United States Government Accountability Office

GAO Report to Congressional Requesters

UNMANNED 

AIRCRAFT SYSTEMS 

Federal Actions 

Needed to Ensure 

Safety and Expand 

Their Potential Uses 

within the National 

Airspace System 

May 2008 

 

GAO-08-511 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

May 2008

UNMANNED AIRCRAFT SYSTEMS 

Federal Actions Needed to Ensure Safety and Expand 

Their Potential Uses within the National Airspace 

Highlights of GAO-08-511, a report to System 

congressional requesters 

Government and private-sector 

interest is growing in unmanned 

aircraft systems (UAS) for use in a 

variety of missions such as U.S.

border protection, hurricane

research, law enforcement, and

real estate photography. However,

UASs can fly only after the Federal

Aviation Administration (FAA) 

conducts a case-by-case safety

analysis. GAO’s research questions 

included (1) What are the current 

and potential uses and benefits of

UASs? (2) What challenges exist in 

operating UASs safely and 

routinely in the national airspace

system? and (3) What is the federal 

government’s response to these 

challenges? To address these

questions, GAO reviewed the 

literature, interviewed agency

officials and aviation stakeholders, 

and surveyed 23 UAS experts. 

UASs are currently being used by federal agencies for border security, 

science research, and other purposes. Local governments see potential

uses in law enforcement or firefighting and the private sector sees 

potential uses, such as real estate photography. An industry survey states 

that UAS production could increase in the future to meet such government 

and private-sector uses. Experts predict that UASs could perform some 

manned aircraft missions with less noise and fewer emissions. 

 

UASs pose technological, regulatory, workload, and coordination 

challenges that affect their ability to operate safely and routinely in the 

national airspace system. UASs cannot meet aviation safety requirements, 

such as seeing and avoiding other aircraft. UASs lack security

protection—a potential challenge if UASs proliferate as expected after 

obtaining routine airspace access. The lack of FAA regulations for UASs 

limits their operation to case-by-case approvals by FAA. Anticipated 

increases in requests to operate UASs could pose a workload challenge for 

FAA. Coordinating multiple efforts to address these challenges is yet 

another challenge. 

FAA and the Department of Defense (DOD) are addressing technological 

challenges. DHS has not addressed the national security implications of 

routine UAS access to the airspace. FAA estimates that completing UAS 

safety regulations will take 10 or more years, but has not yet issued its 

program plan to communicate the steps and time frames required for 

providing routine UAS access. FAA is working to allow small UASs to have 

airspace access and has designated specific airspace for UAS testing. It plans

to use data from this testing and from DOD to develop regulations, but has not 

yet analyzed data that it has already collected. To address its workload 

challenge, FAA is using more automation. Aviation stakeholders and experts 

suggested that an overarching entity could help coordinate and expedite 

federal, academic, and private-sector efforts. In 2003, Congress created a 

similar entity in FAA to coordinate planning for the next generation air 

transportation system among multiple federal agencies and the private sector.

Predator B UASs Used for Border Security 

Source: DHS.

What GAO Recommends

GAO suggests that Congress create

an overarching body within FAA to

coordinate UAS development and 

integration efforts. To realize

public benefits from UASs as soon 

as possible, GAO recommends that

FAA issue its program plan and

analyze the data it has collected,

and that the Department of

Homeland Security (DHS) assess

the security implications of routine

UAS access to the airspace. 

Relevant agencies reviewed a draft 

of this report. The Department of

Transportation agreed to consider

its relevant recommendations. 

DHS agreed with its relevant

recommendation. 

To view the full product, including the scope 

and methodology, click on GAO-08-511. 

For more information, contact Gerald L. 

