A bill with unintended consequences.
The Drone Service Providers Alliance strongly supports domestic manufacturing of UAS, and believes that there should be strong cybersecurity protections for UAS. However, we think a country of origin ban is ill advised.
First, we think it is a poor use of taxpayer resources. It makes agencies and contractors pay more for less capable drones. We should encourage innovation by incentivizing domestic production, not banning procurement or contracting based upon country of manufacture.
Second, just about every single drone manufactured domestically has components manufactured in China. Everything from batteries to PCB boards, electronic speed controllers, motors, and wiring are manufactured overseas. It’s just about impossible to find non-Chinese made components in this sector. Working with a small manufacturer, we had to have discussions about whether it would be ok to have batteries manufactured in China for their drones. We had to talk about whether it would be ok for them to ship printed circuit boards to China and have them assembled with lithium polymer cells that are made in that country. While the policy seems simple, its implementation will be a nightmare for manufacturers.
Third, cybersecurity can be managed through standards bodies and robust testing. US companies and standards bodies understand tech far better than the United States Government. The Aerospace Industries Association as well as the Consumer Technology Association are already working on security standards. Relevant NIST standards may already be applicable.
Fourth, drone businesses will be impacted. For example, if the United States Forest Service or National Parks wanted to contract with a service provider to create a promotional video they couldn’t use any DJI drones. They’d have to purchase Blue sUAS drones that still have Chinese made components but have inferior cameras that can’t compete with a system like the DJI Inspire 2 with X7. It is hard to understand how taking beauty shots of our amazing countryside impacts national security. To us, we believe in using the best tool for a job.
Finally, any prohibition on the use of federal funds could impact small and medium sized businesses that received federal funds. Our interpretation is that it could impact companies that receive SBA grants or other grants impacting operations that have no impact on national security. We believe there are better ways to address the concerns around security and national competitiveness.
We suggest that any restrictions be narrowly tailored to those operations that require higher levels of security. Restrictions should be based upon sensitivity of operations. For example, flying over a forest to take beauty shots should not require a high level of security while operations at Quantico should require a very high level of security. It is all about context appropriate levels of security and validation.
We suggest that UAS that have been validated by a third party to meet an agency’s cybersecurity requirements for its intended use should be exempted from the act. This will allow lower levels of security for operations that are for non-Department of Defense and non-intelligence community operations. We also believe that these requirements should be developed in conjunction with industry standards bodies that have the specific domain expertise.
