SPRINT Robotics Submits Comment to FCC on UAS and UAS Critical Components

SPRINT Robotics has submitted a comment to the U.S. Federal Communications Commission (FCC) in response to Public Notice DA 26-758 concerning proposed restrictions on certain foreign-produced military-grade Uncrewed Aircraft Systems (UAS) and UAS critical components.

The comment was developed with input from the SPRINT Robotics community. In two online Input Forum sessions, representatives of approximately 35 participating companies discussed potential implications for industrial inspection and maintenance and identified practical examples and concerns. SPRINT Robotics subsequently issued a wider call for input, and the responses received were incorporated into the final submission.

SPRINT Robotics recognized the national security objectives underlying the proposed measures. Our comment focused on practical refinements intended to limit unintended consequences for U.S. industry and for the safe and effective use of robotics. The issues addressed included:

• Definition of “military-grade”: Clarifying the scope of this term to avoid unintentionally capturing commercially developed systems and components used in industrial inspection and maintenance applications.
• Replacement parts and continued operation: Ensuring that equipment already lawfully in use can continue to be maintained through access to replacement components, repair parts, and like-for-like replacement units.
• Potential implications for ground robotics: Considering the potential impact of criteria developed for UAS on ground-based robotic systems using similar sensing and other technologies.
• Conditional Approval process: Making the existing Conditional Approval pathway more accessible and predictable for industrial inspection equipment.
• Implementation timeline: Providing sufficient time for industrial users to identify, qualify, integrate, and deploy suitable alternative equipment without unnecessarily disrupting established inspection and maintenance programs.
• Economic and operational impact: Taking into account that the impact on industrial inspection and maintenance may be greater than suggested by the available economic evidence.
• Worker safety: Taking into account that robotic inspection can reduce the need for scaffolding, rope access, confined-space entry, and other work that places people in hazardous locations.

The discussions also addressed practical consequences that may remain even where they fall outside the scope of what the FCC intends to consider in this proceeding. These include impacts on equipment availability, supply chains, procurement, service delivery, and the ability to continue existing inspection and maintenance activities.

SPRINT Robotics will continue to facilitate discussion within the community on how participants can respond to these developments in practice.

Where there is interest, this may also include collaboration between participants to explore possible approaches, share experiences, and address common challenges.

An important foundation in preparing the submission this work was the knowledge base SPRINT Robotics has built together with its participants over the past 11 years. Alongside the efforts of the team involved, our existing guidelines, technology and product data, documented use cases, and the TRL9 Catalogue provided a valuable evidence base for developing and supporting the comment. This illustrates the long-term value of building and maintaining shared industry knowledge within the SPRINT Robotics community.

In addition to the formal FCC submission, SPRINT Robotics will continue to contribute to the public discussion around these measures. Through our public communication channels, we aim to increase awareness of their potential unintended consequences for industrial users and U.S. companies, and to bring practical industrial perspectives into the wider policy discussion.

Participants are invited to continue sharing relevant information, practical examples, and suggestions for follow-up with SPRINT Robotics at sprintrobotics@sprintrobotics.org