Dillingham, (202) 512-2834 

dillinghamg@gao.gov. 
Contents 

Letter 1

Results in Brief 2

Background 6

Federal Agencies Have Used UASs in Many Ways and Expanded 

Government and Commercial Use Is Possible in the Future 10 

Routine Access to the National Airspace System Poses 

Technological, Regulatory, Workload, and Coordination 

Challenges 16

Fully Addressing UAS Challenges Involves Several Agencies and 

Could Take a Decade or Longer 29 

Impact of Routine UAS Operations Is Unknown 41 

Conclusion 42

Matter for Congressional Consideration 43 

Recommendations for Executive Action 43 

Agency Comments 44 

Appendix I Scope and Methods 45 

Appendix II Survey Methods 48 

Appendix III Survey of Experts on Unmanned Aircraft Systems 50 

Appendix IV GAO Contact and Staff Acknowledgments 67 

Tables 

Table 1: Examples of UAS Integration Efforts in Other Countries 26 

Figures 

Figure 1: Conceptual Unmanned Aircraft System 7 

Figure 2: Examples of UASs 8 

Figure 3: CBP’s Predator B UAS Inventory as of December 2007 11 

Figure 4: UASs Used as Communications Relays 12 

Figure 5: Illustration of UAS Use for Hurricane Data Collection 14 

Page i GAO-08-511 Unmanned Aircraft Systems 
Figure 6: Forecast of Civil UASs Produced, 2008 through 2017 23 

Figure 7: Applications for Certificates of Waiver or Authorization, 

Received in Calendar Years 2004–2007, and Projected 

through 2010 27 

Figure 8: Applications for Special Airworthiness Certificates, 

Received in Fiscal Years 2004–2007, and Projected

through 2010 28 

Figure 9: UAS Test Center at New Mexico State University 37 

Page ii GAO-08-511 Unmanned Aircraft Systems 
Abbreviations 

CBP Customs and Border Protection 

COA Certificate of Waiver or Authorization 

DHS Department of Homeland Security 

DOD Department of Defense 

DOT Department of Transportation 

EUROCAE European Organization for Civil Aviation Equipment 

EUROCONTROL European Organization for the Safety of Air Navigation 

FAA Federal Aviation Administration 

ICAO International Civil Aviation Organization 

JPDO Joint Planning and Development Office 

NASA National Aeronautics and Space Administration

NextGen next generation air transportation system 

NOAA National Oceanographic and Atmospheric Administration 

RTCA Radio Technical Commission for Aeronautics 

TSA Transportation Security Administration 

UAPO Unmanned Aircraft Program Office 

UAS unmanned aircraft system 

TCAS Traffic Alert and Collision and Avoidance System 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately. 

Page iii GAO-08-511 Unmanned Aircraft Systems 
United States Government Accountability Office

Washington, DC 20548 

May 15, 2008

The Honorable John Mica 

Ranking Republican Member 

Committee on Transportation and Infrastructure 

House of Representatives 

The Honorable Jerry F. Costello 

Chairman 

Subcommittee on Aviation 

Committee on Transportation and Infrastructure 

House of Representatives 

Government and private-sector interest in unmanned aircraft systems 

(UAS) is growing, due in large part to the U.S. military’s expanded 

development and use of these systems in Iraq and Afghanistan. The 

absence of a pilot on board the aircraft allows unmanned aircraft to 

perform a variety of missions not generally considered favorable for 

manned aircraft. Some unmanned aircraft can remain aloft for 30 hours or 

more, because there is no need for them to land to change pilots. 

Unmanned aircraft can also perform dangerous missions without risking 

loss of life. 

The federal government has used UASs for a number of years for various 

purposes, such as collecting scientific data, assisting with border security,

and gathering weather data from inside hurricanes. Federal agencies are 

planning to increase their use of UASs and state and local governments 

envision using UASs to aid in law enforcement or firefighting. Potential 

commercial uses are also possible, for example, in real estate photography 

or pipeline inspection. The Federal Aviation Administration (FAA) is 

responsible for ensuring that UASs operate safely in the national airspace 

system and is working to develop a regulatory framework to address the 

unique characteristics of UASs. For example, current regulations do not 

indicate how, in the absence of an on-board pilot, UASs should detect, 

sense, and avoid other aircraft to avoid collisions. FAA’s long-range goal is

to permit, to the greatest extent possible, routine government and 

commercial UAS operations in the national airspace system while ensuring 

safety. Presently, because of safety concerns, FAA authorizes civil 

government and military UAS operations in the national airspace system 

on a limited basis after conducting a case-by-case safety review. 

Regulations do not currently permit commercial UAS operations. 

Page 1 GAO-08-511 Unmanned Aircraft Systems 
You asked us to assess efforts to safely integrate UASs into the national

airspace system and the potential impact of those UASs after such 

integration occurs. To meet this objective, we developed the following 

research questions: (1) What are the current and potential uses and 

benefits of UASs? (2) What challenges exist in operating UASs safely and 

routinely in the national airspace system? (3) What is the federal 

government’s response to these challenges? and (4) Assuming that UASs 

have routine access to the national airspace system, how might they 

impact the system and the environment? 

