UNMANNED AIRCRAFT 

SYSTEMS

Continued Coordination, 

Operational Data, and 

Performance Standards 

Needed to Guide Research 

and Development

Statement of Gerald L. Dillingham, Ph.D.

Director, Physical Infrastructure Issues

Testimony 

Before the Subcommittee on Oversight, 

Committee on Science, Space, and 

Technology, House of Representatives

For Release on Delivery 

Expected at 10:00 a.m. EST

Friday, February 15, 2013

GAO-13-346T

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-346T, a testimony 

before the Subcommittee on Oversight, 

Committee on Science, Space, and 

Technology, House of Representatives 

February 15, 2013

UNMANNED AIRCRAFT SYSTEMS

Continued Coordination, Operational Data, and 

Performance Standards Needed to Guide Research 

and Development

Why GAO Did This Study

Unmanned aircraft systems are aircraft 

and associated equipment that do not 

carry a pilot aboard, but instead 

operate on pre-programmed routes or 

are manually controlled by pilotoperated ground stations. Although 

current domestic uses of UAS are 

limited to activities such as law 

enforcement, forensic photography, 

border security, and scientific data 

collection, UAS also have a wide range 

of other potential commercial uses. 

According to an industry forecast, the 

market for UAS is expected to grow

and could be potentially worth $89 

billion over the next decade. 

Concerned with the pace of UAS 

integration into the national airspace, 

Congress established specific 

requirements and set deadlines for 

FAA in the 2012 FAA Modernization 

and Reform Act (the 2012 Act).

This testimony discusses 1) the roles 

and responsibilities of and coordination 

among federal agencies and other 

UAS stakeholders involved in 

integrating UAS, 2) FAA’s progress in 

complying with the 2012 Act’s UAS 

requirements, and 3) research and 

development efforts by FAA and other 

entities to address challenges for

safely integrating UAS. 

This testimony is based on a 2012 

GAO report. In past work, GAO 

analyzed FAA’s efforts to integrate 

UAS into the national airspace, the role 

of other federal agencies in achieving 

safe and routine integration, and 

research and development issues. 

GAO also conducted selected 

interviews with officials from FAA and 

other federal agencies, industry, and 

academic stakeholders.

What GAO Found

While Congress has tasked FAA to lead the effort of safely integrating unmanned 

aircraft systems (UAS) in the national airspace, several federal and other entities 

also have a role. FAA has established various mechanisms to facilitate 

collaboration with these entities. For example, FAA has entered into formal 

agreements with the Department of Defense (DOD) and the National Aeronautics 

and Space Administration (NASA) on obtaining appropriate safety data and

coordinating research and development, respectively. FAA has also involved 

industry stakeholders and academia in the development of standards and 

research for UAS operations. FAA recently created the UAS Integration Office, 

within FAA, to coordinate all intra-agency UAS efforts and provide organizational 

leadership. Continued collaboration among UAS stakeholders will be critical to 

minimizing duplication of research and addressing implementation obstacles. 

While FAA has made progress toward meeting the 2012 Act’s requirements, as 

of January 2013, it has missed several of its deadlines. FAA continues to face 

challenges, with many of its efforts still in process. For example, the 

establishment of six test ranges for UAS operations, as required by the 2012 Act, 

is being delayed due to privacy concerns. Meeting the 2012 Act’s requirements

moving forward will require continued collaboration and significant work for FAA. 

In September 2012, GAO recommended that FAA incorporate mechanisms in its 

planning that allow for regular monitoring to assess its progress. Such 

mechanisms can help FAA identify what has been achieved and what remains to 

be done.

Research and development efforts are under way to mitigate obstacles to safe 

and routine integration of UAS into the national airspace. However, these 

research and development efforts cannot be completed and validated without 

safety, reliability, and performance standards, which have not yet been 

developed because of data limitations. GAO previously reported that FAA has 

not utilized the operational data it already possesses, such as data provided by 

the DOD. 

Examples of UAS

View GAO-13-346T. For more information, 

contact Gerald L. Dillingham at (202) 512-

2834 or dillinghamg@gao.gov. 
Page 1 GAO-13-346T 

United States Government Accountability Office

Washington, DC 20548

Chairman Broun, Ranking Member Maffei, and Members of the 

Subcommittee:

I appreciate the opportunity to testify on several efforts to allow 

unmanned aircraft systems (UAS) to safely and routinely fly in the 

national airspace. UAS are aircraft and associated equipment that do not 

carry a pilot aboard, but instead operate on pre-programmed routes or 

are manually controlled by following commands from pilot-operated 

ground control stations. Figure 1 shows the components of a UAS, 

including the airframe, power plant, communications links, and ground 

control station. UAS are typically described in terms of weight, endurance, 

purpose of use, and altitude of operation. For the purposes of this 

testimony, we consider UAS in two broad categories: a small UAS is less 

than 55 pounds, while a large UAS is 55 pounds or more.1

 

1

We have distinguished between small and large aircraft because a number of rules and 

requirements apply specifically to aircraft that weigh less than 55 pounds, which we 

discuss later in the report. According to an industry association, small UAS are expected 

to comprise the majority of UAS that will operate in the national airspace. 

