Unmanned Aircraft Systems: FAA Could Better Leverage Test Site Program to Advance Drone Integration

UAS could provide significant economic and social benefits, for example by delivering packages or aiding in search and rescue missions. FAA is conducting a phased approach to incrementally integrate UAS safely into the national airspace. As directed by statute, FAA established UAS test sites to allow industry to assess the safety and feasibility of complex UAS operations, such as flying beyond an operator's line of sight. FAA has stated that this program provides research results and other data needed to reach full integration.

GAO was asked to review FAA's management of the test sites. This report examines, among other things: (1) the research conducted at FAA's designated UAS test sites, and (2) how FAA is leveraging and sharing information from the test site program to advance integration. GAO reviewed relevant statutes and regulations, reports, and FAA guidance; analyzed test sites' efforts, including flight test data submitted to FAA from 2015 through 2018; and interviewed FAA officials, test site representatives from all 7 test sites, and 18 test site users, selected to include a range of perspectives.

The Federal Aviation Administration's (FAA) seven designated test sites for unmanned aircraft systems (UAS) have facilitated about 15,000 UAS flight tests since 2015 and supported a wide range of research. Both public and private entities have used the test sites to test technologies in preparation for varied UAS activities, from inspecting utilities to carrying passengers. Research conducted at test sites provides data on the performance of various UAS capabilities and technologies; such data could support FAA's integration efforts.

While FAA collects this data from test sites, it has not fully leveraged the data or the program to advance UAS integration. According to FAA's 2018 Roadmap for UAS Integration a key goal of this program is to provide data to support FAA's decisions on drone integration. FAA officials said the agency intends to use the data to a greater extent in the future to advance integration. Without an analysis plan, however, FAA could miss opportunities to better use the data to inform the overall integration effort, such as to inform UAS operational standards. Also, FAA reports limited public information about how test sites' research relates to the agency's integration plans. Agency officials told GAO they were wary of sharing more information about the test sites, citing concerns about, among other things, protecting test site users' proprietary data. All test site representatives and most users GAO interviewed, however, said that more information on test sites' research would be helpful for UAS stakeholders' research efforts. According to FAA plans, the agency must rely on relationships with stakeholders across government and industry to ensure that integration efforts are harmonized. By sharing more information publicly, FAA could demonstrate to such stakeholders how the agency is fostering and using research to inform and advance integration. Further, with more information, more stakeholders may opt to use a test site to conduct their own research, thus potentially increasing data available to FAA to inform its integration decisions.

GAO recommends that FAA (1) develop a data analysis plan for test site data and 2) share more information on how this program informs integration, while protecting proprietary data. FAA partially agreed with the first recommendation and agreed with the second. GAO added language to the first recommendation to address the issue that FAA raised, as discussed in this report.

The emergence of and anticipated growth of unmanned aircraft systems  (UAS)—commonly referred to as “drones”—could provide significant  social and economic benefits in the United States. UAS operations have  the potential to make commercial enterprise more efficient, for example,  by delivering packages and monitoring agricultural crops. Additionally,  UAS can be used to support public safety by aiding in search and rescue,  engaging in aerial surveillance, and inspecting infrastructure, among  others. In coordination with government and industry, the Federal  Aviation Administration (FAA) is conducting a phased approach to  incrementally integrate both existing and planned UAS operations—from  package delivery to passenger transport—safely into the national  airspace system. Eventually, according to FAA, with industry’s support  and based, in part, on the results of research, development, and testing  efforts on UAS technologies, the agency will be able to fully integrate  UAS operations into the national airspace system, meaning UAS of all  sizes operating in the airspace system along with manned aircraft.

FAA’s UAS test site program, which became operational in 2014, is one  effort that could help the agency reach full UAS integration. As required  by law, FAA established seven UAS test sites to enable both private- sector firms and public entities to safely access the airspace to test  complex UAS operations and conduct research on UAS technologies.  We reported in 2015 that these test sites provide UAS operational and  safety data to FAA, which the agency could use to support its UAS  integration efforts, in part by informing its future decision-making on regulations, policies, and standards. You asked us to examine how FAA  is managing the test sites. This report examines: what research has been conducted at FAA’s designated UAS test what steps FAA has taken to address any test site research how FAA is leveraging and sharing information from the test site  program to advance UAS integration.

To address these objectives, we reviewed relevant statutes and  regulations; FAA orders and guidance; and FAA documents related to  UAS integration, UAS research and development efforts, and the test site  program. We also reviewed test sites’ annual and quarterly reports to  FAA, as well as recent relevant reports by the National Aeronautics and  Space Administration (NASA), Department of Transportation’s Office of  Inspector General (DOT OIG) and GAO. To identify the number of test  flights that have occurred through the test sites, we analyzed flight test  data collected by the test sites and submitted to FAA via FAA’s Mission  Logging System (MLS) from 2015 through 2018. We assessed the  reliability of the data provided by FAA from MLS by reviewing them for  anomalies, outliers, or missing information, among other things. Based on  these steps, we determined them to be sufficiently reliable for capturing  the number of qualifying test flights reported as occurring at each test site  from 2015 through 2018.

In addition, we interviewed FAA and NASA officials, representatives from  all seven test sites, and a selection of seven UAS and aviation industry  stakeholders (e.g., UAS industry associations and aviation research  organizations) to address these objectives. We identified these  stakeholders by reviewing related literature and our prior reports. We also  conducted semi-structured interviews with a non-generalizable sample of  18 current or previous test site clients (whom we will refer to as “users”)  (see app. I). Specifically, we conducted interviews with at least two users  of each test site. We identified users through recommendations from test  site representatives and by reviewing related literature to represent a mix  of both public and private entities. We selected users to interview to  obtain a range of UAS stakeholder perspectives. Because we selected a  non-generalizable sample of users, their responses should not be used to  make inferences about a population. To characterize stakeholders’ views  throughout the report, we defined modifiers (e.g., “some”) to quantify test  site representatives and users as follows:

Representatives: Representatives of “some” test sites refers to  representatives from 3 to 4 of the 7 total designated test sites, and  representatives of “most” test sites refers to representatives from 5 to  6 test sites.

Users: “Some” users represents from 4 to 8 users of the total 18  interviewed, “many” users represents from 9 to 13 users, and “most”  users represents 14 to 17 users.

In addition, we compared FAA efforts identified through documentation  review and interviews to FAA’s stated goals, to federal internal control  standards related to the use of quality information to achieve objectives  and communicating effectively with external parties, and to key practices  for reporting on research and development activities.

