ADI Files BIS Comment

Today, March 5th, we filed our comment in response to the Bureau of Industry and Security’s Notice of Proposed Rulemaking regarding the Information and Communications Technology and Services (ICTS) vulnerabilities in drones. Our comment focused on the specific ICTS components identified by BIS, offering a prioritized risk assessment framework based on the potential for exploitation and impact on national security, particularly within the agricultural sector. ADI proposed a tiered approach to regulation, distinguishing between high-risk components (e.g., ground control stations and mission planning software) and lower-risk components (e.g., sensors and motors) where possible, allowing a more gradual transition to maintain cost competitiveness. We also highlighted the unique vulnerabilities associated with third-party mission planning software, the need to pay particular attention to regulating battery technology, which is far more challenging to shift out of China compared to other goods, and the emergent threat of Chinese drone companies re-badging as American through shell-companies.