 
 

Page 2 GAO-13-346T 

Figure 1: Conceptual Rendering of Unmanned Aircraft System

Current domestic use of UAS is limited to activities such as law 

enforcement, search and rescue, forensic photography, border security, 

weather research, and scientific data collection. UAS also have potential 

commercial uses that include pipeline, utility, and farm-fence inspections; 

vehicular traffic monitoring; real-estate and construction-site photography; 

relaying telecommunication signals; film industry production; and fishery 

protection and monitoring. Concerned with the pace of progress toward 

integrating UAS into the national airspace, in February 2012, Congress 

established specific requirements and set deadlines for FAA to expedite 

UAS integration in the FAA Modernization and Reform Act (the 2012 

Act).2 In September 2012, we reported that FAA had taken steps to meet 

these requirements and deadlines, and raised concerns about when UAS 

 

2

Pub. L. No. 112-95, §§ 332 – 334, 126 Stat. 11 (2012).
 

Page 3 GAO-13-346T 

integration in the national airspace will be achieved.3 We recommended 

that FAA incorporate regular monitoring of its efforts to measure progress 

toward fulfilling its statutory requirements. We also reported on a variety 

of obstacles that still must be overcome before UAS might be safely 

integrated in the national airspace.

My statement today is based on our September 2012 report, updated as 

appropriate, and discusses 1) the roles and responsibilities of and 

coordination among federal agencies and other UAS stakeholders 

involved in integrating UAS into the national airspace; 2) FAA’s progress 

in complying with the 2012 Act’s UAS requirements; and 3) research and 

development efforts by FAA and other entities to address challenges for 

safely integrating UAS. We reviewed and analyzed documents and 

interviewed relevant government, academic, and private-sector entities, 

as well as federal UAS users. More detailed explanations of the methods 

used to conduct our work can be found in the full report referenced 

above. We performed our work 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.

Currently, FAA authorizes all domestic military; public (academic 

institutions, federal, state, and local governments including law 

enforcement organizations); and civil (private sector entities) UAS 

operations on a limited basis after conducting a case-by-case safety 

review. Federal, state, and local government agencies must apply for 

Certificates of Waiver or Authorization (COA), while civil operators must 

apply for special airworthiness certificates in the experimental category. 

Because special airworthiness certificates do not allow commercial 

operations, there is currently no means for FAA to authorize commercial 

UAS operations.

Since FAA started issuing COAs in January 2007, 1,428 COAs have 

been issued. At present, under COA or special airworthiness certification, 

 

3

GAO, Unmanned Aircraft Systems: Measuring Progress and Addressing Potential 

Privacy Concerns Would Facilitate Integration into the National Airspace System, 

GAO-12-981 (Washington, DC: Sept. 14, 2012).

Background 
 

Page 4 GAO-13-346T 

UAS operations are permitted for specific time frames (generally 12 to 24 

months); locations; and operations. So, one agency can be issued 

multiple COAs to operate one UAS for the same purpose. In 2012, FAA 

issued 391 COAs to 121 federal, state, and local government entities 

across the United States, including law enforcement entities as well as 

academic institutions (see fig. 2).4

Figure 2: Entities with COAs Approved from January 1, 2012, through December 31, 

2012

Notes: DOD=Department of Defense, NASA=National Aeronautics and Space Administration, 

LEAs=Local Law Enforcement Agencies, DHS=Department of Homeland Security, DOI=Department 

of the Interior, and DOE=Department of Energy.

According to an industry forecast, the market for government and 

commercial use of UAS is expected to grow, with small UAS having the 

greatest growth potential.5 This forecast estimates that the worldwide 

 

4

These COA figures provided by FAA may not represent the number of active COAs 

because COAs issued prior to January 2012 may still be active and COAs issued during 

2012 may have already expired.

5

Teal Group Corporation, World Unmanned Aerial Vehicle Systems (Fairfax, VA: 2012).
 

Page 5 GAO-13-346T 

UAS market could be potentially worth $89 billion over the next decade. 

The majority of this estimate is for military-type products (primarily the 

U.S. military) with the associated research and development for 

production estimated to be $28.5 billion over the next 10 years. As 

smaller UAS are expected to continue to improve in technology and 

decrease in price, their prevalence in the national airspace is expected to 

increase. The forecast also indicates that the United States could account 

for 62 percent of the world’s research and development investment for 

UAS technology over the coming decade.

Congress has tasked FAA to lead the effort of safely integrating UAS into 

the national airspace, but several other federal agencies—such as the 

Department of Defense (DOD), Department of Homeland Security (DHS), 

and the National Aeronautics and Space Administration (NASA)—also 

have a role. While DOD uses UAS for training and operational missions, 

DHS for border patrol, and NASA for scientific research, each agency 

provides FAA with safety, reliability, and performance data through the 

COA process. These agencies also participate in UAS integration forums 

as discussed later in this section. Table 1 provides an overview of key 

federal UAS stakeholders and their roles in integrating UAS.