We conducted this performance audit from July 2018 to January 2020 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

FAA’s Efforts to Integrate UAS Operations into the National Airspace System

FAA is responsible for overseeing and authorizing any flight operations in  the national airspace system for both manned and unmanned aircraft.  FAA’s UAS Integration Office, located in the Office of Aviation Safety,  seeks to integrate UAS operations into the national airspace system while  ensuring the safety of the public and integrity of the airspace. In July  2018, FAA released the 2018 UAS Integration Roadmap, a second  edition of the agency’s 5-year plan outlining its most current phased  approach for integration, with each step toward full integration allowing  UAS operations of increasing complexity. FAA’s vision for fully  integrating UAS into the national airspace system entails UAS operating  safely and routinely—i.e., without requiring prior approval for UAS  flights—in the same airspace as manned aircraft. While safety is FAA’s  paramount concern, the integration of UAS is important because of the  potential economic benefits that progress in UAS integration could bring,  including more investment in uses such as large passenger operations,  as well as the potential safety benefits, such as more effective firefighting  and other disaster response efforts.

Currently, FAA only allows certain routine UAS operations under specific  conditions while authorizing other UAS operations on a case-by-case  basis. For example, since August 2016, operators of small UAS—defined  as those UAS weighing less than 55 pounds, including any attachments— who have obtained a remote pilot certificate have generally been allowed  to operate without prior FAA approval in certain airspace during the day,  under 400 feet, and not over people or beyond an operator’s line of sight,  among other requirements under FAA’s Part 107 rule. Small UAS  operators may seek a waiver of certain FAA operational requirements  (referred to as a Part 107 waiver) from the agency on a case-by-case  basis, such as a waiver that would allow an operator to fly drones above 400 feet. In contrast, no routine operations—meaning those that can  occur without any prior authorization—are currently allowed for large UAS  (55 pounds and over) for any purpose (see fig. 1 for examples of small  and large UAS). Rather, operators of large UAS must seek authorization  from FAA to fly the aircraft on a case-by-case basis, and the processes  for accessing the airspace vary.

More specifically, civil large UAS operators must, in most cases, obtain a  Certificate of Waiver or Authorization (COA) that demonstrates FAA’s  approval of airspace access, and may also require approval for the  aircraft itself. A COA allows any certificate holder to fly UAS outside of  generally allowable operations, such as at certain altitudes, locations, or  airspace classes (e.g., near airports). FAA grants this approval to an  entity for a specific activity and time period, and sometimes for a specific  make and model of UAS. Public entities—which include federal, state and  local governments, public academic institutions, and law enforcement  agencies—may apply for a COA in order to obtain authorized access to  fly in the national airspace for when they are conducting governmental  operations, as defined by statute. In such cases, the COA allows for the  certificate holder to operate UAS in ways that would otherwise not comply  with airspace requirements, such as operating the drone beyond the  pilot’s line of sight.

In its 2018 UAS Integration Roadmap, FAA outlined some key topics and  operational capabilities to be researched that are associated with specific  UAS integration phases (see fig. 2). For example, both government and  industry entities have research and testing of technologies underway to  provide UAS the capability to detect obstacles in midair, such as other  aircraft, and automatically maneuver to avoid collision; this capability is  commonly referred to as “detect and avoid.” FAA officials have stated that  this key capability is necessary before allowing certain UAS operations on  a routine basis, such as flights beyond the operator’s line of sight.  According to FAA, the agency plans to use data from several UAS  research programs—including the test site program—and from other  sources to inform its future decisions regarding UAS integration.

In 2012, FAA was required by statute to establish a program to integrate  UAS into the national airspace system and to establish six UAS test sites  in order to develop a process for allowing research to occur at these test  sites, among other requirements. In response to Congress’ mandate, in  2013 FAA selected six public entities to be designated as test sites based  on a number of factors, including geography, climate, and the respective  institutions’ expertise, and added another entity in response to legislation  in 2016 for a total of seven designated test sites. According to FAA  officials, the test site program was intended to enable industry  stakeholders to test complex UAS operations and conduct research on  the corresponding technologies. Each test site is a public entity, such as a  public academic institution or branch of the state government, which FAA  authorizes to conduct various UAS operations through the COA process.  UAS stakeholders, including manufacturers or entities seeking to use  UAS for various purposes, can pay to work with any of the seven FAA- designated test sites to conduct test flights or receive training on UAS  operations and regulations, among other activities, based on the test site  staff’s expertise. FAA has not directly funded the test sites’ general  operations, so the sites have had to rely on other funding sources, such  as revenues generated from users, state funds, federal research grants,  and commercial investment. Congress recently appropriated $6 million to  FAA to provide matching funds to qualified commercial entities seeking to  test UAS technologies at FAA designated test sites.

FAA manages the test site program using formal agreements and by  providing support to test site staff. The test sites signed individual Other  Transaction Agreements (OTA) with FAA that establish their agreement  to meet specific requirements aimed to support FAA’s UAS integration  efforts. For example, these agreements lay out that test sites must  follow safety processes and data procedures, as well as provide certain  deliverables to FAA. Specifically, the agreements outline that the test  sites will provide FAA certain operations and safety-related data for  specific test flights, which FAA stores in a database it created specifically  for test site data. In addition, once the test sites were operational, FAA  designated an official to serve as the test site program manager for all  seven sites who, among other duties, facilitates regular meetings with test  site representatives to discuss ongoing issues and regularly  communicates with other FAA lines of business to keep them informed  about key efforts underway at test sites.

According to FAA, the designated test sites have the equipment and  infrastructure to support UAS flight testing, such as UAS pilots, launch  pads, command centers, and, if required, chase aircraft (see fig. 3).

Test site staff can facilitate UAS flight operations under a test site’s COA  or by complying with the Part 107 rule. Since 2015, the test sites have  held a “blanket” COA that allows them to conduct government functions  for small UAS in Class G (uncontrolled) airspace anywhere in the United  States except within restricted or prohibited areas. In addition, test sites  have applied for and been granted COAs to operate UAS of different  sizes in locations (referred to as “test ranges”) outside their state, and in a  variety of airspaces at various elevations (see fig. 4 for a sample of test  site COAs). For example, as of October 2019, the Alaska test site had  COAs for test ranges in many states including Alaska, Hawaii,  Tennessee, and Oregon—one of which allows operations up to 15,000  feet above mean sea level within three classes of airspace around  Pendleton, Oregon. Some test ranges are located at airports, such as  Griffiss International Airport in New York, which can help facilitate the  testing of UAS that may require runways for take-off and landing, as well  as testing of UAS flying in areas with manned aircraft.

However, stakeholders, such as UAS manufacturers or companies  interested in using UAS for various purposes, are not required to use an  FAA-designated test site for UAS flight testing. In addition to seeking  authorization directly from FAA to conduct their own flights or flying  according to current rules such as Part 107, UAS stakeholders can work  with other entities—such as military airports, public academic institutions  or other public test sites—to which FAA has granted COAs to conduct  complex UAS operations. For many stakeholders, however, working with  a designated test site may provide quicker access to testing than seeking  their own authorization from the FAA. For example, a UAS manufacturer  might work with a test site to test the company’s UAS prototype at a  certain elevation under a test site’s existing COA (following all applicable  COA guidelines, such as performing a government function with the  operation) because the test site already had that authorization in place.  Additionally, it may be beneficial for a UAS manufacturer or operator to  work with a test site because the test site has experience in obtaining  authorizations or waivers from FAA for similar types of operations or  aircraft.

