08/29/2026
It is vitally important that all drone enthusiasts, entrepreneurs, and public safety professionals who utilize foreign-made drones submit an official comment before September 2, 2026, to the FCC in response to PS Docket 26-189 which is a proposed restriction on the importation and sale of foreign-made drones, specifically any DJI drone the FCC seeks to classify as "military grade" due simply to having thermal or LiDAR capability. Below is our official comment submitted on behalf of our customers and the entire drone community. Linked to this post is a video with instructions in the comments on how to submit a response to the FCC. https://www.youtube.com/watch?v=2cls5MHfi38
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August 28, 2026
Federal Communications Commission
45 L Street NE
Washington, DC 20554
Re: PS Docket No. 26-189 — Opposition to Proposed Restrictions on Previously Authorized Foreign-Produced UAS and the Overbroad Classification of Civilian Thermal and LiDAR Drones as “Military-Grade”
To the Commissioners and Staff of the Federal Communications Commission:
I respectfully submit these comments in opposition to the proposed prohibition on the continued importation and marketing of previously authorized foreign-produced unmanned aircraft systems merely because they incorporate thermal imaging, LiDAR, or other technologies that may have potential military applications.
I write not only as a member of the drone industry, but as a small business owner and authorized DJI dealer whose livelihood, customers, and community are directly affected by federal drone policy.
I fully recognize and support the federal government's responsibility to protect the national security of the United States. Legitimate security vulnerabilities should be identified, evaluated, and addressed. However, national-security policy should be based on demonstrable risk and the design and intended function of a product—not simply on whether a commercially available technology could theoretically have a military use.
The proposed definition of "military-grade" is therefore deeply concerning.
Thermal and LiDAR Sensors Are Civilian Technologies, Not Evidence of a Military
Under the proposal in PS Docket No. 26-189, a drone may be considered "military-grade" because it contains thermal imaging capability or LiDAR. Yet neither technology is inherently military.
Thermal cameras are routinely used by firefighters to locate hotspots in burning structures and wildfires. Police departments use them to locate missing persons, fleeing suspects, and people in dangerous environments without unnecessarily placing officers at risk. Search-and-rescue organizations use thermal-equipped drones to find lost hikers and vulnerable individuals at night or in difficult terrain.
Outside government, thermal drones have created entirely new American small-business industries. Entrepreneurs use them for deer recovery, lost-pet searches, wildlife management, roof inspections, solar-panel inspections, electrical inspections, industrial maintenance, agricultural applications, and countless other legitimate purposes.
LiDAR is similarly fundamental to civilian industry. Surveyors, engineers, construction companies, utilities, forestry professionals, infrastructure inspectors, environmental scientists, and mapping companies use LiDAR-equipped drones to create accurate three-dimensional models, measure terrain, inspect infrastructure, map vegetation, document construction progress, and gather data far more safely and efficiently than was previously possible.
The FCC's Public Notice itself identifies thermal imaging and LiDAR as criteria that could cause an aircraft to be characterized as "military-grade." But the fact that a technology has usefulness in a military environment does not transform every civilian product incorporating that technology into military equipment. Many technologies have dual-use applications. The appropriate question should be how a product is designed, marketed, configured, and intended to be used—not whether one of its sensors could conceivably provide information useful in a military context.
DJI has publicly stated that its products are manufactured for civilian use, that it does not market or sell its products for military use, and that it opposes the weaponization of its products. Commercial DJI aircraft are sold openly to photographers, hobbyists, construction firms, farmers, surveyors, first responders, small businesses, and other civilian customers—not as weapons platforms.
Calling an enterprise drone "military-grade" solely because it can see heat or collect three-dimensional spatial data creates a dangerously broad standard.
American Police, Fire, and Search-and-Rescue Agencies Depend on DJI
Perhaps nowhere are the consequences of this classification more serious than in public safety.
Police departments, sheriff's offices, fire departments, emergency-management agencies, and search-and-rescue organizations across the United States have invested heavily in DJI technology. These aircraft provide thermal imaging, high-resolution zoom cameras, mapping capabilities, long flight times, reliable transmission systems, obstacle avoidance, and mature software ecosystems at prices that local agencies can realistically afford.
For a firefighter searching for hotspots in a burning building or wildfire, thermal imaging is not a "military-grade" feature. It is a life-safety tool.
For a search-and-rescue team trying to locate a missing child or lost hiker after dark, thermal imaging is not a weapon. It may be the difference between finding that person alive and finding them too late.
For a police department documenting a major accident, searching dangerous terrain, or providing officers with situational awareness during an emergency, a drone can reduce risk to officers and civilians alike.