Table 1: Key Federal UAS Stakeholders and Their Roles Integrating UAS into the National Airspace

Key stakeholders UAS integration role 

Federal Aviation Administration (FAA) FAA’s UAS Integration Office is responsible for ensuring that UAS operate safely in the 

national airspace. 

Department of Defense (DOD) DOD provides FAA with UAS operational and safety data, as well as research and 

development support. 

National Aeronautics and Space 

Administration (NASA) 

NASA provides research and development and testing on UAS integration efforts. 

Department of Homeland Security (DHS) DHS’s Customs and Border Patrol has provided flight demonstrations to FAA’s Next 

Generation Air Transportation System (NextGen) Office. 

General Services Administration (GSA) The General Services Administration (GSA) is responsible for tracking the federal 

government’s UAS inventory. Federal agencies that own or lease UAS report their 

UAS inventory, cost and utilization data to GSA. 

Department of Justice (DOJ) DOJ’s National Institute of Justice is responsible, in part, for assisting the technology 

needs—including UAS—of local, state, and tribal law enforcement agencies. 

Source: GAO analysis of FAA data.

FAA has established various mechanisms to facilitate collaboration with 

its partner agencies, and private sector entities to safely integrate UAS 

(see table 2). For example, given its unique role in managing partnerships 

among federal agencies for the Next Generation Air Transportation 

FAA Is Responsible 

for Leading 

Coordination Efforts 

across Agencies and 

Industry to Achieve 

UAS Integration
 

Page 6 GAO-13-346T 

System (NextGen), FAA’s Joint Planning and Development Office (JPDO) 

was tasked by the Office of Management and Budget to, in conjunction 

with partner agencies, develop a strategic interagency UAS Research, 

Development, and Demonstration Roadmap.6 This roadmap provides a 

framework for interagency and private sector coordination on UAS 

research and development efforts. Several working groups have also 

been formed, such as the UAS Executive Committee, to facilitate 

collaboration between agencies. FAA has also entered into 

memorandums of understanding (MOU) with some of these federal 

agencies. FAA signed MOUs with NASA and DOD regarding research 

and development and the availability of safety data, respectively. FAA has 

also involved industry stakeholders and academia through the UAS 

Aviation Rulemaking Committee and RTCA SC-203. For example, the 

RTCA SC-203 (a standards-making body) is developing safety, reliability, 

and performance standards for UAS operations.

 

6

NextGen is a complex undertaking that requires acquiring new integrated air traffic 

control systems; developing new flight procedures, standards, and regulations; and 

creating and maintaining supporting infrastructure to create a more automated aircraftcentered, satellite-based air transportation system. JPDO’s primary responsibility is for 

overseeing and coordinating NextGen research activities within the federal government 

and ensuring that new technologies are used to their fullest potential in aircraft and the air 

traffic control system. 
 

Page 7 GAO-13-346T 

Table 2: Examples of UAS Collaboration across Agencies or in Industry 

Forums for collaboration UAS integration role

JPDO FAA’s JPDO provides a framework for UAS stakeholders to collaborate and coordinate 

on their UAS integration efforts. 

UAS Executive Committeea The UAS Executive Committee–composed of senior executives from federal agencies 

including FAA, DOD, NASA, and DHS–is responsible for identifying solutions to the 

range of technical, procedural, and policy concerns arising from UAS integration into 

domestic airspace. 

 

UAS Aviation Rulemaking Committeeb The UAS Aviation Rulemaking Committee was chartered in 2011 to provide a 

mechanism for industry and academic stakeholders as well as other federal, state, and 

local government entities to provide recommendations and standards to FAA on issues 

related to UAS integration. 

 

RTCA SC-203 RTCA is a private, not-for-profit organization consisting of industry experts. SC 203 is 

responsible for developing consensus-based recommendations and standards regarding 

UAS communications, navigation, surveillance, and air traffic management system 

issues that are provided to FAA. 

c

ASTM International Committee F38 ASTM International Committee F38 is a private organization, consisting of industry 

experts that are responsible for developing standards and consensus-based 

recommendations to FAA for small UAS integration into the national airspace and 

worldwide. 

d

Source: GAO analysis of FAA data.

a

The UAS Executive Committee was formed as a result of the National Defense Authorization Act 

(NDAA) for Fiscal Year 2010 (Pub. L. No. 111-84, 123 Stat. 2190 (2009)). Section 935 of 2010 NDAA 

states that “The Secretary of Defense and the Secretary of Transportation shall, after consultation 

with the Secretary of Homeland Security, jointly develop a plan for providing expanded access to the 

national airspace for unmanned aircraft systems of the Department of Defense” and requires that the 

Executive Committee members to provide Congress with, among other things, a communication plan, 

specific milestones for expanded access to the national airspace, and that the Committee report on 

their efforts. 

b

FAA also chartered a small UAS Aviation Rulemaking Committee in 2008, which made 

recommendations for the standards and regulations for the operation of small UAS in the national 

airspace.

c

RTCA, formerly the Radio Technical Commission for Aeronautics, serves as a federal advisory 

committee, and its recommendations are the basis for a number of FAA’s policy, program, and 

regulatory decisions.

d

ASTM International, formerly known as the American Society for Testing and Materials, works to 

deliver the test methods, specifications, guides, and practices that support industries and 

governments worldwide.

