Comment from Articles In Common LLC

I oppose this proposed rule as drafted because it risks creating a broad and expanding system of drone exclusion zones without demonstrating that existing authorities are insufficient. The FAA correctly acknowledges that the National Airspace System is a public resource and that restricting access is an extraordinary remedy. However, this proposal would allow thousands of facilities across sixteen critical infrastructure sectors to seek long-term flight restrictions, potentially resulting in a patchwork of permanent no-fly zones that significantly reduce lawful access for responsible operators. The FAA already has extensive tools available, including Remote ID, aircraft registration, Part 107 certification, Temporary Flight Restrictions, and civil and criminal penalties for unlawful operations. The proposal does not provide sufficient evidence that expanding geographic restrictions will be more effective than enforcing existing laws against those who actually misuse drones. The economic impacts also deserve greater consideration. Small businesses, photographers, surveyors, infrastructure inspectors, researchers, conservation organizations, search and rescue volunteers, journalists, and recreational pilots all rely on predictable access to public airspace. Additional restrictions and permitting requirements create burdens that fall primarily on law-abiding operators, while individuals with malicious intent are unlikely to be deterred by new no-fly zones. I am also concerned about the impact this proposal could have on transparency and public accountability. Drones have become an important tool for journalists, documentary filmmakers, researchers, and watchdog organizations to document pollution, environmental damage, wildlife impacts, and conditions at industrial agriculture facilities. The public has a legitimate interest in understanding what occurs at facilities whose operations may affect surrounding communities, public health, the environment, or animal welfare. Restricting lawful aerial access around broad categories of facilities could unintentionally reduce independent oversight and make it more difficult to expose misconduct or abuse that is otherwise hidden from public view. If the FAA proceeds with this rule, applicants should be required to meet a high evidentiary standard demonstrating a specific, documented, and recurring threat that cannot reasonably be addressed through existing laws or less restrictive alternatives. Every restriction should be narrowly tailored, publicly justified, subject to periodic review, and automatically expire unless renewed based on current evidence. The National Airspace System belongs to the public. Restrictions should remain the exception, not the rule. The FAA should preserve lawful access wherever possible while focusing enforcement resources on operators who violate existing laws rather than creating increasingly broad restrictions that diminish transparency, innovation, and responsible use of public airspace.