Test Sites Have Facilitated Thousands of UAS Test Flights for a Wide Range of Research and Activities

Test Sites Have Facilitated about 15,000 UAS Test Flights

According to FAA’s MLS data, the test sites facilitated about 15,000  total UAS test flights occurring under test site COAs from April 2015  through December 2018 (see table 1). However, according to test site  representatives, staff at these sites facilitated more UAS flights during this  time frame than is reflected in the MLS data, because additional flights  were conducted using different allowances than COAs, such as under the  Part 107 rule that allows certain routine small UAS operations.

According to FAA officials, the decrease—starting in 2017—in the annual  number of reported test flights by the test sites, as reflected in table 1  above, is due in part to a change in regulations. Specifically, when FAA’s  Part 107 rule took effect in August 2016, it provided a new avenue for  small UAS operators, including test site staff and other airspace users, to  test certain small UAS operations without requiring a COA or other  authorization, effectively reducing the number of test flights logged into  FAA’s MLS. Agency officials also told us that Part 107 changed the type  of research users request from the test sites, which may have reduced  the number of test flights facilitated through the test sites. While there  have been fewer flight tests, according to some test site representatives  and users we spoke to, recent testing has been for more complex  research. For example, one test site representative stated that now the  site’s users have bigger, more extensive research projects involving more  tasks than just test flights, such as developing the operational models,  performing testing on various technologies, and installing equipment to  support complex UAS operations.

Test Sites Have Supported UAS Stakeholders in Conducting Research in Preparation for Varied UAS Activities, from Inspecting Utilities to Carrying Passengers

Research conducted at the test sites has provided information to FAA  that, according to agency officials, supports its efforts to integrate UAS  into the national airspace system. Test site representatives told us that  they have supported over 440 public and private users to conduct  research and development on UAS to be used for a variety of UAS  activities. While FAA officials told us that they cannot direct specific types  of research to be conducted at the test sites unless the agency funds that  research, we found that users have nevertheless conducted UAS  research and development activities that FAA has identified as important  for UAS integration. For example, users conducted research on the safety  risks of UAS, such as concussion collision studies, and have tested UAS  capabilities, such as the ability to carry loads of varying weights. Also,  based on our analysis, we found that users have tested UAS technologies  at the test sites that align with some of the key capabilities identified by  FAA as necessary for the upcoming phases of UAS integration (see table  2).

Test site users also reported benefits from working with test sites.  According to the users we interviewed, the test sites have provided them  an opportunity to explore and improve UAS technologies, and to learn  more about how they could use UAS for their own purposes in the  national airspace. For example, one user of the New York test site had  tested communication equipment and detect-and-avoid capabilities on  large UAS that they manufacture and sell to other entities for conducting  surveillance activities, such as drug interdiction. Many of the test site  users (11 of 18) we spoke to stated that using a test site provided a  significant benefit for advancing their entity’s UAS research and  development efforts. In addition, according to 9 of the 18 users we spoke  to, test sites provided them with direct and immediate access to tools that  helped them test their technologies. For example, users stated that it was  beneficial that test sites have specific authorities from FAA for certain  types of testing under a COA as well as infrastructure to allow for  advanced UAS research.

Some activities the test site users we spoke to plan to conduct with UAS  are already regularly occurring—meaning FAA either allows these to  occur on a routine basis or has allowed them to occur through additional  authorization on a regular basis. Others are not yet occurring on a regular  or routine basis due either to legal restrictions, such as restrictions on  operating UAS beyond the operator’s visual line of sight or needed  technological advancements, but FAA expects them to occur routinely in  the future (see table 3).

Some users we spoke to have also worked with a test site to conduct  extensive hazard and risk mitigation testing to build safety cases and get  approval from FAA to conduct complex UAS operations. FAA generally  requires safety cases when a user is seeking approval to deviate  significantly from current UAS requirements, such as when seeking to  conduct beyond-visual-line-of-sight operations using a small UAS. For  example, according to representatives from an insurance company we  spoke to, they worked with the Virginia test site for over a year to build a  safety case to prove that the company could safely operate its small UAS  beyond the operator’s line of sight and over people. According to test site  representatives, this risk mitigation testing entailed dozens of  experiments, including how to address the risk of an UAS abruptly losing  power. For instance, if a UAS operating over a house for an insurance  inspection loses power, it could fall, potentially causing damage to the  building as well as injuring someone standing on the ground below. In  November 2018, FAA granted approval for the company to fly its fleet of  UAS over people and beyond the operator’s line of sight in sparsely  populated communities nationwide for insurance claim inspections.

Test Sites Have Also Participated in Federal UAS Research Projects Intended to Inform UAS Integration

All test sites have competed for and were selected by federal agencies to  participate, to varying degrees, in additional UAS research efforts  designed to inform aspects of FAA’s integration plans. The projects  include:

The Department of Transportation’s (DOT) UAS Integration Pilot  Program (IPP): In May 2018, DOT selected 10 project teams—which  included the Alaska, North Dakota, and Virginia test sites—to  participate in this program aimed at evaluating different concepts for  certain UAS operations in specific communities. According to DOT,  the IPP is an opportunity for state, local, and tribal government  agencies to partner with private sector entities, such as UAS  operators or manufacturers, to, among other things, accelerate the  approval of operations that currently require case-by-case  authorizations. Two key intended outcomes of the IPP are to assess  the respective communities’ acceptance of low-altitude UAS  operations, and to balance national and local interests in furthering  UAS integration. For example, the Alaska test site is a member of the  University of Alaska Fairbanks IPP team, with a primary focus of  enabling complex UAS technology for pipeline inspections in the  area’s harsh climatic conditions through testing technologies, such as  using detect and avoid technology at night. While project awardees do  not receive any federal funding for this program, FAA officials told us  they are collecting data from IPP efforts to inform future decision- making.

FAA’s Center of Excellence for UAS: In May 2015, FAA selected a  team of 15 research institutions, including the Alaska and New Mexico  test sites, called the Alliance for System Safety of UAS through  Research Excellence (ASSURE), to serve as FAA’s Center of  Excellence for Unmanned Aircraft Systems and to conduct academic  research critical to safe and successful UAS integration. Congress  has appropriated funds to ASSURE since fiscal year 2014 to pay for  operational expenses and research, and according to FAA officials,  ASSURE institutions are eligible to receive grant funding from FAA’s  Research, Engineering, and Development appropriations. ASSURE  institutions receive federal grants to conduct research to assess  specific technologies or risks with the intent to inform FAA regulations  and policies. For example, ASSURE institutions have received grants  from FAA to study UAS noise certification, ground and airborne  collision severity and impacts, and UAS detect and avoid  technologies. According to FAA, funding from non-federal entities,  such as international civil aviation authorities can be applied to  ASSURE. Some of ASSURE’s research has been peer reviewed and  published. According to an ASSURE representative we spoke to, all  of the research conducted through ASSURE is in alignment with  FAA’s plans for UAS integration as outlined in the 2018 UAS  Integration Roadmap.