FAA also has agreements with a range of industry, federal research 

entities, universities, and international organizations to conduct research. 

These research and development agreements, known as Cooperative 

Research and Development Agreements and International Agreements, 

typically require the agency, organization, or company to perform types of 

research and provide FAA with the data in exchange for funding. For 

example, in 2009 FAA established an agreement with the European 

Union to initiate, coordinate, and prioritize the activities necessary for 

supporting the development of provisions required for the evolution of 
 

Page 8 GAO-13-346T 

UAS to full recognition as a legitimate category-of-airspace user.7 In 

addition, FAA partners with federally funded research and development 

centers on UAS integration efforts.8

Within FAA, steps have also been taken to increase collaboration and 

provide the organizational leadership needed to safely accelerate UAS 

integration. FAA recently created the UAS Integration Office under one 

executive to provide stable leadership and focus on the FAA UAS 

integration efforts.9 The office will coordinate all intra-agency collaboration 

efforts. At this time, some UAS responsibilities are being handled in other 

offices throughout FAA. For example, some of the research and 

development efforts and analysis of operation and safety data are being 

performed by the Air Traffic Office and the Accident, Investigation, and 

Prevention Office, respectively. The UAS Integration Office reports 

directly to the Director of the Flights Standards Service, which provides 

visibility for the office. At this time, several planning efforts are under way 

in the office. However, because the reorganization has only recently been 

implemented, it remains unclear whether the office will provide the 

support needed to guide a collaborative effort given the complexities of 

safely integrating UAS into the national airspace.

While collaboration mechanisms have been developed to help facilitate 

UAS integration into the national airspace, continued collaboration among 

UAS stakeholders will be critical to minimizing duplication of research and 

addressing implementation obstacles. For example, as we previously 

reported in our September 2012 report, federal agencies have not yet 

stepped forward to proactively address the growing concerns regarding 

the potential security and privacy implications of UAS.10 We 

recommended that DOT, DHS, and the Attorney General initiate 

 

7

FAA’s International Agreements include ones with the Netherlands, the German 

Aerospace Center, and the European Union. 

8

FAA’s Federally Funded Research and Development Centers are located at MITRE, 

MIT’s Lincoln Lab, and the Air Force Research Lab. 

9

The UAS Integration Office was formally created in January 2013. However, work was 

being performed on UAS integration prior to operations being formalized. For example, the 

FAA appointed the Executive in March 2012.

10The Congressional Research Service has issued a report assessing the use of UAS 

under the Fourth Amendment. Congressional Research Service, Drones in Domestic 

Surveillance Operations: Fourth Amendment Implications and Legislative Responses, 

R42701 (Washington, D.C.: September 2012). 
 

Page 9 GAO-13-346T 

discussions, prior to the integration of UAS into the national airspace, to 

explore whether any actions should be taken to guide the collection and 

use of UAS-acquired data. As we discuss later in this statement, FAA and 

DOD will need to continue to work together to determine how to leverage 

DOD’s operational and safety data to help develop UAS operations 

standards, which is a critical step in the integration process. While we did 

not evaluate the collaboration mechanisms already in place, stakeholders 

told us that collaboration was occurring, but efforts could be improved. 

Specifically, stakeholders told us they would like to see additional 

leadership from FAA.

FAA has several efforts under way to satisfy the 2012 Act’s requirements, 

most of which must be achieved between May 2012 and December 2015. 

See table 3 for a list of selected requirements and the status of FAA’s 

efforts to meet them. FAA has made progress toward these selected 

requirements. Of the seven deadlines that had passed, however, FAA 

had completed two as of January 2013.

Table 3: Selected Requirements and Status for UAS Integration under the FAA Modernization and Reform Act of 2012, as of 

January 31, 2013

Deadline FAA Modernization and Reform Act of 2012 requirement Status of action 

05/14/2012 Enter into agreements with appropriate government agencies to simplify the process for 

issuing COAs or waivers for public UAS. 

In process 

05/14/2012 Expedite the issuance of a COA for public safety entities. Completed 

08/12/2012 Establish a program to integrate UAS into the national airspace at 6 test ranges. This program 

is to terminate 5 years after date of enactment. 

In process 

08/12/2012 Develop an Arctic UAS operation plan and initiate a process to work with relevant federal 

agencies and national and international communities to designate permanent areas in the 

Arctic where small unmanned aircraft may operate 24 hours per day for research and 

commercial purposes. 

Completed 

08/12/2012 Determine whether certain UAS can fly safely in the national airspace before the completion 

of the Act’s requirements for a comprehensive plan and rulemaking to safely accelerate the 

integration of civil UAS into the national airspace or the Act’s requirement for issuance of 

guidance regarding the operation of public UAS including operating a UAS with a COA or 

waiver. 

In process 

11/10/2012 Develop a comprehensive plan to safely accelerate integration of civil UAS into national 

airspace. 