Many smaller public-safety agencies simply do not have the budgets to replace their DJI fleets with significantly more expensive American-made systems. Domestic alternatives exist and should continue to be developed, but in many cases they do not yet provide the same combination of price, camera performance, flight endurance, payload flexibility, mapping capability, accessories, software maturity, product availability, and overall ecosystem offered by DJI.
A theoretically available replacement is not a meaningful replacement if a small police or fire department cannot afford to purchase it.
This Proposal Would Harm American Small Businesses
The consequences also extend far beyond drone manufacturers.
I am a DJI dealer and a small business owner. Businesses like mine have invested years building customer relationships, technical knowledge, inventory, marketing, support capabilities, and infrastructure around a legitimate civilian industry.
We sell products to hobbyists, photographers, contractors, entrepreneurs, public-safety organizations, commercial pilots, mapping professionals, and many other customers who use drones productively every day.
If previously authorized DJI products are suddenly prohibited from importation and sale, the financial consequences will not fall primarily on a foreign manufacturer. They will also fall on American dealers, distributors, service companies, educators, pilots, and other small businesses.
Many DJI dealers are not massive corporations capable of simply shifting into another industry. They are small, family-owned companies. They employ Americans, rent American commercial space, pay American taxes, advertise through American businesses, purchase services from American vendors, and support local customers.
For many of these businesses, DJI represents a substantial part of their product offering because DJI represents a substantial part of the civilian drone market.
Eliminating access to those products without a commercially viable replacement could force businesses to reduce staff, discontinue drone operations, or close entirely.
Federal policy intended to strengthen American industry should not inadvertently destroy American small businesses that have spent years building legitimate businesses around products that were lawfully authorized for sale in the United States.
DJI's Market Position Cannot Simply Be Replaced Through Regulation
DJI's position in the civilian drone industry is unlike that of an ordinary electronics manufacturer.
Industry analysis has placed DJI at roughly 80 percent of the U.S. commercial drone market and above 90 percent of the global consumer drone market. DJI did not literally invent unmanned aircraft, but the company played an extraordinary role in pioneering, popularizing, and defining the modern ready-to-fly civilian camera-drone industry.
That market position was earned by developing products that combined reliability, sophisticated flight-control technology, cameras, obstacle sensing, transmission systems, software, portability, and affordability in a way competitors struggled to match.
Removing a company with that level of market pe*******on does not automatically create an American competitor capable of replacing it.
It creates a vacuum.
There Is No Comparable American Consumer-Drone Ecosystem
The problem is particularly severe for consumers and prosumers.
Products such as the DJI Mini series, Air series, and Mavic series occupy price and capability categories for which there is presently no true American-made equivalent.
The DJI Mini 5 Pro, Air 3S, and Mavic 4 Pro illustrate the enormous range of civilian users who would be affected—from families and hobbyists purchasing their first quality camera drone to professional photographers, videographers, real-estate professionals, inspectors, and small commercial operators.
American drone companies have already demonstrated how difficult the consumer market is. Skydio, once the most prominent American consumer-drone competitor, discontinued its consumer business in 2023 to concentrate on enterprise and public-sector customers. Other American companies have similarly exited or redirected their efforts away from the mass consumer market.
That history matters.
There is little evidence that prohibiting DJI products will suddenly result in a U.S. manufacturer producing a $700, $1,000, or $2,000 camera drone with comparable performance at comparable scale.
American companies have rational economic incentives to pursue government, defense, and high-value enterprise contracts where margins can be substantially higher. Developing a sophisticated mass-market consumer aircraft, manufacturing it at scale, establishing a repair and distribution network, maintaining apps and firmware, and selling it at consumer prices is an entirely different business proposition.
If an American-made "replacement" costs several times more than the product it replaces, it is not a replacement for the average consumer.
The result would not necessarily be American drone dominance. It could simply mean that American consumers lose access to advanced drone technology.
Enterprise Alternatives Must Reach Genuine Price and Capability Parity
I strongly support the development of a competitive American drone-manufacturing industry.
This should not be viewed as an argument against companies such as Skydio, BRINC, Freefly, Inspired Flight, or other American manufacturers. Their continued development is important to the United States.
But industrial policy should build domestic capability rather than attempting to manufacture competitiveness by prematurely removing the products against which American companies are competing.
For many commercial operators, the relevant question is not whether an American drone exists. The question is whether an American drone can perform the same mission, with similar reliability, sensors, endurance, payloads, software integration, support, and workflow, at a price the customer can realistically afford.
Today, that answer is often no.
A mapping contractor cannot simply absorb tens of thousands of dollars in additional equipment cost.
A volunteer search-and-rescue organization cannot manufacture additional funding.
A small rural fire department cannot spend money it does not have.