FAA’s and NASA’s UAS Traffic Management (UTM): The UTM  program is a collaborative effort of FAA and NASA to design a system  with a similar concept as FAA’s air-traffic-control system for manned  aviation that would enable small UAS to operate safely at low altitudes  around other aircraft. NASA is leading the research, development,  and testing of various technologies that would comprise the system,  and plans to transfer the results of the research to FAA to determine  next steps. NASA selected six test sites—Alaska, Nevada, New York,  North Dakota, Texas, and Virginia—to participate, to varying degrees,  in the four different phases of this project. NASA has provided funding  to the six test sites through contracts for their participation in testing  the system. UTM research is divided into four phases, called  technology capability levels, each with specific technical goals. For  example, technology capability level three entailed testing  technologies that maintain a safe distance between two UAS flying  over moderately populated areas. All six sites participated in the first  three phases, which according to NASA officials brought in about 35  industry partners for this research effort. The Nevada and Texas test  sites are currently participating in the fourth and final phase, which— as of October 2019— NASA expected to complete in 2019. In  addition, FAA selected the North Dakota, Nevada, and Virginia test  sites to participate in its UTM Pilot Program. The program’s goals are  to develop, demonstrate, and provide services that will support the  implementation of UTM operations.

NASA’s UAS Integration in the National Airspace System:  Beginning in 2015, NASA provided funding to the New York and  Virginia test sites, among other entities, for this project, which is  intended to demonstrate solutions to technical challenges to inform  FAA’s development of operational standards for UAS. For example,  through this project, NASA intends to test detect and avoid  technologies by assessing UAS performance during a variety of  scenarios, and then by recommending a minimum set of performance  standards to FAA for consideration. According to NASA officials, the  agency has completed work at the New York test site related to  developing standards for routine operations by large UAS. As of  October 2019, NASA had ongoing research at the Virginia test site on  command and control communications that officials expected to  complete in 2019.

FAA’s UAS Detection at Airports: According to FAA, six test sites— Nevada, New Mexico, New York, North Dakota, Texas, and Virginia— participated in this program alongside various industry partners to  evaluate technologies that can be used to safely detect UAS near  airports. Funded by FAA, this research project included evaluating  the capabilities of various UAS detection technologies by different  manufacturers at four U.S. airports in 2016 and 2017. This research  was used to inform minimum performance standards for UAS  detection systems deployed at airports.

FAA Has Improved Collaboration and Taken Other Steps to Address Challenges to Test Sites Conducting UAS Research

As the Program Has Matured, FAA Has Taken Some Steps to Address Management Challenges

All test site representatives stated that FAA has improved both its  management of the UAS test sites and collaboration with representatives  in recent years as the program has matured. According to test site  representatives, initially, as the program began, there was considerable  turnover among FAA test site managers, which made it more difficult for  the staff at the test sites to collaborate with FAA officials to undertake  research efforts. FAA officials acknowledged that because they had not  established test sites before, it took time to determine the best approach  for managing this program. However, according to most representatives,  in the last few years, FAA has begun to better collaborate with the test  sites. Specifically, FAA has solicited input from test site representatives  on various issues related to UAS integration and helped facilitate  information sharing between the test sites and various FAA lines of  business. For example, agency officials told us that they invited air traffic  specialists from a regional FAA office to participate in a recent UAS Test  Site program semi-annual meeting. Through this meeting, these FAA  regional staff learned about the test sites’ initiatives and about unique  aspects of the test sites’ COAs, which, as previously noted, they use to  conduct flight tests. According to FAA officials, with the better  understanding about test sites’ operations gained at the meeting, these  regional FAA staff will be able to process the test sites’ COA requests  more efficiently. Most test site representatives also told us that FAA’s  current UAS test site program manager and other FAA staff are  responsive to, for example, questions or requests for guidance on a  particular issue.

Further, based on our interviews with test site representatives and our  analysis of test sites’ reports submitted to FAA, the agency has taken  steps to address some challenges from the past. In our March 2015  testimony and July 2015 report on FAA’s progress in integrating UAS into  the national airspace, we outlined initial challenges that stakeholders  most frequently cited as affecting test sites’ ability to attract users and to  generate sufficient revenue to remain in operation during their first year.  Since 2015, FAA has taken several steps to address these challenges, by  providing additional guidance, streamlining the COA process for test  sites, and improving the agency’s collaboration with and management of  the test sites (see table 4).

However, based on our analysis of interviews conducted for this review  with test site representatives and users, these previously identified  challenges persist.

Lack of FAA guidance on priority research: Most test site  representatives reported that while FAA has improved its  management of the program, available FAA guidance still lacks the  needed detail about research areas to prioritize in order to promote  overall UAS integration efforts. For example, some test site  representatives told us that the 2018 UAS Integration Roadmap  should provide more information about the agency’s planned  timeframes for implementing various steps to achieve full UAS  integration, such as how and when FAA plans to integrate large UAS.  Without such details, representatives say they cannot fully inform  potential users when it might be possible to routinely use some  complex UAS operations that are in demand by industry but currently  only allowed on a case-by-case basis, such as the ability to fly small  UAS beyond the operator’s line of sight or over people. Several  representatives told us they are concerned that some potential test  site users may postpone their research or conduct it abroad because  of this lack of detail on when FAA plans to routinely allow such  complex UAS operations.

According to FAA officials and as noted in table 4 above, the agency  has issued strategic plans and provided briefings to test site  representatives and stakeholders on relevant research needed to  achieve UAS integration. However, FAA officials told us that there are  limitations on how much guidance they can provide the test sites.  They said that the Anti-Deficiency Act prevents FAA from directing  specific test site activities and obtaining research data, other than the  operations and safety data required by the COA, without providing  compensation. Officials also noted that until standards and regulations  are developed—an effort for which the agency has not set a targeted  completion date—a case-by-case approval basis will be needed for  allowing complex UAS operations. With regard to the concern that  some potential test site users may be conducting research abroad,  FAA officials told us that testing abroad will not provide these  stakeholders the same experience as testing in the United States,  given that the U.S. national airspace system is more complex than  those abroad in terms of traffic and congestion.