In process 

11/10/2012 Issue guidance regarding operation of civil UAS to expedite COA process; provide a 

collaborative process with public agencies to allow an incremental expansion of access into 

the national airspace as technology matures and the necessary safety analysis and data 

become available and until standards are completed and technology issues are resolved; 

facilitate capability of public entities to develop and use test ranges; provide guidance on 

public entities’ responsibility for operation. 

In process 

Meeting the 2012 Act’s 

Requirements Will 

Continue to Challenge 

FAA
 

Page 10 GAO-13-346T 

Deadline FAA Modernization and Reform Act of 2012 requirement Status of action 

02/14/2013 Approve and make publically available a 5-year roadmap for the introduction of civil UAS into 

national airspace, to be updated annually. 

In process 

02/14/2013 Submit to Congress a copy of the comprehensive plan. In process 

08/14/2014 Publish in the Federal Register the Final Rule on small UAS. In process 

08/14/2014 Publish in the Federal Register a Notice of Proposed Rulemaking to implement 

recommendations of the comprehensive plan. 

None to date 

08/14/2014 Publish in the Federal Register an update to the Administration’s policy statement on UAS in 

Docket No. FAA-2006-25714. 

None to date 

09/30/2015 Achieve safe integration of civil UAS into the national airspace. In process 

12/14/2015 Publish in the Federal Register a Final Rule to implement the recommendations of the 

comprehensive plan. 

None to date 

12/31/2015 Develop and implement operational and certification requirements for public UAS in national 

airspace. 

In process 

Source: GAO analysis of FAA Modernization and Reform Act as well as FAA progress.

These requirements can be considered under four categories: (1) 

developing plans for integrating UAS into the national airspace; (2) 

changing the COA process; (3) integrating UAS at six test ranges; and (4) 

developing, revising, or finalizing regulations and policies related to UAS. 

The following provides additional information on the status of FAA’s 

efforts to meet the requirements under these four categories:

• Comprehensive plan and roadmap for UAS integration. FAA, with the 

assistance of JPDO, is developing several planning documents 

required by the 2012 Act, including a 5-year roadmap and 

comprehensive plan to outline steps toward safe integration. As of 

January 2013, FAA officials told us they were in the final stages of 

reviewing and approving these documents and expected to make 

them publically available by the February 14, 2013 deadline. In light of 

the timeframes and complicated tasks involved in achieving the 

requirements, in September 2012, we recommended that FAA 

incorporate mechanisms in its 5-year roadmap and comprehensive 

plan that allow for regular monitoring to assess progress toward safe 

and routine access of UAS into the national airspace. Incorporating 

regular monitoring can help FAA understand what has been achieved 

and what remains to be done and help keep Congress informed about 

this significant change to the domestic aviation landscape. While FAA 

concurred with our recommendation, because these documents were 

not publically available as of January 2013, it remains unclear whether 

they include mechanisms for monitoring progress.
 

Page 11 GAO-13-346T 

• Changes to the COA process. FAA has changed the existing COA 

process in response to the 2012 Act, including taking steps to 

expedite COAs for public safety entities and developing agreements 

with government agencies to expedite the COA or waiver process. To 

help expedite COAs for public safety entities, FAA extended the 

length of UAS authorization from a 12-month period to a 24-month 

period so that those entities receiving COAs do not have to reapply as 

frequently. In addition, FAA made additional changes to simplify the 

COA application process, including automating the application 

process through an online form. FAA also worked with DOJ’s National 

Institute of Justice to develop an MOU to meet the operational 

requirements of law enforcement entities, which are expected to be 

early adopters of small UAS. Officials from both FAA and DOJ have 

reached agreement on a draft version of the MOU establishing this 

process. However, this MOU is still under legal review at FAA and 

DOJ.11

• Test ranges. FAA has taken steps to develop, but has not yet 

established, a program to integrate UAS at six test ranges, as 

required by the 2012 Act. As part of these ranges, FAA must safely 

designate airspace for integrated manned and unmanned flight 

operations, develop certification standards and air traffic requirements 

for UAS, ensure the program is coordinated with NextGen, and verify 

the safety of UAS and related navigation procedures before 

integrating them into the national airspace. FAA expects data 

obtained from these test ranges will contribute to the continued 

development of standards for the safe and routine integration of 

UAS.12 In March 2012, FAA issued a Request for Comments in the 

Federal Register and received a number of comments. FAA officials 

told us they are still working to meet all of the specified requirements 

for the test ranges and had expected to issue a Screening Information 

Request to initiate the competitive bid process for selecting the six 

 

11Additionally, FAA has signed a letter of agreement with the Department of the Interior 

and is in the process of establishing additional agreements with other agencies, such as 

DOD and NASA. 

12The designation of permanent areas of operation for UAS in the Arctic, also required by 

the 2012 Act, could provide FAA with another source of data. In November 2012, FAA 

finalized an Arctic Implementation Plan to expand small UAS use in the Arctic and has 

assigned a program manager who will officially assume his position in February 2013.
 