A one-person deer-recovery business cannot necessarily replace a several-thousand-dollar thermal aircraft with a dramatically more expensive enterprise platform.
A small surveying or inspection company cannot remain competitive if regulatory action suddenly multiplies its equipment costs.
American alternatives should be given the opportunity and incentives to reach technological and economic parity. But restricting DJI before that happens risks harming the very American businesses, first responders, contractors, and entrepreneurs federal policy should be helping.
Any Transition Should Follow Domestic Capability—Not Precede It
If the federal government ultimately determines that additional restrictions on foreign-produced drones are necessary, those restrictions should not occur until domestic or trusted-market replacements exist in sufficient quantity and at reasonably comparable levels of capability and cost.
Before restricting previously authorized civilian aircraft, the government should evaluate whether replacement products provide meaningful parity in areas including:
flight endurance; thermal-imaging capability; optical zoom; LiDAR and mapping compatibility; RTK positioning; obstacle avoidance; payload flexibility; transmission range and reliability; autonomous flight; mapping and fleet-management software; repair and parts availability; supply capacity; and total cost of ownership.
Until alternatives meet those practical requirements, a prohibition is not a transition strategy. It is a forced technology gap.
Public-safety agencies and American businesses should not be required to sacrifice capability while waiting for the domestic industry to catch up.
National Security Can Be Addressed More Precisely
The Commission can protect legitimate national-security interests without categorizing ordinary civilian technology as military equipment.
Restrictions can be tailored toward aircraft actually designed for military missions, weaponization, specialized military payloads, combat-specific communications, purpose-built autonomous attack capabilities, or other objectively military characteristics.
Likewise, if particular models present demonstrable cybersecurity or data-security concerns, those concerns should be evaluated on a product-specific and evidence-based basis as a formal review of the product.
Independent security testing, restrictions involving sensitive federal facilities, cybersecurity standards, network-security requirements, conditional approvals, data-localization requirements, and other targeted approaches can address specific risks without eliminating entire classes of valuable civilian aircraft.
A thermal camera should not be enough to convert a firefighter's drone into military equipment.
A LiDAR scanner should not be enough to convert a surveyor's drone into military equipment.
And the hypothetical possibility that a civilian product could be misused should not automatically justify eliminating lawful access to that product for millions of Americans who use it responsibly.
Requested Action
I respectfully request that the Commission revise the proposed approach in PS Docket No. 26-189 and:
1. Remove thermal-imaging capability, standing alone, as a basis for classifying a UAS as "military-grade."
2. Remove LiDAR capability, standing alone, as a basis for classifying a UAS as "military-grade."
3. Differentiate civilian and commercial aircraft from platforms specifically designed, configured, marketed, or intended for military or weapons applications.
4. Preserve the continued importation and marketing of previously authorized civilian DJI products unless a specific, product-level security risk is demonstrated.
5. Conduct a meaningful economic-impact analysis addressing U.S. small businesses, drone dealers, commercial operators, public-safety agencies, and other affected users before implementing additional restrictions.
6. Require an assessment of available domestic replacement capability, pricing, production capacity, and feature parity before restricting products relied upon by public-safety and commercial users.
7. Provide a meaningful transition period tied to actual domestic-market capability rather than an arbitrary regulatory deadline if additional restrictions are ultimately adopted.
8. Continue encouraging American drone manufacturing through investment, innovation, research, procurement opportunities, and competition rather than attempting to create a domestic market by eliminating products before viable substitutes exist.
National security and American innovation are not mutually exclusive objectives.
The United States should absolutely build a stronger domestic drone industry. We should want American companies to produce the world's best drones and compete successfully on performance, innovation, reliability, and price.
But we should not confuse removing competition with creating competitiveness.
Nor should we redefine ordinary civilian technologies such as thermal imaging and LiDAR as "military-grade" simply because those technologies have potential military applications.
DJI drones have become tools of photographers, firefighters, police officers, search-and-rescue teams, surveyors, farmers, inspectors, contractors, small businesses, hobbyists, and entrepreneurs throughout the United States. Sweeping restrictions on these aircraft would have immediate consequences for Americans who have done nothing more than purchase, sell, and rely upon lawful civilian technology.
I urge the Commission to adopt a narrower, evidence-based approach that protects national security while preserving access to essential civilian drone technology, protecting American small businesses, supporting first responders, and allowing sufficient time for the domestic drone industry to develop truly competitive alternatives.
Thank you for considering these comments and for allowing affected small businesses and members of the U.S. drone community to participate in this proceeding.
Respectfully submitted,
Garret Hultgren
Owner, Altitude Hobbies
Sorry, I tried to make this short, but this is too important to ski...