To address these questions, we reviewed the literature, FAA and 

Department of Defense (DOD) documents, and aviation trade association 

reports. We also interviewed officials from DOD, the Department of 

Homeland Security (DHS), and the National Aeronautics and Space 

Administration (NASA) about their operations and plans to operate UASs 

in the national airspace system. We interviewed officials in associations 

that represent UAS manufacturers and users of the national airspace 

system. To determine the expected growth of UASs, we obtained industry 

forecasts. Additionally, we administered a Web-based survey to 23 UAS 

experts, selected with the assistance of the National Academies, to obtain

their opinions of the steps that FAA could take to accelerate UAS 

integration in the national airspace system and the impact that UASs might 

have on the system and the environment after integration occurs.1

 We 

conducted this performance audit from October 2006 to May 2008, 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. (See app. I for additional information on our 

scope and methods.) 

Federal agencies such as DHS, the Department of Commerce, and NASA 

use UASs in many areas, such as border security, weather research, and 

forest fire monitoring. These agencies have plans to expand their UAS use 

in domestic airspace, and local governments and commercial entities also

Results in Brief 

 1

At our request, the National Academies provided names of 26 experts in aviation 

regulations and safety, UAS technology, next generation air transportation system 

planning, airport operations, human factors, and international issues. Three experts did not

respond to the survey. 

Page 2 GAO-08-511 Unmanned Aircraft Systems 
have interest in using UASs. Many factors support the potential for 

expanded use of UASs. For example, the nation’s industrial base has 

expanded to support military operations and the number of trained UAS 

operators is increasing as personnel return from overseas duty. Moreover,

some of the technology used in military UAS operations could be applied 

to civil uses. DHS is expanding its use of UASs for border security and 

NASA is likely to continue using UASs to gather scientific data. 

Additionally, local law enforcement and firefighting agencies have 

expressed interest in using UASs to assist at crime scenes and wildfire 

locations, and commercial users envision using UASs for tasks such as 

photographing real estate or inspecting pipelines. According to an industry 

forecast, the market for government and commercial-use UASs could grow

in the future. The forecast also indicates that the United States could 

account for 73 percent of the world’s research and development 

investment for UAS technology over the coming decade. According to a 

UAS study and experts we surveyed, UAS development could lead to 

technological advances that could benefit all national airspace users. For 

example, some experts we surveyed noted that improved collision 

avoidance technologies developed for UASs could lead to reduced aircraft 

separation requirements, which could increase airspace capacity. 

Additionally, UASs could produce environmental benefits if they assume 

some missions currently performed by manned aircraft by using quieter 

engines that produce fewer emissions, according to experts we surveyed. 

Routine UAS access to the national airspace system poses technological, 

regulatory, workload, and coordination challenges. A key technological 

challenge is providing the capability for UASs to meet the safety requirements

of the national airspace system. For example, a person operating an aircraft

must maintain vigilance so as to see and avoid other aircraft. However,

because UASs have no person on board the aircraft, on-board equipment,

radar, or direct human observation must substitute for this capability. No

technology has been identified as a suitable substitute for a person on board

the aircraft in seeing and avoiding other aircraft. Additionally, UASs’

communications and control links are vulnerable to unintentional or

intentional radio interference that can lead to loss of control of an aircraft and 

an accident,2 and in the future, ground control stations—the UAS equivalent 

to a manned aircraft cockpit—may need physical security protection to guard 

against hostile takeover. Although DOD has achieved operational successes

 2

Although DOD often uses the term “mishap” to refer to UAS accidents, we use accidents

throughout this report. 

Page 3 GAO-08-511 Unmanned Aircraft Systems 
with its use of UASs in Iraq and Afghanistan, accidents of varying degrees of

severity have resulted from UAS reliability problems and human factors 

issues, i.e., equipment designs that did not fully account for human abilities,

characteristics, and limitations. Our analysis of 41⁄2 years of DOD’s data

indicates that UAS component failures caused about 65 percent of the 

accidents and human factors issues—a common challenge in new 

technology—caused about 17 percent of the accidents. Because a regulatory 

framework to ensure UAS safety does not exist, UASs have had only limited

access to the national airspace, which, in turn, has created additional 

challenges. For example, UAS developers have faced a lack of airspace for 

testing and evaluating their products, and data on UAS operations in the 

national airspace, which could aid in developing regulations, is scarce. In the 

coming years, FAA could face a workload challenge in responding to

increasing requests from federal agencies to operate UASs in the national 

airspace system. However, FAA’s future workload is uncertain because there 

is no accurate inventory of federally-owned and –leased UASs. GSA has 

responsibility for maintaining the inventory of federally-owned and –leased

aircraft, but its regulations have not been updated to require federal agencies

to report UASs. Coordinating the efforts of federal agencies with those of 

academic institutions that have UAS expertise, and with the private sector, 

which has a stake in UASs obtaining routine airspace access, serves as

another challenge. 