Page 12 GAO-13-346T 

test ranges in July 2012.13 However, because of privacy concerns 

regarding the collection and use of UAS-acquired data expressed by 

commenters, the internal review process of the Screening Information 

Request was delayed. FAA officials said they hired a privacy expert to 

help develop a strategy to address these concerns and are working to 

incorporate this strategy in its Screening Information Request. As of 

January 2013, officials noted that FAA expects to release the 

Screening Information Request in the next 4 to 6 weeks.

• Rulemaking. While FAA has efforts under way supporting a 

rulemaking for small UAS, as required by the 2012 Act, it is uncertain 

whether FAA will meet the August 2014 deadline. In fact, the agency’s 

rulemaking efforts for UAS date back more than 5 years, when it 

established the small UAS Aviation Rulemaking Committee in 2008. 

In August 2011, FAA initially provided the Secretary of Transportation 

with its draft Notice of Proposed Rulemaking (NPRM). FAA officials 

told us in January 2013 that the FAA is still internally reviewing the 

draft and working to agree on the NPRM’s language. According to the 

officials, FAA has not determined when it might issue the NPRM.

As we reported in 2012, many entities have research and development 

efforts under way to mitigate obstacles before UAS are allowed to operate 

safely and routinely in the national airspace. Some of these obstacles and 

related research include vulnerabilities in UAS operations, such as sense 

and avoid; command, control, and communications, including lost link, 

dedicated radio-frequency spectrum, and Global Positioning System 

(GPS) jamming and spoofing; and human factors. However, these 

research and development efforts cannot be completed and validated 

without safety, reliability, and performance standards, which have not yet 

been developed because of data limitations.

 

13A Screening Information Request is a request by the FAA for documentation, 

information, presentations, proposals, or binding offers concerning an approach to 

meeting potential acquisition requirements established by the FAA.

Standards and Data 

Needed to Guide UAS 

Research and

Development Efforts 

for Agencies
 

Page 13 GAO-13-346T 

To date, no suitable technology has been deployed that would provide 

UAS with the capability to sense and avoid other aircraft and airborne 

objects and to comply completely with FAA regulatory requirements of the 

national airspace.14 However, research and development efforts by FAA, 

DOD, NASA, and MITRE, among others, suggests that potential solutions 

to the sense and avoid obstacle may be available in the near term.15

Since 2008, FAA and other federal agencies have managed several 

research activities to support meeting the sense and avoid requirements. 

DOD officials told us that the Department of the Army is working on a 

ground-based sense and avoid system that will detect other airborne 

objects and allow the pilot to direct the UAS to maneuver to a safe 

location. The Army has successfully tested one such system, but it may 

not be useable on all types of UAS. Another potential system to address 

this obstacle is an airborne sense and avoid system, which could equip 

UAS with the same GPS-based transponder system that will be used in 

FAA’s NextGen air-traffic-management system and with which some 

manned aircraft are starting to be equipped. In 2012, NASA researchers 

at Dryden Flight Research Center successfully tested an automatic 

dependent surveillance-broadcast (ADS-B) transponder system on its 

Ikhana UAS.16 17 An airborne sense and avoid system could include ADSB, along with other sensors such as optical/infrared cameras and radar.

Ensuring uninterrupted command and control for both small and large 

UAS remains a key obstacle for safe and routine integration into the 

national airspace. Since UAS fly based on pre-programmed flight paths 

 

14The FAA regulations include 14 C.F.R § 91.111, “Operating near other aircraft,” with 

reference to “create a collision hazard,” and 14 C.F.R. § 91.113, “Right-of-way rules.” 

15MITRE is a public interest company that works in partnership with the federal 

government applying systems engineering and advanced technology to address issues of 

national importance. 

16ADS-B transponder system uses GPS signals along with aircraft avionics to transmit the 

aircraft’s location to ground receivers. The ground receivers then transmit that information 

to controller screens and cockpit displays on aircraft equipped with automatic dependent 

surveillance-broadcast transponder system avionics. 

17Ikhana is a large UAS that NASA has used for a number of research activities, such as 

monitoring and tracking wildfires and expects to use for an arctic mission to assess the 

surface sea ice next year. 

Elements of UAS Research 

and Development

Sense and Avoid

Command, Control and 

Communication Systems
 

Page 14 GAO-13-346T 

and by commands from a pilot-operated ground control station, the ability 

to maintain the integrity of command and control signals are critically 

important to ensure that the UAS operates as expected and as intended.

In a “lost link” scenario, the command and control link between the UAS 

and the ground control station is broken because of either environmental 

or technological issues, which could lead to loss of control of the UAS. To 

address this type of situation, UAS generally have pre-programmed 

maneuvers that may direct the UAS to hover or circle in the airspace for a 

certain period of time to reestablish its radio link. If the link is not 

reestablished, then the UAS will return to “home” or the location from 

which it was launched, or execute an intentional flight termination at its 

current location. It is important that air traffic controllers know where and 

how all aircraft are operating so they can ensure the safe separation of 

aircraft in their airspace.18 FAA and MITRE have been measuring the 

impacts of lost link on national airspace safety and efficiency, but the 

standardization of lost link procedures, for both small and large UAS, has 

not been finalized. Currently, according to FAA, each COA has a specific 

lost link procedure unique to that particular operation and air traffic 

controllers should have a copy for reference at all times. Until procedures 

for a lost link scenario have been standardized across all types of UAS, 

air traffic controllers must rely on the lost link procedures established in 

each COA to know what a particular UAS will do in such a scenario.

