The FCC has proposed classifying drone light show aircraft as “military-grade” swarming UAS

Category 7 describes a technology that show drones are the opposite of

Read the two bullets in Category 7 against each other. The first describes systems where UAS operate autonomously, without human intervention, to coordinate with each other, avoid collisions, maintain formations, and dynamically respond to changes in operational or threat environments.

A drone light show does none of that:

• The flight is fully pre-programmed. Every aircraft executes a fixed, time-indexed trajectory that was computed and uploaded on the ground before takeoff.
• There is no drone-to-drone communication. The aircraft do not sense each other, talk to each other, negotiate, or make decisions.
• Collision avoidance happens in software before the show, not in the air. Minimum separation is validated at design time in the show design software. There is no in-flight autonomous deconfliction because there is no in-flight autonomy.
• Nothing responds to a threat environment. The aircraft cannot perceive an environment at all.

Functionally, a show fleet is a synchronized playback device — closer to a theatrical lighting console than to any autonomous swarm. The FCC has placed two opposite architectures under one heading and applied the threat rationale of the first to the equipment of the second.

There is no BVLOS capability in drone light show operations

This is uniform across the industry, and it is worth stating plainly on the record:

• Every drone show in the United States is flown within visual line of sight. No operator is flying shows BVLOS.
• The aircraft fly a pre-loaded show file and are monitored over a local RTK correction link and a Wi-Fi router at the launch site.
• The control link is short-range by design. Outside Wi-Fi range the aircraft loses its link and executes its failsafe: return and land. There is no long-range command and control path, no cellular or satellite link, and no ability to operate at distance from the ground station.

An aircraft that cannot leave the immediate area of its ground station without landing itself is not a platform for surveillance, standoff attack, or any of the mission profiles the Public Notice describes.

Show aircraft fail every other military-grade criterion, by design

The payload limitation is not incidental — it follows directly from the weight budget. Every gram costs flight time and formation density, so show aircraft are built as light as physically possible: an LED, a GPS/RTK receiver, a small battery, and typically 15 to 25 minutes of endurance. There is no spare lift for anything else.

The stated threat rationale describes the opposite of a light show

The Public Notice justifies Category 7 on the grounds that swarming makes UAS harder to detect, track, and counter, and that such systems can overwhelm defenses and provide persistent surveillance.

• Show drones are the most detectable aircraft in civil aviation. They are engineered to be visible for miles. That is the entire product.
• Every flight is announced in advance. Published location, published time, filed NOTAM, airspace authorization, and coordination with ATC where required.
• They cannot overwhelm anything. Payload capability is minimal because the airframes are built to be as light as possible.
• They cannot conduct persistent surveillance. Endurance is measured in minutes, and most show aircraft carry no camera at all. Where a camera is present, it is a single downward-facing sensor pointed straight at the ground, used only as a landing aid when the RTK GPS position is degraded or faulty. It does not look outward, and it is not a surveillance sensor by any reasonable definition.

This equipment has already been evaluated by the FAA for safe civil operation

Drone light shows are among the most heavily scrutinized commercial UAS operations in the country. Every operator flying a show is doing so under an approved FAA waiver that authorizes multiple aircraft from a single remote pilot.

Critically, that waiver is not just an assessment of the operator — it is an assessment of the aircraft. The FAA evaluates the specific drone model and its functionality: its flight control behavior, its failsafes, its geofencing, its lighting, its link architecture and its performance envelope. The aircraft is registered with the FAA, and the waiver authorizes us to fly that specific registered drone. The federal aviation authority has therefore already made a considered technical determination about this exact equipment, in this exact use, at the airframe level.

Add airspace authorizations, NOTAM filings, site surveys, geofencing, return-to-home failsafes, on-site safety officers, local permits, and aviation liability insurance. If you hold a waiver, cite your waiver number in your comment, and say which aircraft it covers.

An import ban does not add oversight to a vetted operator flying vetted aircraft. It removes equipment from one.

The 47 CFR § 2.903 problem: a second topic that needs its own comment

Here is the situation, in sequence:

1. The FCC adopted 47 CFR § 2.903, which prohibits granting new equipment authorizations for equipment on the FCC Covered List.
2. In December 2025, the Covered List was expanded to include foreign-produced UAS and UAS critical components, subject to the listed exceptions.
3. The combined effect: newer, upgraded, more secure foreign-produced show aircraft can no longer receive a new FCC equipment authorization.

So the industry is already frozen, independently of the import ban now being proposed. We cannot move to newer hardware with improved geofencing, improved link security, improved failsafes or improved firmware integrity, because the newer models cannot be authorized at all. We are locked onto older equipment indefinitely.

That is a worse security outcome than the one the rule is trying to produce — and the Commission has already accepted this reasoning in a related context. OET has issued and extended waivers permitting certain Class I permissive changes to covered UAS specifically so that software and firmware updates that mitigate harm to consumers can continue. The same logic applies to hardware generations.

There is no domestic alternative, and the FCC's own record shows it

The Public Notice tentatively concludes that economic and supply chain impacts would be minor, reasoning that military-grade UAS are a minority of the market and that domestic production is more prevalent in higher-end, military-grade subsectors.

That is a defensible statement about actual military drones. It is simply not true of drone light show aircraft. Look at the domestic manufacturers the FCC cites as evidence of investment filling the gap — they build delivery drones, public safety drones, and defense drones. Not one of them manufactures drone light show aircraft at production scale.

The FCC asks directly whether domestically produced alternatives exist. For our category, the honest answer today is no. If we do not say so on the record, the tentative conclusion stands.

The industry already cannot meet demand, and public policy is pushing more demand toward us

Independence Day is the clearest illustration. Demand concentrates into a single night, and the national fleet cannot come close to covering it — operators across the country turn away a large share of the shows requested of them every July, because there simply are not enough aircraft and crews in the United States to fly them. Report your own real numbers here: how many July 4th inquiries you received, and how many you were able to accept.

At the same time, public policy is deliberately steering events toward us. Cities, counties, and states across the country are restricting or banning fireworks over wildfire risk, drought, air quality, noise, wildlife impact, and veteran and pet welfare — and they are adopting drone light shows as the sanctioned, lower-risk, environmentally preferable alternative. Many municipalities made that switch in the last few seasons.

The result is a policy collision worth putting squarely in front of the Commission:

If your city or a client's city has restricted fireworks and moved to drone shows, name it and describe it. Concrete local examples are exactly the kind of public interest evidence the Commission is asking for.

Do not just oppose — ask for specific relief

Pure opposition rarely moves an agency. Give the Commission a concrete, low-cost way to fix this. We suggest asking for one or more of the following, in this order:

1. Fix the definition. Limit Category 7 to systems with genuine autonomous inter-drone coordination and dynamic threat response — that is, keep the first bullet and strike the light show sentence. This costs the Commission nothing and gives up no security.
2. Create a category exemption for entertainment UAS. There is a live precedent: on June 15, 2026, based on a national security determination from the Department of War, the FCC removed “Toy Drones,” including those containing foreign-produced components, from the Covered List. The mechanism exists and has been used recently for a category found not to present unacceptable risk.
3. Extend that exemption to equipment authorization so drone show aircraft can continue to be certified under § 2.903 — see Argument 6.
4. Grant a class-wide Conditional Approval for entertainment and light show UAS through DoW or DHS, rather than requiring every small operator to seek individual approval.
5. At minimum, extend the transition period and exempt replacement aircraft and spare components for existing, FAA-waivered operators.