Addressing the challenges of allowing routine UAS access to the national

airspace system involves the efforts of several federal agencies and could 

require a decade or more of additional work. FAA is addressing 

technological challenges by sponsoring research on topics such as detect,

sense, and avoid, and taking steps to obtain dedicated radio frequency 

spectrum for UAS operations, which could address UAS communications 

and control vulnerabilities. DOD is addressing UAS reliability challenges

by urging manufacturers to use redundant, fail safe designs, and has made

some progress in addressing human factors challenges by standardizing 

some UAS ground control stations. Additionally, a federal advisory body is 

developing technical standards for UASs. However, DHS’s Transportation 

Security Administration (TSA) has not yet examined the security 

implications of routine UAS operations in the national airspace. Fully 

addressing regulatory challenges to allowing all UASs to have routine 

access to the national airspace system may not occur until 2020, after the 

aforementioned advisory body completes its technical standards work and 

FAA incorporates those standards in its regulations. In the interim, FAA 

has created an Unmanned Aircraft Program Office to coordinate efforts to 

develop standards and regulations. FAA is also developing a UAS program 

plan that would inform the aviation community of the steps and time 

Page 4 GAO-08-511 Unmanned Aircraft Systems 
frames required for providing routine UAS access. Although the plan was 

being developed in December 2006, it had not been approved for issuance 

as of March 2008. Additionally FAA is developing regulatory procedures to 

allow small UAS operations in the national airspace under low-risk 

conditions. FAA has established a 12,000 square mile UAS test center to 

provide airspace for testing and evaluating UASs and to provide data for 

use in developing regulations. FAA expects to obtain additional data from 

increased coordination with DOD. However, FAA has not yet analyzed the 

limited data that it has already accumulated on recent UAS operations in 

the national airspace system, citing resource constraints. To address 

expected workload increases, FAA is introducing more automation into its 

work processes and has granted DOD authority to operate small UASs, 

weighing 20 pounds or less, over its installations without receiving prior 

FAA approval. Additionally, GSA is updating its regulations to require 

federal agencies to report their owned and leased UASs, which could help

FAA plan for its future workload. Given the variety of federal entities 

involved with UAS issues, as well as the stake that the private sector has in 

routine UAS operations in the national airspace system, experts and 

stakeholders suggested that an overarching entity be established to 

coordinate and expedite these efforts. Congress used a similar approach in

2003 when it passed legislation to create the Joint Planning and 

Development Office (JPDO), within FAA, to coordinate planning for the 

next generation air transportation system among multiple federal agencies

and the private sector. 

Because data on UAS operations in the national airspace system are 

scarce and routine operations are many years away, the impact of routine

access on the system and the environment remains generally speculative. 

The impact will depend on a number of factors that, today, are 

unpredictable due to a lack of data. For example, one study notes that, 

while more needs to be known about the needs and capabilities of future 

UASs, their operations could have a disruptive impact on aviation by 

introducing more complexity. A federal advisory body has reported that 

UASs will create unique challenges because, in comparison to manned 

aircraft, UAS missions often involve hovering or circling in one location

and UASs’ speed, maneuverability, and climb rates, may differ from 

manned aircraft. These differences could affect air traffic flow, air traffic 

controller workload, and departure and arrival procedures. Many of the 

experts we surveyed predicted that UASs would add to the number of 

aircraft and therefore affect airspace and airport capacity and add to the

workload of air traffic control in the same manner as additional manned 

aircraft. However, our experts also noted that, if UASs assume some 

Page 5 GAO-08-511 Unmanned Aircraft Systems 
missions currently performed by manned aircraft, and perform them with

smaller and quieter engines, UASs could benefit the environment. 

We suggest that Congress consider creating an overarching body within 

FAA, as it did when it established JPDO, to coordinate the diverse efforts 

of federal agencies, academia, and the private sector in meeting the safety

challenges of allowing routine UAS access to the national airspace system. 