Progress has been made in obtaining additional dedicated radiofrequency spectrum for UAS operations, but additional dedicated 

spectrum, including satellite spectrum, is still needed to ensure secure 

and continuous communications for both small and large UAS operations. 

The lack of protected radio-frequency spectrum for UAS operations 

heightens the possibility that a pilot could lose command and control of a 

UAS. Unlike manned aircraft—which use dedicated, protected radio 

frequencies—UAS currently use unprotected radio spectrum and, like any 

other wireless technology, remain vulnerable to unintentional or 

intentional interference. This remains a key security and safety 

vulnerability because, in contrast to a manned aircraft in which the pilot 

has direct physical control of the aircraft, interruption of radio 

transmissions can sever the UAS’s only means of control.

 

18Air traffic controllers monitor and coordinate the movement of air traffic. They 

communicate with pilots of aircraft, including UAS, but do not directly control the 

operations of aircraft. 

Lost Link

Dedicated Radio-Frequency 

Spectrum
 

Page 15 GAO-13-346T 

UAS stakeholders are working to develop and validate hardware and 

standards for communications operating in allocated spectrum. For 

example, FAA’s UAS Research Management Plan identified 13 activities 

designed to mitigate command, control, and communication obstacles. 

One effort focused on characterizing the capacity and performance 

impact of UAS operations on air-traffic-control communications systems. 

In addition, according to NASA, it is developing, in conjunction with 

Rockwell Collins, a prototype radio for control and a non-payload 

communications data link that would provide secure communications.

The jamming of the GPS signal being transmitted to the UAS could also 

interrupt the command and control of UAS operations. In a GPS jamming 

scenario, the UAS could potentially lose its ability to determine its 

location, altitude, and the direction in which it is traveling.19 Low cost 

devices that jam GPS signals are prevalent. According to one industry 

expert, GPS jamming would become a larger problem if GPS is the only 

method for navigating a UAS. This problem can be mitigated by having a 

second or redundant navigation system onboard the UAS that is not 

reliant on GPS, which is the case with larger UAS typically operated by 

DOD and DHS.

Encrypting civil GPS signals could make it more difficult to “spoof” or 

counterfeit a GPS signal that could interfere with the navigation of a UAS. 

Non-military GPS signals, unlike military GPS signals, are not encrypted 

and transparency and predictability make them vulnerable to being 

counterfeited, or spoofed. In a GPS-spoofing scenario, the GPS signal 

going from the ground control station to the UAS is first counterfeited and 

then overpowered. Once the authentic (original) GPS signal is 

overpowered, the UAS is partially under the control of the “spoofer.” This 

type of scenario was recently demonstrated by researchers at the 

University of Texas at Austin at the behest of DHS. During the 

demonstration at the White Sands Missile Range, researchers spoofed 

one element of the unencrypted GPS signal of a fairly sophisticated small 

UAS (mini-helicopter) and induced it to plummet toward the desert floor. 

The research team found that it was straightforward to mount an 

intermediate-level spoofing attack, such as controlling the altitude of the 

UAS, but difficult and expensive to mount a more sophisticated attack.

 

19Jamming and spoofing are problems that also affect other industries and projects. 

GPS Jamming and Spoofing
 

Page 16 GAO-13-346T 

The research team recommended that spoof-resistant navigation systems 

be required on UAS exceeding 18 pounds.20

UAS stakeholders have been working to develop solutions to human 

factor issues for both small and large UAS. According to FAA, human 

factors research examines the interaction between people, machines, and 

the environment to improve performance and reduce errors. Human 

factors are important for UAS operations as the pilot and aircraft are not 

collocated. The separation of pilot and aircraft creates a number of 

issues, including loss of sensory cues valuable for flight control, delays in 

control and communications loops, and difficulty in scanning the visual 

environment surrounding the unmanned aircraft. As part of its UAS 

Integration in the National Airspace System Project, NASA is working to 

develop human factor guidelines for ground control stations and plans to 

share the results with RTCA SC-203 to inform recommended guidelines. 

In addition, the Department of the Army is working to develop universal 

ground control stations, which would allow UAS pilots to fly different types 

of UAS without having to be trained on multiple configurations of a ground 

control station.

The development of standards for UAS operations is a key step in the 

process of safe integration and supporting research and development 

efforts. Setting standards, certification criteria, and procedures for sense 

and avoid systems as well as protocols to be used for the certification of 

command, control, and communication systems will guide research and 

development efforts toward a specifically defined goal. Once the 

standards are developed, FAA will use the standards in UAS regulations. 

Currently, UAS continue to operate as exceptions to the regulatory 

framework rather than being governed by it. Without specific and 

permanent regulations for safe operation of UAS, federal stakeholders, 

including DOD and NASA, continue to face challenges and limitations on 

their UAS operations. The lack of final regulations could hinder the 

acceleration of safe and routine integration of UAS into the national 

airspace.

