Oregon Urges FCC to Establish Drone Test Sites in Mountainous Areas Rather Than Solely in Labs

Oregon Proposes Drone Test Sites to FCC

The Oregon Department of Aviation (ODAV) has submitted an eight-point response to the Federal Communications Commission (FCC) regarding its public notice on “Unleashing American Drone Dominance” (GN Docket No. 26-74). The draft, shared by ODAV Director Kenji Sugahara on LinkedIn, aims to encourage stakeholder feedback before the May 1 comment deadline.

Oregon’s response is notable for its specificity, identifying three potential locations for new Unmanned Aerial Systems (UAS) innovation zones: one in the Cascades near Oakridge, another along the Columbia River Gorge, and a third in southeast Oregon. This approach contrasts with many comment filings that merely request the FCC to consider various options.

Proposed Test Areas and Licensing Framework

The draft argues that the FCC’s current experimental licensing framework under Part 5 is inadequate for the mobile UAS testing required for public-interest operations. Oregon seeks a UAS-specific experimental license pathway that would allow for broader geographic authority, longer terms, faster modifications, and multi-band testing under a single authorization.

The proposed test areas are strategically chosen:

• The Cascades site near Oakridge features mountainous terrain prone to wildfires, where line-of-sight obstructions and weather variability are significant challenges.
• The Columbia River Gorge corridor facilitates testing across state lines, addressing cross-jurisdictional coordination.
• Southeast Oregon offers open terrain with a sparse population, minimizing interference risks while maximizing operational value for emergency logistics.

Oregon emphasizes that effective testing environments for wildfire response, infrastructure inspection, and medical delivery must reflect real-world conditions rather than controlled academic settings. The state also calls for collaboration between the FCC, FAA, and NTIA to support corridor-based testing for ongoing operations.

Spectrum Access and UAS Control Links

Oregon supports the FCC’s initiative to utilize the 5030-5091 MHz band for UAS control links and advocates for immediate measures that allow trusted operators to access this band while longer-term frameworks are developed. The state argues that relying solely on unlicensed bands is insufficient for safety-critical operations due to their susceptibility to interference.

The filing urges the FCC to assess how different frequency bands can support various functions within UAS architecture, emphasizing the need for reliable command and control links. Oregon prioritizes wildfire response, emergency management, and rural logistics in spectrum allocation discussions.

Addressing National Security Concerns

Oregon’s filing acknowledges national security issues related to foreign-produced drones but requests that the FCC maintain continuity in public-service operations. The state proposes a “simple risk appropriate waiver process” during the transition to domestic alternatives.

Despite concerns about national security, Oregon stresses that promoting domestic systems alone is not enough. The state argues that trusted deployment relies on practical access to equipment, certification pathways, technical support, and coordination with standards development organizations.

Clarifying Counter-UAS Testing Regulations

Oregon’s seventh recommendation seeks to clarify the distinction between various functions related to counter-UAS operations, including detection, tracking, identification, and mitigation. The state does not request expanded mitigation authority for local actors but calls for the removal of regulatory uncertainties that hinder the development of detection technologies.

Additional Recommendations

Oregon’s filing includes three additional recommendations:

• Modernizing coordination and notification procedures to better suit mobile, low-altitude drone operations.
• Establishing a centralized FCC resource for UAS and counter-UAS operators to access licensing pathways and equipment authorization rules.
• Ensuring that civil, public-safety, and state-led operations remain central in federal spectrum policy discussions.

The conclusion of the filing emphasizes the importance of considering rural and mountainous terrain, wildfire-prone regions, infrastructure corridors, and medically underserved communities in the FCC’s regulatory framework.

Implications for Future Drone Regulations

Kenji Sugahara’s experience in the drone industry lends credibility to Oregon’s filing, which stands out among the many comments the FCC will receive. By proposing specific test site locations and highlighting the operational needs of drone users, Oregon’s response may influence how the FCC approaches drone regulations moving forward.

As the FCC prepares to review comments, Oregon’s proactive stance could encourage other states to adopt similar positions, potentially reshaping the regulatory landscape for drone operations in the United States.