ACD Press Release

ACD Submits Comments to FAA Supporting Rule to More Effectively Manage Unmanned Aircraft Systems

Arlington, VA –Today, the Alliance for Chemical Distribution (ACD) submitted comments to the Federal Aviation Administration (FAA) as it finalizes a rule that would establish a regulatory structure governing unmanned aircraft flight restrictions (UAFRs) around fixed-site critical infrastructure. With unmanned aircraft systems (UAS) capabilities advancing rapidly and global examples of their use against industrial infrastructure, ACD strongly supports timely finalization of the Section 2209 rule so that both government and industry are equipped with tools to address risks before a major incident occurs. UAFRs are a critical element within a broader, layered framework for managing risks associated with UAS operations.

In the comments, ACD Senior Vice President of Government Affairs Brian Callahan warned of the increasing risk to critical supply chain infrastructure from unauthorized UAS activity.

“ACD member facilities operate complex, high-hazard environments that depend on predictable and secure operating conditions. ACD members therefore do not support UAS operations over their facilities unless the operations are conducted by the facility, on its behalf, or pursuant to its prior authorization and continuing coordination. Any other aerial activity, whether unintentional or deliberate, introduces unacceptable levels of uncertainty and can have cascading impacts on public safety, raw material supply, and economic stability.”

Callahan further noted an evolving threat landscape, which requires a forward-looking framework that considers not only historical incidents but also credible future scenarios.

“Compared to the conditions that existed when earlier incidents were documented, today’s UAS environment presents greater challenges, including systems that are more capable and widely available, flight operations that are more advanced, including coordinated multi-drone activity, and barriers to entry which have declined as a result of changing technologies or failure to reauthorize standards which enforced facility security measures, such as the Chemical Facility Anti-Terrorism Standards program.”

Callahan concluded by urging the FAA to finalize a “flexible, risk-based rule that provides meaningful access for high-consequence private-sector facilities, protects confidential and security-sensitive information, avoids unnecessary administrative and technical burdens, and reflects real-world chemical distribution operations.”

ACD looks forward to continued collaboration with FAA and its federal partners to protect employees, communities, and essential supply chains from evolving aerial risks. Working together, we can strengthen critical infrastructure security and support safe integration of UAS into the National Airspace System.

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The Alliance for Chemical Distribution (ACD) partners with our more than 400 chemical distribution industry members to provide the education, connection, standards, and advocacy they need to responsibly move the essential products our world depends on. As leaders in the $27B+ chemical distribution industry, ACD member companies commit to the highest standards in quality, safety, sustainability, and performance through ACD Responsible Distribution^TM. For more information, visit www.acd-chem.com.