We also recommend that FAA issue its UAS program plan, analyze the 

UAS operations data that it has collected, and establish a process to 

analyze DOD’s data on UAS research, development, and operations. In 

addition, we recommend that DHS examine and fully address the security 

implications of routine civil UAS access in the national airspace system. 

We provided a draft of this report to the Department of Transportation 

(DOT), DHS, DOD, GSA, NASA, and the Department of Commerce. DOT 

agreed to consider the relevant recommendations and DHS agreed with 

our recommendation to it. GSA commented that it will continue its efforts 

to ensure that FAA has accurate information on the number of federallyowned and –leased UASs. DOT commented that the report would benefit 

from additional information on the impact of UASs on airports. We 

revised the report to include DOT’s concern that the impact of UASs on 

safety and capacity at airports requires further study. DOT, DOD, and 

DHS provided technical comments, which we incorporated as appropriate. 

NASA and the Department of Commerce had no comments. 

FAA defines an unmanned aircraft as one that is operated without the 

possibility of direct human intervention from within or on the aircraft. In 

the past, these aircraft were sometimes called “unmanned aerial vehicles,” 

“remotely piloted vehicles,” or “unmanned aircraft.” FAA and the 

international community have adopted the term “unmanned aircraft 

system” to designate them as aircraft and to recognize that a UAS includes 

not only the airframe, but also the associated elements—the control 

station and communications links—as shown in figure 1. 

Background 

Page 6 GAO-08-511 Unmanned Aircraft Systems 
Figure 1: Conceptual Unmanned Aircraft System

The capabilities of UASs differ from manned aircraft in several ways. A 

UAS can operate for far longer periods than an onboard pilot could safely

operate an aircraft. Future scenarios envision UASs remaining aloft for 

weeks or even months using fuel cell technology or airborne refueling 

operations. UASs may fly at slower speeds than most manned aircraft; 

some operate at low altitude (between buildings) while others fly well 

above piloted aircraft altitudes. Some UASs can fly autonomously based 

on pre-programmed data or flight paths, while others fly based on 

commands from pilot-operated ground stations. UASs also vary widely in

size, shape, and capabilities. Some UASs, such as the Global Hawk, have a 

wingspan as large as that of a Boeing 737. Others, because they do not 

need the power or physical size to carry a pilot, can be small and light 

enough to be launched by hand, as is the case for the SkySeer UAS shown

in figure 2. 

Page 7 GAO-08-511 Unmanned Aircraft Systems 
Figure 2: Examples of UASs 

Weight: 26,750 pounds

Launch mechanism: runway

Wingspan: 116 feet

Maximum speed: 350 knots

Maximum altitude: 65,000 feet

Mission duration: 32 hours

Current application: civil and military

Weight: 3,150 pounds

Launch mechanism: vertical

Wingspan: 27.5 feet (rotor diameter)

Maximum speed: 125 knots

Maximum altitude: 20,000 feet

Mission duration: up to 8 hours

Current application: military

Weight: 38 pounds

Launch mechanism: catapult

Wingspan: 10.2 feet

Maximum speed: 70 knots

Maximum altitude: 16,400 feet

Mission duration: 20 hours

Current application: civil and military

Weight: 4 pounds

Launch mechanism: hand launch

Maximum speed: 24 knots

Maximum altitude: 11,000 feet

Mission duration: 50 minutes

Current application: civil

Weight: 10,000 pounds

Launch mechanism: runway 

Wingspan: 66 feet 

Maximum speed: over 220 knots

Maximum altitude: 50,000 feet

Mission duration: 30 hours

Current application: civil and military

SkySeer

ScanEagleTM

Aerosonde®a Predator Bb

RQ-4A Fire Scout c

Weight: 33.5 pounds

Launch mechanism: catapult or from roof of fast

moving ground vehicle

Wingspan: 9.5 feet

Maximum speed: 60 knots

Maximum altitude: 15,000 feet

Mission duration: up to 30 hours

Current application: civil and military

Sources: AAI Corporation, U.S. Navy, U.S. Air Force, and Octatron Inc.

a

Aerosonde® is a registered trademark of Aerosonde Pty Ltd.

b

The civil version of the Predator B is shown. The military version of the Predator B is known as the 

Reaper (MQ-9). 

c

Model shown is RQ-4A. The Air Force has begun procuring model 4B for which some characteristics 

differ. Model 4B’s weight is 32,250 pounds; wingspan is 131 feet; maximum speed is 340 knots;

maximum altitude is 60,000 feet; and mission duration is 28 hours. 