Complex and lengthy COA process: Most test site representatives  and users we interviewed told us that FAA should implement a less  complex and time-consuming COA process for the test sites.  According to test site representatives, FAA’s actions have decreased  the time it takes to obtain simple COAs and Part 107 waivers, but for  applications to conduct more complex research activities, FAA’s  process remains lengthy and uncertain. This challenge makes it more  difficult for test sites to meet users’ needs, according to  representatives, and can subsequently lead companies to conduct  UAS research in other countries. For example, some representatives  told us that one test site’s request for a waiver to fly UAS beyond  visual line of sight had taken 3 years for FAA to approve, and they  could not understand why. Representatives also told us that for COA  applications involving requests to research complex UAS operations,  it was not always clear why FAA denied their requests, leading to  uncertainty. According to FAA officials, the waiver that took 3 years to  approve was an outlier and the agency’s processing of such waivers  usually takes 90 days or less. However, in January 2018, DOT’s OIG  similarly reported that FAA has had difficulty keeping pace with the  volume of Part 107 waiver requests received and, in particular, has  been slow to approve complex UAS waivers—such as requests to  operate beyond the operator’s visual line of sight. In this report, the  DOT OIG made recommendations related to improving the waiver  process, which FAA is working to address.

Generating sufficient revenue to maintain test site operations:  Most test site representatives told us that securing sufficient funding  to develop future capabilities and infrastructure in order to attract  industry users and partners, remains a major challenge that they  predict will continue. Some test site representatives told us that their  respective contracts with NASA for projects such as UTM have been  their largest single revenue source. Another representative mentioned  that the U.S. Coast Guard has been a test site user, which has helped  the site to generate revenue. Test sites have attempted to generate  revenue in other ways, for example by obtaining state and local  government funds to build infrastructure to attract users, applying for  competitively awarded research contracts, and consulting and  conducting research with potential users in different locations. FAA  officials acknowledged that the test sites will need to continue to  generate sufficient revenues to support their operations, but noted  that, whenever possible, the agency provides the test sites with  opportunities to compete to participate in funded research efforts,  such as those related to the UTM program.

FAA Has Taken Steps to Address Technology- Related Challenges, Which Are Complex

Most test site representatives and users we interviewed also identified  technology-related challenges affecting test sites’ ability to conduct  research as continuing issues. These mostly relate to technology-related  capabilities that will be vital for achieving full UAS integration, but which  are currently still in development (see fig. 5). As we have previously  reported, integrating UAS into the national airspace will require FAA to  address key technology-related challenges to enable routine UAS  operations with manned aircraft. For example, in our July 2015 report,  we identified such challenges affecting test sites, in addition to the  management-related challenges discussed above. According to test site  representatives and FAA officials, these key technology challenges and  concerns could affect broader UAS integration and research efforts, and  thus impact the pace of or stop the progress toward full integration into  the national airspace system.

Such key technology-related challenges and related efforts to address  them include:

Availability of dedicated radio-frequency spectrum: Radio- frequency spectrum provides communication links between a UAS  and its control station or operator. According to FAA, dedicated radio- frequency spectrum is important to ensure UAS safety and security in  order to operate in the national airspace. For example, radio- frequency spectrum is needed for command and control, detect and  avoid, and beyond visual-line-of-sight capabilities of UAS. Without a  dedicated radio-frequency spectrum, the intentional or unintended  interference of radio transmissions could sever the UAS means of  control because other consumer products also use radio frequencies  that could cause interference. FAA officials and test site  representatives told us this spectrum-availability problem is the one  challenge that has the potential to bring UAS research efforts to a halt  if not addressed. Representatives from five of seven test sites  indicated that availability of spectrum affects their ability to conduct  their research operations and, more broadly, also affects the progress  of other efforts contributing to UAS integration. Similarly, some test  site users told us that when deciding on a potential test site to contract  with for conducting their research, they asked about whether the test  site faced any radio frequency interference.

According to FAA officials, the agency is assisting test sites in  addressing this challenge by collaborating with the Federal  Communications Commission (FCC), which is responsible for  allocating spectrum to nonfederal users for various purposes and  assigning spectrum licenses. FAA’s Spectrum Office is a participant  in the regularly occurring meetings between FAA officials and test site  representatives. These representatives said they have been  communicating with FAA to clarify guidance on the different frequency  bands to use at various operating altitudes related to an FCC rule.  Nevertheless, according to FAA officials, in the near future, more  issues will likely surface related to spectrum because of the industry’s  interest in conducting flights beyond visual line of sight for both small  and large UAS. FAA officials told us spectrum reserved for aviation  safety communications are limited. Therefore, the officials are  investigating how to get the maximum UAS capacity in the national  airspace by efficient management of the current allocated spectrum.  Furthermore, FAA is preparing a report for Congress that covers the  use of spectrum allocated for possible UAS activities. FAA officials  told us that the report will not delay or prohibit the use of any licensed  spectrum for UAS. FAA expects to submit its report to Congress in  April 2020.

Limitations to conducting counter-UAS detection and research:  Counter-UAS activities involve using technology to help detect, track,  and defend against illegal or unauthorized activities. Pursuant to  federal law, it is illegal to damage or destroy aircraft, and this statute  may apply to UAS. Other provisions of federal law may prohibit the  use of certain detection systems and mitigation systems.

FAA does not support the use of counter-UAS systems, which  includes interdiction capabilities, by any entities other than the federal  agencies with explicit statutory authority to use these technologies,  including for the testing and evaluation of such systems. In addition,  FAA has limited authority for testing UAS detection and mitigation  systems at airports. Federal agencies with the authority to mitigate  risks of UAS under certain circumstances are the Departments of  Defense, Energy, Justice, and Homeland Security. According to one  test site representative, industry’s ability to conduct research on  counter-UAS technologies is limited because it requires the  participation of one of the four agencies listed above. FAA officials  told us that these federal agencies have the authority to conduct  counter-UAS operations. These agency officials noted that the test  sites could support counter-UAS research activities, for example, by  providing the expertise and any infrastructure needed for the test  flights, such as a chase aircraft.

Some test site representatives and users we spoke to suggested that  it would be helpful if more counter-UAS research were allowed. For  example, they said that further research is needed to understand how  to address counter-UAS threats—such as someone illegally trying to  interfere with the radio frequency of a UAS delivering a package. One  test site representative told us that multiple users want to fly swarms  of UAS (where one operator flies multiple UAS simultaneously in  proximity) to conduct counter-UAS operation research, but it is a  challenge to support users’ desired research because of current  restrictions. However, some stakeholders pointed out that the  available technology for conducting such research, such as detect  and avoid technology, is not developed enough yet to allow for  effective research in this area.

FAA Collects Data from the Test Sites but Has Not Fully Leveraged the Data or the Program to Advance UAS Integration

FAA Regularly Collects Information and Data from Test Sites, but Has Not Determined How to Use These Data to Advance UAS Integration

FAA regularly gathers information from the test sites in the following  ways:

Meeting with test site representatives: In the previously described  regular meetings between FAA and test sites—monthly by  teleconference and semi-annually in-person—participants share  information on experiences conducting research and challenges  faced. According to FAA officials, the meetings are helpful in informing  the agency about the types of UAS research that users are pursuing,  among other things. Representatives of all seven test sites agreed  that these meetings are helpful. For example, some representatives  noted that such meetings facilitate information sharing about, for  example, the status of other FAA-affiliated UAS research efforts— such as UTM and the IPP—and the status of other FAA initiatives  underway, such as UAS rulemakings.

