Comment from Anonymous

To the Federal Aviation Administration: I am writing to oppose extending Unmanned Aircraft Flight Restriction (UAFR) eligibility to food and agriculture facilities, particularly large-scale industrial animal agriculture operations such as factory farms and slaughterhouses. I understand the agency has not yet set eligibility criteria for this sector and is seeking comment on whether and how to do so. I urge the FAA to exclude industrial animal agriculture facilities from UAFR eligibility, or at minimum to build in an explicit exception preserving the public's ability to document these facilities from the air. The public interest in aerial documentation is well established. Drone photography has repeatedly surfaced information the public could not otherwise access, because these facilities span hundreds or thousands of acres and are largely invisible from public roads or ground level. Aerial footage has documented flooded manure lagoons after Hurricane Florence, mass depopulation operations during avian and swine flu outbreaks, feedlots holding well over 100,000 cattle, and egg operations whose "free-roaming" marketing claims did not match the conditions on the ground. In one case, aerial documentation gathered by Animal Outlook and We Animals contributed to a class action settlement against an egg producer for misrepresenting its hens' living conditions. This is not incidental journalism — it is often the only mechanism by which regulators, courts, and consumers learn what is actually happening at these sites. The safety and security rationale that justifies UAFRs elsewhere does not transfer cleanly to this sector. The facilities Congress originally identified for UAFR eligibility — chemical plants, oil refineries, water treatment systems — face a plausible physical threat: a drone collision, disruption, or attack with potential for a hazardous release or debilitating impact. Industrial animal agriculture facilities have not been shown to face a comparable threat from photographic drone overflight. The record does not establish that a drone taking pictures constitutes a safety or security risk to a barn, feedlot, or slaughterhouse in the way it plausibly does to a refinery or a nuclear facility. Granting UAFR eligibility on biosecurity grounds, without evidence that aerial photography itself introduces disease risk, would extend a security tool to a documentation problem it was never designed to solve. Biosecurity and worker-safety framing deserves scrutiny, not automatic deference. Industry commenters have argued that facility-based flight restrictions would protect the food supply, animal health, and the workers on these sites. I'd ask the FAA to weigh that framing against the documented record: environmental violations tied to these same operations (including manure lagoon failures and water contamination), the routine use of practices widely criticized on animal welfare grounds, and the well-documented rates of serious injury, PTSD, and substance use disorder among slaughterhouse and meatpacking workers. A rule that shields these facilities from the one tool that has reliably brought such harms to light does not serve food security or worker safety — it removes the accountability mechanism that has helped identify problems in the first place. Requested action. I ask the FAA to: - Decline to extend standard UAFR eligibility to food and agriculture facilities, particularly concentrated animal feeding operations and slaughterhouses; or, if the agency proceeds, - Require applicants in this sector to demonstrate a specific, evidence-based safety or security threat from drone overflight — not merely biosecurity concerns in the abstract; and - Preserve a clear exception for newsgathering, research, and public-interest documentation, so that lawful compliant drone operations conducted for journalism, environmental monitoring, or animal welfare oversight are not swept into a restricted airspace designation. Thank you for the opportunity to comment.