Oregon Is Telling the FCC What It Actually Takes to Run Drones at Scale, and the List Is Long

On April 15, 2026, the Oregon Department of Aviation submitted comments to the Federal Communications Commission in response to a public notice on unmanned aviation, and it's worth reading, not because Oregon is a unique case, but because it spells out in plain terms what the actual bottlenecks are for scaling drone operations in the United States.

The filing, from Director Kenji Sugahara, covers a lot of ground. But three points in particular should matter to anyone running a drone operation or building a business around one.

The Experimental Licensing System Wasn't Built for This

Oregon's first major point: the FCC's Part 5 experimental licensing framework, the pathway most commercial drone operators currently use to test new systems is structurally inadequate for modern UAS operations. The current system was designed for small scale, static, short duration testing. It moves too slowly, covers too little geography, and doesn't accommodate the kind of multi-band, multi-environment testing that serious operational planning requires.

Oregon's ask is direct: create a UAS specific experimental license with broader geographic authority, longer terms, and the ability to test across multiple frequency bands under a single authorization. They also want blanket authorizations for qualified operators running defined corridors, a concept borrowed from satellite licensing that's well understood but hasn't been applied to aerial operations at this scale.

This matters because experimental licensing is currently the only pathway for operators who want to test BVLOS routes, new payload configurations, or operations in complex terrain. If that pathway is too narrow or too slow, it creates a bottleneck that affects everything from wildfire response to infrastructure inspection.

Rural and Mountainous Terrain Is Where the Real Operational Challenge Lives

The second notable point: the environments that matter most for drone operations; wildfire detection, search and rescue, medical supply delivery, aren't in flat fields near universities. They're in mountain passes, river corridors, and rural communities with limited transportation alternatives. And the FCC's current framework doesn't reflect those realities.

Oregon identified three specific areas it wants designated as innovation zones and test beds: the Cascades near Oakridge, the Columbia River Gorge, and southeast Oregon. These aren't arbitrary locations. They're places where the gap between a drone delivery and a road delivery is measured in time critical outcomes, and where communications resilience and route continuity are genuine safety issues, not edge cases.

The FCC is being asked to coordinate with other federal agencies to enable corridor-based testing that actually simulates real operating environments, rather than confined test sites that don't represent the terrain where drones would actually be deployed at scale.

Spectrum Isn't Optional for Safety-Critical Ops

The third point is the one that tends to get glossed over in drone industry coverage: spectrum. Oregon's filing is direct on this, relying on unlicensed spectrum alone is insufficient for safety critical operations because those bands are susceptible to interference. The department wants the FCC to accelerate practical access to the 5030-5091 MHz band for UAS control links, and to modernize coordination requirements that were built for static uses and cause unnecessary friction for route-based aerial operations.

This is a regulatory conversation that rarely gets airtime compared to FAA rule making, but it's foundational. If the communications link isn't reliable, nothing else about the operation is.

The National Security Friction Point

Oregon also touched on the tension between national security concerns around foreign-produced drones and the operational continuity of public service agencies. The department isn't dismissing those concerns, it's asking for a workable transition pathway, including a risk appropriate waiver process, so that agencies running critical operations aren't suddenly grounded because of supply chain definitions they don't control.

It's a pragmatic position: acknowledge the concerns, provide a pathway forward, keep the operations running.

The Bottom Line

Oregon's filing won't make headlines the way a new BVLOS waiver or a high-profile cargo trial does. But it's a useful document because it names the specific regulatory gaps that operators already know exist, and it frames them in terms of operational outcomes rather than abstract policy goals.

The FCC's proceeding on "Unleashing American Drone Dominance" is still open. What Oregon submitted is essentially a requirements document from an operational state agency, one that flies in wildfire country, manages rural infrastructure, and knows the difference between a demo flight and a mission critical one. That's the kind of input that shapes whether the final framework actually works for the people it's supposed to enable.