drone Pros: replacing my fleet with a domestic alternative that I have priced would cost roughly $200,000, which is 200% of my annual revenue. That is not a cost increase. That is a closing sale.
988 filings, 58%, said there is no domestic alternative for the work they do. 502 filings, 29%, said the American equivalent costs substantially more. We already knew that. It is not a surprise. As one operator put it, DJI drones are not a luxury for small operators — they are the only affordable, reliable and technologically advanced tool available in the United States market today.
And then there is the part I think is genuinely unfair. 653 filings, 38%, point out that they bought this equipment legally, under FCC authorizations that were valid at the time. As one filer wrote, retroactively revoking that authorization does not just block future purchases, it undermines the basis on which we built a business in the first place.
We also filed our own comment in the docket, based on our survey of 8,056 operators. 96.7% of them rely on the equipment this rule would capture, and 76.6% expect significant or business-ending impact.
Business-ending impact. The FCC said this would be minor and contained. The record says otherwise, 1,700 times over.
Public Safety: 513 Filings Say This Rule Will Cost Lives
298 public safety agencies filed in this docket. Police departments, fire departments, search and rescue teams, emergency management. Every single one of them that engaged on the definition called it too broad. Every single one.
598 filings were about search and rescue and firefighting, and 513 of them said the rule is going to cost lives. I am not saying that. They are saying it.
Here is what it sounds like. The Lincoln County Sheriff’s Office: we recently completed a search and rescue for a missing autistic person who had been missing for five hours, and we located him with our drone and brought him back safely to his family. A volunteer search and rescue team: a ban on these DJI drones and their maintenance parts would end our search and rescue team. The Blair Police Department in Nebraska: for a 22-officer municipal police department, it can be the difference between having a drone program and not having one at all.
The National Sheriffs’ Association filed on behalf of its member sheriffs, and the ask was modest. Let us keep what we already own. Confirm that the American alternatives actually work. And if you cannot confirm that, give state and local law enforcement the same carve-out you are giving federal agencies.
Because here is a detail a lot of people missed. The proposal exempts equipment for federal government use, but it does not exempt your county sheriff’s office. Same mission, same missing kid, different patch on the shoulder, different drone they are allowed to use.
Agriculture: A Circular Definition That Captures Ag Aircraft by Construction
We had 175 agricultural filings, which is a lot considering the size of that field. The FCC’s spray criterion is drawn from the FAA’s agricultural aircraft rule, which means that by construction, it captures agricultural aircraft.
As one commenter put it, a spray drone is not a chemical weapon merely because it applies pesticides. 561 filings tie this directly to crop yield and food supply. Spray drones let a farmer treat a field that is too wet for a tractor. They cut chemical use, and they replace low-altitude manned crop dusting, which is one of the most dangerous flying jobs in the country.
The repair problem hits agriculture hardest, because a season does not wait. As one ag operator wrote, an aircraft that cannot be repaired is an aircraft that cannot fly, which amounts to a practical ban on equipment already in service.
And frankly, this one is worse than badly drawn. It is circular. The FCC borrowed its definition from the FAA’s rule on dispensing economic poison — the rule that governs agricultural aircraft. So a test built for ag aircraft captures ag aircraft. That looks a lot like it was done by design.
Here is what it costs you. A spray drone flies when the ground rig cannot. The field is too wet for the tractor. The corn is too tall for the ground sprayer. And that is the exact moment fungicide needs to go on — on hillside orchards, on rice, on whatever it is. Every one of these jobs has a clock on it. Crop protection has to happen inside a narrow window set by weather and disease pressure, not by a compliance timeline. Miss it, and you cannot reschedule. You lose the yield.
That is why the repair issue lands harder here than anywhere else in the docket. A season does not wait for parts that are backlogged or unavailable. An aircraft that cannot fly in July is an aircraft you do not have that year.
And the spray criterion reaches well past farming. The American Mosquito Control Association filed, because public health mosquito abatement is spray work too. Under this definition, the drone your county uses to knock down the mosquito population is military-grade.
Mapping, Survey, Energy, Film: This Is Not a Niche
Lidar is the mapping industry: surveying, construction progress, stockpile volumes, utility corridors, crash reconstruction for law enforcement. One firm put it this way — this is not a minor cost increase, it is a barrier that would prevent many small firms from bidding competitively, serving customers and operating safely.
317 filings came from infrastructure inspection and the energy sector, and that one was filed as a block: the Edison Electric Institute, the American Petroleum Institute, the American Chemistry Council, rural electric co-ops and natural gas associations.