Collecting data from test sites: Test sites have provided several  types of data to FAA since 2015, including:

Entering data on flight tests into the MLS—the system that FAA  established for this purpose. MLS data include details about flight  tests, such as duration, whether the test involved complex  operations such as beyond the operator’s line of sight, and any  accidents or incidences that occurred. According to FAA officials,  MLS is used for collecting test site data—which will be used to,  among other things, inform the final report to Congress that is  required by statute.

Submitting data into FAA’s aforementioned COA application  processing system, which FAA uses to process COAs.

Submitting quarterly and annual reports to FAA, which summarize  activities completed by each test site, including research and  development efforts for users, milestones met and the key  challenges faced in undertaking activities.

According to FAA officials, their efforts related to the UAS test site  program have been primarily focused on meeting requirements such as  those related to test sites outlined in the 2012 Act. Among other things,  the 2012 Act required FAA to:

Establish test sites to provide a way to access airspace to conduct  research and development.

Develop standards and requirements for UAS flight operations at test  sites.

At the end of the test site pilot program, submit a final report to  Congress with findings and conclusions about projects facilitated  through the program.

In response to the 2012 Act’s requirements, as previously noted, FAA  established the test sites and developed requirements for how test sites  should conduct UAS flight testing.

As FAA has been focused on collaborating with the test sites and meeting  the 2012 Act’s and other requirements, agency officials have not  prioritized determining how to use data gathered from the sites to  advance UAS integration. To date, FAA has only used data from test sites  in a few cases to directly inform the agency’s UAS integration efforts. For  example, in one case, FAA used data from an ASSURE project  conducted at a test site to develop a noise certification standard; these  data were not from MLS. In another example, FAA officials told us that— as of February 2019—they were planning to use MLS and other test site  data to make a decision about an applicant that had submitted a request  to conduct UAS package delivery operations.

According to officials, FAA intends to use the data collected from test  sites to a greater extent in the future to further integration, such as in the  following ways:  In November 2018, FAA asked ASSURE to review test site data to  identify data FAA could use to approve safety cases. As previously  noted, FAA generally requires safety cases to be submitted as part of  any application to use a UAS operation that is not yet routinely  allowed in the national airspace due to risk, such as flights beyond the  operator’s line of sight. Safety cases include evidence of how the  applicant will address any risks that the new complex UAS operation  would introduce into the airspace, such as the risks of the UAS  abruptly losing power. According to FAA officials, this research was  initiated in December 2018 with a plan to complete it by March 2020.  According to these officials, the results of this research should help  the overall UAS integration effort. Specifically, the results may help  FAA officials to more clearly define the information UAS operators  should submit to demonstrate how the safety risks associated with  their proposed operation will be mitigated.

Officials indicated that FAA also intends to use MLS and other test  site data to continue developing, evaluating, and validating the  aforementioned UTM system.

FAA officials told us that while they have not fully leveraged test site data,  they are using other information from the test sites—such as information  shared in meetings—to support the agency’s efforts to integrate UAS into  the national airspace. According to FAA officials, the test site program  supports UAS integration not only by providing industry stakeholders with  an avenue for testing complex UAS operations and concepts, but also by  helping FAA officials stay informed about issues related to integration.  Specifically, these officials told us that the informal information sharing  that occurs in regular meetings between FAA officials and test site  representatives has been valuable. Through such informal exchanges,  FAA officials keep abreast of the various types of research being requested by industry stakeholders and challenges faced by such  stakeholders pursuing such research. For example, as noted previously,  test site representatives have used these meetings to discuss  challenges—such as related to dedicated spectrum—with FAA officials. In  addition, based on what FAA officials have observed at test sites, the  agency has been able to grant other airspace users more flexible  authorizations, for example COAs covering larger geographical areas.  Specifically, these agency officials told us that because they observed  that the test sites have been able to maintain an acceptable level of  safety after being allowed more flexibility in their aforementioned  nationwide blanket COAs, the agency felt confident enough to give more  flexibility to other airspace users with COAs for using complex UAS  operations.

FAA’s UAS integration plans specify the importance of not only collecting  data but also using the data to inform strategic planning efforts. FAA’s  publicly available plans state that FAA intended to use information from  the test site program to inform its UAS integration efforts. Specifically,  according to the 2018 UAS Integration Roadmap, the test site program  plays a critical role in UAS integration as one of the program’s goals is to  provide information so that FAA can determine technical and operational  trends that could support safety-related decision making for integration,  and develop policy and standards required to address new and novel  aspects of UAS flight operations. In addition, FAA’s Unmanned Aircraft  Systems Test Site Data Collection and Analysis document issued in  2016, indicates that by September 2016, FAA planned to analyze the  data to determine operational trends, communicate them via dashboards,  and share the collected and analyzed data with stakeholders. Further,  federal internal control standards state that agencies should use quality  information to achieve the agency’s objectives and support informed  decisions. Specifically, agencies should first identify what data are needed to achieve the entity’s objectives, then obtain the needed data  from internal and external sources in a timely manner, and finally process  and evaluate the obtained data into quality information that supports the  entity’s objectives.

While FAA has indicated plans to analyze and use test site data in the  future, it has not yet developed a data analysis plan to do so. FAA  officials told us that having an analysis plan for MLS data could be useful  and that—as of September 2019— they were considering creating such  as plan but had not taken steps to do so. According to FAA officials and  some test site representatives, and based on our review, some currently  collected data could be useful in informing integration efforts. Specifically,  FAA officials and two test site representatives told us that some MLS  data—for example on accidents and lost control links—could be useful.  For example, data on accidents and lost communication links could be  combined with other MLS data on the respective test flights—such as the  time of day, type of UAS being flown, and other factors—to determine  whether certain conditions or UAS models are at a greater risk of a crash  or other incident. According to FAA officials, this combined data could  theoretically help the agency to measure risk and to determine if there are  any factors that contribute to lost control links between the UAS and the  remote pilot in the flight testing environment. The results of such a data  analysis could help inform integration efforts, such as in developing  operational standards for UAS.

Without a plan for analyzing the data, FAA could miss opportunities to  leverage what was intended to be a cornerstone of the test site  program—information to help FAA move UAS further toward full  integration into the national airspace. Having such an analysis plan could  help FAA articulate how the agency will use test site data more in the  future and identify other data that are within the agency’s authority to  request from test sites that would help inform integration. Representatives  from three test sites told us that their staff currently collects other data  that FAA is not collecting but which could help to inform the agency’s  UAS integration efforts. Based on our review of test sites’ annual reports  to FAA, for instance, all test sites have been involved in facilitating test  flights of UAS operations beyond the operator’s line of sight. FAA may be  able to use data from such flight tests as it develops standards for  allowing these types of UAS operations on a routine basis in the national  airspace. Further, the National Academy of Sciences reported in 2018  that FAA has underutilized the test sites because it has not determined  which test site data could inform the agency’s risk assessments for UAS  (which FAA conducts before allowing any new complex UAS operation to  be used on a routine basis) nor collected that specific data from test  sites.

