Oregon Tells FCC: Build Drone Test Sites in Mountains, Not Just Labs

The Oregon Department of Aviation (ODAV) has drafted an eight-point response to the Federal Communications Commission’s April 1 public notice on “Unleashing American Drone Dominance” (GN Docket No. 26-74), and it reads less like a bureaucratic comment filing and more like a field manual from a state that actually flies drones in hard terrain. ODAV Director Kenji Sugahara shared the draft publicly on LinkedIn, inviting other stakeholders to adopt its positions or offer feedback before the May 1 comment deadline.

Oregon’s filing stands out because it names three specific locations the state has already identified for new UAS innovation zones: one in the Cascades near Oakridge, another along the Columbia River Gorge between Oregon and Washington, and a third in southeast Oregon. That specificity matters. Most comment filings ask the FCC to “consider” things. Oregon is telling the commission where to put them.

Oregon identifies three drone test corridors in real terrain

The draft filing argues that the FCC’s current experimental licensing framework under Part 5 was built for campus labs and small research sites, not for the kind of corridor-based, mobile UAS testing that public-interest operations demand. Oregon wants a UAS-specific experimental license pathway with broader geographic authority, longer terms, faster modifications, and multi-band testing under a single authorization.

The three proposed test areas are not random pins on a map. The Cascades site near Oakridge sits in mountainous, wildfire-prone terrain where line-of-sight obstruction and weather variability are constant factors. The Columbia River Gorge corridor crosses state lines between Oregon and Washington, testing cross-jurisdictional coordination. Southeast Oregon offers the sparse population and open terrain where interference risk is low but operational value for emergency logistics and rural access is high.

Oregon’s argument is direct: the environments that matter most for wildfire response, infrastructure inspection, and medical delivery are mountain passes, forested regions, and remote road networks. Testing drones in flat, controlled academic settings produces data that does not transfer to those conditions. The filing also calls on the FCC to coordinate with the FAA and NTIA to enable corridor-based testing that supports recurring operations rather than one-off demonstrations.

Spectrum access and the 5030-5091 MHz band

On spectrum, Oregon backs the FCC’s push toward the 5030-5091 MHz band for UAS control links and wants near-term measures that let trusted operators use that band now, while longer-term frameworks develop. The state argues that reliance on unlicensed bands alone is not a long-term answer for safety-critical operations. Those frequencies are susceptible to interference and were never designed for precision control links, a problem we detailed in our coverage of the FCC’s public notice last week.

The filing urges the FCC to evaluate how different bands can support different functions within a UAS architecture. Command and control links need reliability above all else. Payload data, surveillance feeds, and supplemental connectivity have different requirements. Oregon wants the FCC to match spectrum allocation to mission type rather than applying blanket rules. And it makes an explicit priority call: wildfire response, emergency management, and rural logistics should not have to wait behind broader commercial spectrum debates.

Oregon walks a careful line on trusted deployment and the DJI ban

Section V of the filing is the most politically loaded. Oregon acknowledges national security concerns about foreign-produced drones but asks the FCC to preserve continuity of public-service operations and provide a “simple risk appropriate waiver process” during the transition.

This is the same state that compiled the NASAO white paper documenting 467 restricted drones across 25 states and up to $2 billion in national exposure from the FCC’s December 2025 Covered List action. Oregon itself had just one compliant drone out of 22 in its fleet when that survey was published. The filing’s language is measured, but the subtext is clear: encouraging domestic alternatives is not enough when agencies cannot buy them yet.

The draft states explicitly that the FCC should not frame the issue as if promoting domestic systems alone is sufficient. Trusted deployment depends on practical equipment access, certification pathways, technical support, and coordination with standards development organizations. Security and operability, Oregon argues, must move together.

Counter-UAS testing separated from mitigation authority

Oregon’s seventh recommendation draws a line that few other filings are likely to draw this clearly. The state asks the FCC to distinguish between detection, tracking, identification, situational awareness, communications testing, and mitigation. Those are six separate functions, and Oregon argues they should not be conflated in regulation.

The filing does not ask for expanded mitigation authority for state or local actors. It does ask the FCC to remove the regulatory uncertainty that slows development of detection and awareness technologies. Oregon suggests that both detection and mitigation testing could be appropriate uses for innovation zones, keeping the testing contained while allowing the technology to mature.

The remaining three recommendations

Oregon’s other three sections round out the filing. Section IV asks the FCC to modernize coordination and notification procedures that were designed for static, ground-based communications and do not fit mobile, low-altitude drone operations. Section VI calls for a centralized FCC information resource where UAS and counter-UAS operators can find licensing pathways, equipment authorization rules, and coordination requirements in one place instead of piecing them together across multiple bureaus. Section VIII argues that civil, public-safety, and state-led operations should remain central in federal spectrum policy, not sidelined behind defense and commercial priorities. Oregon recommends the FCC engage with state aviation agencies through the National Association of State Aviation Officials (NASAO) as it develops its UAS rules.

The filing’s conclusion puts the point bluntly: “Rural and mountainous terrain, wildfire-prone regions, infrastructure corridors, and medically underserved communities should not be afterthoughts in this conversation. Rather, they should be central to it.”

DroneXL’s Take

I have known Kenji Sugahara since before he took the ODAV director role in 2023, back when he was running the Drone Service Providers Alliance with Vic Moss. He served on the FAA Remote ID Aviation Rulemaking Committee, holds one of the earliest Remote ID patents in the country, and sat on the FAA’s BVLOS Aviation Rulemaking Committee. When he puts his name on a filing, it carries weight because he has spent years on both sides of the regulatory table.

What makes this filing different from the dozens of other comments the FCC will receive by May 1 is that Oregon is not asking for abstract reform. It has three test site locations picked out. It has the NASAO data showing what the current framework costs. And it has a director who personally understands what drone operators need because he was one. That combination of operational credibility and specific proposals is rare in federal comment proceedings, where most filings read like they were written by lawyers who have never launched a drone.

The FCC will receive hundreds of comments on this docket. Most will fall into two camps: industry asking for fewer restrictions, and security hawks asking for more. Oregon’s filing occupies a third lane, the one that says the current framework is failing the agencies that actually use drones to serve the public. Expect other state aviation directors to follow Oregon’s lead through NASAO. If five or more states submit coordinated comments echoing Oregon’s positions by May 1, the FCC will have a harder time treating state-level operations as an afterthought in its final rules.

DroneXL uses automated tools to support research and source retrieval. All reporting and editorial perspectives are by Haye Kesteloo.