Then 215 filings from film and media. 766 filings from hobby and recreational flying, with the AMA filing for 150,000 members, mostly over the 55-pound threshold. New York’s MTA filed. Universities filed. A tribal environmental program filed. This is not a niche.
The Other Side: All Sixteen Filings That Backed the Ban
Let me talk about who supported this, because I said we would name them, and I mean it. Sixteen filings support the prohibition as proposed.
The Foundation for Defense of Democracies, a national security think tank, wrote the longest argument on that side. Their case is that heavy-lift, sensor-loaded, long-endurance aircraft are the same class of machine currently flying in combat, and that when an adversary state builds them, the dual-use question resolves against the buyer. They cite Ukraine using Mavic 3 thermals for reconnaissance. That may sound like a real argument, but they fail to mention that the same drone, built in a different country by a different manufacturer, can be used in exactly the same way.
Then there is the Agricultural Drone Initiative, an American ag-drone manufacturer consortium, which argues that Chinese software control over spray aircraft is a food security risk and that Chinese dumping has already killed two American ag-drone companies. They are the only trade group on that side of the docket.
Then two venture capital firms, and a domestic drone manufacturer working in spatial intelligence. And Skydio filed too — and I want to be precise here, to be fair. Skydio filed an ex parte notice, not a full endorsement, and what it actually asked for was careful, calibrated measures with reasonable transition periods. So even Skydio is asking for a longer runway.
That is against 1,686 filings saying this will do severe economic damage. I am not saying those 16 filings are illegitimate. Some are thoughtful, and the Agricultural Drone Initiative makes a real point about a rebranding loophole the FCC should absolutely fix. But 16 is 16. An agency that reads this record and adopts the rule as written is not weighing evidence. It is ignoring it.
To the Commission: You Asked, and 1,584 People Answered
If somebody from the Commission is watching this, and I hope you are, I want to say this plainly and without any heat.
You asked whether the economic impact would be minor and contained. 1,701 people answered. One agreed with you. You asked whether your definition captures military-grade equipment. 1,584 people answered. 1,575 said no.
And you denied three requests to extend this comment period. Then 28% of the record showed up in the last three days anyway, because people were scrambling to be heard.
The industry is not asking you to do nothing. 990 filings landed with a narrower definition. 358 asked for a phased transition. 225 asked you to protect equipment people already own, along with the parts that keep it flying. That is a serious industry trying to help you write a better rule.
If this goes through as written, the thing that fails first is not a Chinese company. It is the two-person mapping business in Ohio. It is the volunteer search and rescue team in Maine. It is the sheriff’s office in Nebraska with 22 officers. You can fix this, and the record tells you exactly how.
What Your Comment Did, and Why This May End Up in Court
Last thing, and this is for the people who actually filed. A lot of you left a comment because we asked you to, or because somebody in the community asked you to. And I know a fair number of you figured it would disappear into the void. It did not. Your comment is in the permanent public record of this proceeding. It has a docket number, and it is cited in our analysis.
I think there is a real chance this ends up in court, and here is why.
First, 176 filings argue that the FCC does not have the legal authority to do this, and that is not a fringe position in this record.
Second, DJI and Autel both built that argument in detail, with citations. DJI’s position is that the statute requires the Commission to make a specific determination about a company or a product, and that a blanket rule based on where something was built does not meet that bar. They also point out that the underlying national security determination never uses the phrase military-grade and never lists the seven categories in this document. When a manufacturer files something that reads like an appellate brief, it is usually because one is coming.
Third, there is a procedural argument. This went out as a public notice inside an existing docket rather than as a full rulemaking, and commenters have already raised that under the Administrative Procedure Act. They also raised the fact that the rule exempts federal agencies but not the county sheriff’s office. Treating two identical drones differently based on who is holding the controller is the kind of thing a court looks at very closely.
I am not a lawyer, and I am not predicting an outcome. What I am telling you is that the groundwork for a challenge is already in the record. And if that happens, this record is the evidence. 1,686 filings describing severe economic harm did not exist before you sat down and wrote one. You made that happen.
Everything is in the analysis: question by question, 202 quotes word for word, all 341 organizations and where they landed, plus the raw spreadsheet so you can check every number I just gave you. DroneXL has also published its own count of the coded record. Thanks for filing.
This article is based on a video from our YouTube partner Greg Reverdiau. Watch the full video on the Pilot Institute YouTube channel, and find more of Greg’s work on his DroneXL author page.