FAA Is Publicly Sharing Limited Information about How the Test Site Program Informs the Agency’s UAS Integration Efforts

FAA provides limited information to the public, including stakeholders and  test site users, about how the research being conducted at test sites  helps to inform FAA’s UAS integration efforts. FAA officials point to two  main public efforts related to the test sites program:

FAA’s 2018 UAS Integration Roadmap, described earlier, includes a  high-level overview of how the test sites program informs the agency’s  integration efforts. For example, it states that test sites provide  information that FAA can use to determine technical and operational  trends that could support safety-related decision making. However, it  does not provide any information about, for example, how the  research at test sites directly relates to FAA’s next planned phases of  integration.

FAA’s UAS Test Sites website is the agency’s main public outreach  effort, and provides information such as links to the websites of the  test sites. However, in examining the website, we found little  description of how this program relates to FAA’s broader integration  plans and no discussion of desired outcomes from the research under  way at test sites. In contrast, the websites for two other UAS research  efforts that FAA is involved in—the UTM program and DOT’s IPP— have program descriptions that include the purpose of the program,  and some intended research outcomes. These two program  descriptions make it relatively easy for the reader to understand how  those programs fit into FAA’s broader UAS integration efforts. See  figure 6, which shows the program descriptions on FAA’s respective  websites for the test site program and the IPP.

FAA also compiles some information on test sites that is not publicly  available. For example, FAA staff annually compile information about the  types of research conducted at test sites and present it in the Test Sites  Fact Book, which links the information to key capabilities needed for the  incremental integration of UAS into the national airspace. However, this  document is only available to FAA staff and, according to officials,  contains some data that test site users could deem proprietary. FAA  officials told us that they also plan to submit the aforementioned final  report to Congress on the test site program, which is currently due in late  2023. According to these officials, however, this report is not intended to  be made public.

All test site representatives and many users in our review (13 of 18)  reported that publicly available information on research efforts underway  at test sites is limited. Many users we spoke to (11 of 18) stated that  FAA should include more information about the test sites on its website,  and in FAA’s planning documents, such as the 2018 UAS Integration  Roadmap. These representatives and users also told us improved FAA  communication could increase the UAS stakeholders’ awareness of test  sites’ capabilities, expertise, and services, and their understanding about  how the program fits into FAA’s broader integration efforts.

According to FAA, collaboration and cooperation across industry and  government is important for UAS integration—a complex endeavor  involving multiple stakeholders from different sectors. As FAA’s 2018  UAS Integration Roadmap states, given the large scale of the UAS  integration effort, FAA must rely on crucial relationships across  government and industry to ensure its integration efforts are harmonized  and consistent. It further states that all the work needed to resolve  collective challenges requires collaboration between partners at local,  state, tribal, and national levels as well as with partners across the UAS  stakeholder community. In addition, federal internal control standards  and leading practices for reporting on research and development  activities emphasize the importance of making the status of such activities  transparent to stakeholders. Specifically the federal internal control  standard for communicating information calls on federal agencies to  externally communicate quality information so that external parties can  help the entity achieve its respective objectives. Further, this standard  suggests that agencies should select appropriate methods to  communicate externally, taking into consideration factors such as the  intended audience and the availability and ease of access to the  information. In addition, as we have reported, leading practices for  reporting on research and development efforts include clearly  communicating the status of such efforts to the public and stakeholders.

For example, in a 2017 report about FAA’s management of its aviation  research and development portfolio—which includes UAS research  efforts—we found that FAA could more fully adhere to leading practices if  it provided more information for Congress and other stakeholders, such  as on the status of various research and development activities. We  noted that with more complete and transparent information, Congress and  industry and other stakeholders are better able to make informed  decisions. In another example, in several reports on FAA’s  implementation of the Next Generation Air Transportation System— another complex endeavor involving coordination with industry and other  stakeholders—we emphasized the importance of sharing information  about the status of various projects with stakeholders whose participation  will be essential to the progress of the overall effort.

FAA officials told us that they were wary of providing more public  information about the test sites, based on concerns about potentially  being perceived to be promoting the designated test sites and concerns  about sharing data that could be proprietary. For example, officials told us  that when potential test site clients approach FAA, they simply direct  these potential clients to the FAA’s UAS Test Sites website. The officials  told us that they do not wish to be seen as promoting or advertising one  of the FAA-designated UAS test sites over the others, because such  promotion would conflict with FAA’s role as a regulator. They also said  that FAA wants to avoid suggesting that operators seeking to research  complex UAS operations are required to contract with a designated test  site. They noted that the decision about whether or not to use a  designated test site should be left to the potential client. In addition, FAA  officials expressed concerns about sharing any information that the test  site users could deem to be proprietary, such as information about their  research projects currently underway. For example, the officials noted  that some test site users do not want to be identified as such.

In our assessment, however, it would be possible for FAA to share more  information publicly about how the test site program fits into the agency’s  broader UAS integration effort without promoting any particular test site or  sharing any proprietary information. For example, some context in the  Test Sites Fact Book could be informative because it links research  underway at test sites to FAA’s integration plans. This book includes a  section on current test site research with examples that, if shared, could  help increase stakeholders’ understanding of how FAA could use the  research being conducted at test sites to inform its decisions. This section  indicates that test sites are involved in research aimed at, for example:

Advancing UAS standardization, meaning the FAA and all the test  sites working together to advance the industry from a systems  perspective to develop standardized UAS training, maintenance, and  safety risk mitigation. Data from such research could help inform FAA  decisions such as, for example, setting standards for drone spacing  and mitigating risks.

Using UAS for wildfire operations, including test sites and users— such as emergency response agencies—finding effective ways to use  UAS to respond to such situations. Data from such research could  help FAA improve, for example, its response time when an  emergency COA is requested by such agencies.

Such additional information, if shared, could help FAA to clearly  demonstrate to the wider audience of UAS stakeholders that the agency  is fostering research through test sites that directly relates to its UAS  integration plans. As noted above, the test site users we interviewed told  us they were conducting research at test sites related to FAA’s upcoming  phases of its UAS integration plan, including research on large cargo and  passenger operations. Although some UAS stakeholders—such as users  of test sites—may currently be aware of the research underway at test  sites, the audience for UAS integration is larger and includes others such  as those from the information technology and agricultural industries, and  local government agencies whose stakeholders may be less familiar with  FAA’s efforts.

