fcc_ecfs:FCC-2026-2905-0001:26110057095

**Re: PS Docket No. 26-189** Our nonprofit organization relies on thermal drones to find lost dogs and return them safely to their families. These drones are not military equipment. They are search-and-rescue tools that allow our volunteers to locate animals at night, in remote areas and under other conditions in which conventional searches may fail. We have invested tens of thousands of dollars in our thermal drone fleet. Much of that money was donated by individuals who trusted us to use it to save lost animals. The FCC’s proposal would classify any drone equipped with thermal imaging as “military-grade,” regardless of its design, operator or intended use. That definition is far too broad. Thermal imaging is a dual-use technology. Its presence alone does not make a drone military-grade, and peaceful public-service applications should not be swept into a prohibition intended to address national security threats. Although the proposal would allow organizations to continue operating drones they already own, prohibiting the importation and marketing of these systems would still strand our investment over time. Drones, batteries, controllers, thermal cameras and other critical components wear out, become damaged and eventually require repair or replacement. Without continued access to affordable equipment, service and parts, our existing fleet would become unsustainable. Our organization does not have the resources to replace its fleet with U.S.-made equivalents that cost many times more. The practical result would be fewer searches, reduced coverage and lost dogs remaining exposed longer to traffic, severe weather, injury and death. For a small nonprofit, the loss of tens of thousands of dollars in donated equipment is not a minor economic effect. It is catastrophic. The FCC specifically asks whether its proposal would have significant economic and supply-chain consequences and whether suitable domestically produced alternatives are available. Our experience demonstrates that the consequences for nonprofit search organizations would be substantial and that cost-prohibitive alternatives are not meaningful alternatives at all. We respectfully ask the FCC to: 1. Remove thermal-imaging capability, by itself, as a basis for classifying a drone as military-grade. 2. Alternatively, establish an explicit exemption for qualified nonprofit search-and-rescue organizations, volunteer emergency-response organizations and state, local and tribal first responders. 3. Permit these exempt organizations to continue purchasing replacement aircraft, batteries, controllers, thermal cameras, repair parts and other critical components needed to maintain existing fleets. National security concerns can be addressed through narrowly tailored safeguards, including registration, restrictions on end use, cybersecurity and data-handling requirements and appropriate limitations near sensitive facilities. A blanket restriction based solely on a drone’s thermal-imaging capability would unnecessarily eliminate affordable, lifesaving technology from organizations using it solely for the public good. Thermal drones save animals’ lives. For our nonprofit, this proposal is not an abstract matter of supply-chain policy. It threatens our ability to carry out our mission and would waste tens of thousands of dollars entrusted to us by our donors. We urge the FCC to create a clear and workable exemption for nonprofit search-and-rescue organizations and first responders.