 

20The presentation “Assessing the Civil GPS Spoofing Threat” by Todd Humphreys, 

Jahshan Bhatti, Brent Ledvina, Mark Psiaki, Brady O’Hanlon, Paul Kintner, and Paul 

Montgomery sought to assess the spoofing threat of a small civil UAS. The team built a 

civilian GPS spoofer and tested some countermeasures. They concluded that GPS 

spoofing is a threat to communications security and civil spoofing has not been the focus 

of research in open literature. 

Human Factors 

Development of UAS 

Safety, Reliability, and 

Performance Standards
 

Page 17 GAO-13-346T 

Standards-making bodies are currently developing safety, reliability, and 

operational standards.21 While progress has been made, the standards 

development process has been hindered, in part, because of FAA’s 

inability to use safety, reliability, and performance data from DOD, the 

need for additional data from other sources, as well as the complexities of 

UAS issues in general. As we previously reported, while DOD provided 

FAA with 7 years of data in September 2011, FAA officials told us they 

have been unable to use this data to develop standards because of 

differences in definitions and uncertainty about how to analyze these 

data.22 To mitigate these challenges FAA has been working with DOD to 

develop an MOU and better identify what data are needed. Finally, FAA is 

also working with MITRE to develop a data collection tool that will allow 

officials to better analyze the data they receive from DOD.

The establishment of six test ranges, as previously discussed, and the 

designation of permanent areas of operation in the Arctic could provide 

FAA with two potential new sources of safety, reliability, and performance 

data for UAS. However, it is unclear when the test ranges and Arctic area 

will be operational. Use of these data will be important in developing 

safety, reliability, and performance standards, which are needed to guide 

and validate the supporting research and development efforts. According 

to an RTCA official, both DOD and NASA are sharing the results of their 

UAS flight experience and research and development efforts to assist 

RTCA in the standards development process. The RTCA official 

suggested that the standards-making process might be accelerated if it 

could start by producing an initial set of standards for a specific UAS with 

a clearly defined mission. The committee could then utilize those initial 

standards, along with the subsequent safety and performance data from 

those operations, to develop additional standards for increasingly 

complex UAS functions and missions.

FAA and NASA are taking steps to ensure the reliability of both small and 

large UAS by developing a certification process specific to UAS. 

Currently, FAA has a process and regulations in place for certifying any 

 

21For example, RTCA, a standards-making body chartered by FAA, established a federal 

advisory committee to establish minimum aviation-system performance standards and 

minimum operational performance standards for FAA to use in developing UAS 

regulations. 

22In June 2011, FAA and DOD signed a memorandum of agreement that specified the 

data from this process that would be provided.
 

Page 18 GAO-13-346T 

new manned aircraft type and allowing it access to the national airspace. 

FAA’s Research and Development office is working to identify the 

substantive differences in how to meet the certification standards for 

manned and unmanned aircraft. According to its 2012 Research 

Management Plan, the office has six activities under way that support the 

development of UAS-specific certification and airworthiness standards.

In closing, UAS integration is an undertaking of significant breadth and 

complexity that touches several federal agencies. Congress has 

highlighted the importance of UAS integration by establishing statutory 

requirements and setting deadlines for FAA. FAA, as the lead agency, 

faces the daunting task of ensuring that all of the various efforts within its 

own agency, as well as across agencies and other entities, will align and 

converge in a timely fashion to achieve UAS integration within these 

deadlines. Because of concerns about the agency’s ability to meet 

deadline requirements, we recommended that FAA incorporate regular 

monitoring of its efforts to assess progress toward fulfilling its 

requirements outlined in the 2012 Act. Incorporating regular monitoring 

will help to inform stakeholders and Congress about what has been 

achieved and what remains to be done and help FAA build stakeholder 

confidence in its ability to achieve UAS integration in a safe and timely 

manner. In addition, the various entities’ research and development 

efforts require continued collaboration to address the critical issues that 

need to be resolved before UAS are allowed to operate safely and 

routinely in the national airspace. This collaboration will be important to

help align research and development goals across federal agencies and 

minimize duplication of research or inefficient use of resources.

Chairman Broun, Ranking Member Maffei, and Members of the 

Subcommittee, this concludes my prepared statement. I would be 

pleased to answer any questions at this time.
 

Page 19 GAO-13-346T 

For further information on this testimony, please contact Gerald L. 

Dillingham, Ph.D., at (202) 512-2834 or dillinghamg@gao.gov. In 

addition, contact points for our Offices of Congressional Relations and 

Public Affairs may be found on the last page of this statement. Individuals 

making key contributions to this testimony include H. Brandon Haller, 

Assistant Director; Heather Krause, Assistant Director; Cheryl Andrew; 

Colin Fallon; Rebecca Gambler; Geoffrey Hamilton; Daniel Hoy; Brian 

Lepore; Sara Ann Moessbauer; Faye Morrison; Jeffrey Phillips; Nalylee 

Padilla; and Melissa Swearingen.

GAO Contact and 

Staff 

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