Further, with more accessible information on how research at the test  sites relates to FAA’s UAS integration efforts, more stakeholders may  choose to use a test site to conduct their own research. Given that one of  the primary goals of the test site program is to provide information to FAA  to help the agency develop the policies and standards required to  address new and novel aspects of UAS flight operations, having more  test site users could help the agency achieve this goal by making more  data available to FAA. As noted previously, many selected users we  interviewed told us that using a test site provided a significant benefit for  advancing their entity’s UAS research and development efforts. However,  some UAS stakeholders who could benefit from a test site’s assistance— such as those outside of the aviation industry seeking to submit a safety  case to FAA for approval of complex UAS operations—may not currently  be aware of the option for conducting research through a test site. For  instance, a stakeholder interested in conducting research involving, for  example, using UAS for small package delivery, may be unaware that test  sites have already helped to facilitate such research for their users. FAA  officials told us that stakeholders outside of the aviation industry can  particularly benefit from a test site’s expertise since they may be less  familiar with FAA’s processes for approving UAS operations on a case- by-case basis. All test site representatives and some users in our review  told us that if FAA communicated more clearly about the role of the test  site program in the overall UAS integration effort, more stakeholders  would likely leverage the test sites.

FAA’s designated UAS test sites provide significant benefits to the UAS  industry, offering their users a variety of services, with minimal operating  investment from FAA. Many users in our review told us that their decision  to work with a test site proved invaluable in helping achieve their  respective goals. As FAA proceeds with its plans to incrementally  integrate UAS into the national airspace—a large effort requiring  collaboration with many stakeholders—the agency could benefit from  better leveraging all of its available resources. According to FAA,  additional research and development work—including data on UAS  operations—is needed to inform its decisions as it allows for more  complex UAS operations to be routinely used in the national airspace.

UAS stakeholders working with FAA test sites are testing complex UAS  operations and various capabilities identified by FAA as needed to inform  integration policies and rules moving forward. However, without a plan for  analyzing the test site data, FAA could miss opportunities to better use  the data to inform the overall UAS integration effort, such as by applying  the data to inform UAS operational standards. Having such an analysis  plan could help FAA articulate how the agency will use test site data more  in the future and identify other data that are within the agency’s authority  to request from test sites that would help inform integration. In addition,  by sharing more information about how the program relates to FAA’s  integration efforts, the broader community of UAS stakeholders may have  a greater awareness of the types of research and testing being conducted  at test sites and thus be better able to participate in the effort. Further,  without more accessible information, such as examples of how research  underway at test sites aligns with FAA’s planned phases of UAS  integration, some UAS stakeholders may not be aware of their options for  pursuing research through a test site, thus potentially limiting the  usefulness of the test site program for UAS stakeholders and for FAA.

We are making the following two recommendations to FAA:

The Administrator of FAA should develop a plan for analyzing  currently-collected UAS test site data to determine how they could be  used to advance UAS integration, and whether the collection of any  additional test site data, within the agency’s authority to request, could  be useful for informing integration. (Recommendation 1)

The Administrator of FAA should publicly share more information on  how the test site program informs integration while continuing to  protect information deemed proprietary. This information could be  shared, for example, on the agency’s UAS Test Sites website.  (Recommendation 2)

We provided a draft of this report to DOT and NASA for their review and  comment. In its written comments, reproduced in appendix II, DOT  partially agreed with the first recommendation and agreed with the  second recommendation. FAA also provided technical comments, which  we incorporated as appropriate. NASA officials reviewed our draft, but did  not have any comments.

FAA partially agreed with the first recommendation to develop a plan for  analyzing test site data, noting a concern about using such a plan to  determine if the collection of any additional test site data could be useful  for informing integration. Specifically, FAA noted that the agency cannot  require test sites to share data from their privately contracted users, other  than the data required for the test sites’ COAs or for their OTAs with FAA.  FAA also noted a concern that our draft report incorrectly assumes that  the data collected through the test site program are adequate to meet  FAA’s UAS integration needs when this program is limited in the data that  can be collected. However, our report states that the test site program is  only one of several sources of data to inform FAA’s future decisions  regarding UAS integration, and that a data analysis plan could help FAA  determine whether any additional data could be useful for informing  integration. To address FAA’s comments, we added language to our  recommendation to clarify that the consideration of potential additional  data would be for data that are within the agency’s authority to request  from test sites, such as through the OTAs. We continue to believe that  implementing this recommendation would enable the agency to better  leverage test site research and data to inform its decisions related to UAS  integration.

FAA agreed with our second recommendation to share more information  on how the test site program informs the agency’s UAS integration effort.  However, FAA stated that the agency’s integration plans and Test Site  Fact Book cannot be made publicly available due to future rulemaking  and proprietary information contained in these documents. We  acknowledge in our report that these documents could include information  that test site users deem proprietary. We include in our recommendation  that FAA should continue to protect any information deemed proprietary  while making information about the test site program’s contribution to  UAS integration publicly available.

We are sending copies of this report to the appropriate congressional  committees, the Secretary of the Department of Transportation, and other  interested parties. In addition, the report is available at no charge on the  GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-2834 or krauseh@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix III.

Appendix I: List of Unmanned Aircraft Systems (UAS) Test Sites and Stakeholders Whose Representatives GAO Interviewed

Federal Aviation Administration Designated UAS Test Sites

Entity  Griffiss International Airport (New York) - Northeast UAS Airspace Integration Research  Alliance  New Mexico State University – Physical Science Laboratory  North Dakota Department of Commerce – Northern Plains UAS Test Site  State of Nevada – Nevada Institute for Autonomous Systems  Texas A&M University-Corpus Christi – Lone Star UAS Center of Excellence and Innovation  University of Alaska Fairbanks – Alaska Center for UAS Integration  Virginia Polytechnic Institute and State University – Mid-Atlantic Aviation Partnership  Agricultural Research Service, United States Department of Agriculture  Alliance for System Safety of UAS through Research Excellence, Mississippi State  University  Association for Unmanned Vehicle Systems International  JHW Unmanned Solutions, LLC  Massachusetts Institute of Technology Lincoln Lab  National Emergency Response and Recovery Training Center, Texas A&M Engineering  Extension Service  Project Vahana, Airbus A3  Vanilla Aircraft (now Vanilla Unmanned)

Appendix II: Comments from the Department of Transportation

Appendix III: GAO Contact and Staff Acknowledgments

Heather Krause at (202) 512-2834 or krauseh@gao.gov.

In addition to the individual named above, Vashun Cole (Assistant  Director); Jessica Bryant-Bertail (Analyst-in-Charge); Jon Felbinger;  Camilo Flores; Richard Hung; Josh Ormond; Amy Rosewarne; Alexandra  Rouse; Kelly Rubin; Marc Schwartz; and Larry Thomas made key  contributions to this report.

Drones have the potential to deliver packages, monitor crops, and provide many other significant social and economic benefits in the United States.

The Federal Aviation Administration, in coordination with industry, is working on safely integrating drones into the national airspace with manned aircraft. FAA has 7 designated drone test sites, which have facilitated about 15,000 drone research flights since 2015.

FAA could make better use of the data it collects from the test sites. We recommended FAA develop a data analysis plan and share more information publicly about how test site research relates to the agency’s drone integration plans.