On 15 April 2026, the Oregon Department of Aviation submitted comments to the Federal Communications Commission regarding its public notice on ‘Unleashing American Drone Dominance’. The department views this proceeding as a practical opportunity to improve the communications and regulatory framework necessary to support real-world uncrewed aircraft systems (UAS). For states such as Oregon, the primary goal is a regulatory environment that permits trusted operators to conduct safe, repeatable and scalable operations where they can deliver the greatest public benefit, such as wildfire detection, search and rescue, and medical delivery.

Modernising experimental licensing – The department supports substantial reform of the FCC’s Part 5 experimental licensing framework. The existing system was not designed for the scale and complexity of modern UAS operations and is often too slow and geographically narrow for effective testing.

To address this, the commission should create a UAS-specific experimental licence pathway that allows broader geographic authority, longer terms and multi-band testing under a single authorisation. The department also recommends the greater use of blanket authorisations for qualified entities operating in defined corridors. Testing must evaluate how systems perform across real terrain, varying elevations and changing weather patterns, rather than being confined to single flat sites or small academic footprints.

Rural and mountainous innovation zones – A key recommendation is the establishment of additional innovation zones and testbeds in sparsely populated and mountainous environments. The department has identified three potential areas for this: the Cascades near Oakridge, the Columbia River Gorge and southeast Oregon.

These remote locations are vital because the environments that matter most for emergency logistics and wildfire response are not urban university corridors. Rather, they are mountain passes, river corridors and communities with limited transportation alternatives where communications resilience and route continuity become decisive factors. The FCC should coordinate with other federal agencies to enable corridor-based testing that reflects these real operating environments.

Spectrum access and coordination – Reliance on unlicensed spectrum alone is insufficient for safety-critical operations, as these bands are susceptible to interference. The FCC must accelerate practical access to reliable spectrum, specifically prioritising the implementation of the 5030-5091 MHz band for UAS control links.

Furthermore, the FCC must modernise its coordination requirements to reduce procedural friction. Legacy coordination structures were developed for static uses and often cause delays and duplicative reviews for route-based aerial operations. The coordination process should be rigorous where needed, but also predictable, timely and proportional to risk.

National security and public service – Acknowledging national security concerns regarding foreign-produced UAS, the department notes that public entities need confidence that their systems do not create unacceptable risks. However, the FCC must preserve the continuity of public-service operations by providing a workable transition pathway, including a simple, risk-appropriate waiver process.

To help navigate this complex regulatory landscape, the FCC should establish a centralised information resource for UAS and counter-UAS operators. This resource should provide plain-language explanations of licensing pathways, equipment and supply-chain considerations, and national security requirements. Clarification is also needed to ensure that counter-UAS testing for air domain awareness—such as detection and tracking—is not conflated with mitigation authority.

Ultimately, the central question for the future of uncrewed aviation is whether the federal framework will enable operations in environments where they provide the best return on investment. As the director of the Oregon Department of Aviation, Kenji Sugahara, concluded, rural terrain, wildfire-prone regions and medically underserved communities should be central to federal spectrum policy.