Page 8 GAO-08-511 Unmanned Aircraft Systems 
DOD has pioneered UAS applications for wartime use and, in 2007, was 

the major user of UASs, primarily for ongoing conflicts in Iraq and 

Afghanistan. While many of DOD’s UAS operations currently take place 

outside the United States, DOD needs access to the national airspace 

system for UASs to, among other things, transit from their home bases for 

training in restricted military airspace or for transit to overseas 

deployment locations.3

 DOD officials stated that the need for military UAS 

access to the national airspace system is under review, and also noted that 

increased access would also allow their UASs to be more easily used to aid 

in fighting wildfires. 

Several federal agencies have roles related to UASs. FAA is responsible for 

ensuring UASs are safely integrated into the national airspace system’s air 

traffic control procedures, airport operations, and infrastructure, and with 

existing commercial, military, and general aviation users of the system. 

When UASs operate in that system, they must meet the safety 

requirements of the U.S. Code of Federal Regulations, Title 14, parts 61 

and 91.4

 FAA approves, on a case-by-case basis, applications from 

government agencies and private-sector entities for authority to operate 

UASs in the national airspace system. Federal, state, and local government 

agencies must apply for Certificates of Waiver or Authorization (COA), 

while private-sector entities must apply for special airworthiness 

certificates. In either case, FAA examines the facts and circumstances of 

proposed UAS operations to ensure that the prospective operator has 

acceptably mitigated safety risks. Special airworthiness certificates are the 

only means through which private-sector entities can operate UASs in the 

national airspace system. Because special airworthiness certificates do not 

allow commercial operations, there is currently no means for authorizing 

commercial UAS operations. 

NASA has conducted UAS research in the past. NASA led the 9-year 

Environmental Research Aircraft and Sensor Technology Program that 

focused on UAS technology for high altitude, long-endurance aircraft 

engines, sensors, and integrated vehicles. NASA also played a key role in a 

partnership with other federal agencies and industry called “Access-5.” 

 3

DOD has more than 5,000 UASs, ranging in size from the Raven, a hand-launched UAS, to

large UASs such as the Global Hawk and Predator. Most of DOD’s UASs are currently

deployed overseas. 

4

Part 61 addresses certification requirements for pilots, flight instructors, and ground 

instructors. Part 91 addresses general operating and flight rules. 

Page 9 GAO-08-511 Unmanned Aircraft Systems 
Access-5 incorporated the efforts of the UAV National Industry Team, 

known as UNITE, formed by six private-sector aerospace firms, as well as 

FAA, DOD, and other industry participants. The Access-5 partnership 

sought to achieve routine operations for high-level, long-endurance UASs 

in the national airspace system. NASA contributed about 75 percent of the 

funding for this effort and the partnership had laid out plans through 2010. 

Although the partnership ended in fiscal year 2006 when NASA cancelled 

its funding, the project claimed a number of accomplishments, including 

creating productive and cohesive working relationships among key 

stakeholders and recommendations to advance the introduction of UASs 

into the national airspace system. 

Other agencies and organizations have roles or interests relating to UASs. 

For example, DHS’s TSA has authority to regulate security of all 

transportation modes, including non-military UASs, to ensure that 

appropriate security safeguards are in place. GSA has the responsibility for 

maintaining an inventory of all federally-owned or -leased aircraft, as 

reported by federal agencies. Additionally, a number of associations, 

representing private-sector aviation industries, such as airframe and 

components manufacturers, and users of the national airspace system, 

have interest in UASs progressing toward routine access to the system. We 

refer to officials of these associations as stakeholders in this report. 

Several federal agencies are using UASs of varying sizes for missions 

ranging from forest fire monitoring to border security. These agencies are 

interested in expanded use of UASs and state and local governments 

would also like to begin using UASs for law enforcement or firefighting. 

UASs also could eventually have commercial applications. 

Federal agencies use UASs for many purposes. NASA, for example, uses 

UASs as platforms for gathering scientific research data and has partnered 

with other government agencies to demonstrate and use UASs’ unique 

capabilities. At its Wallops Island, Virginia, Flight Facility, NASA operates 

a small fleet of Aerosonde® UASs on a lease-to-fly basis for researchers. 

NASA also operates a modified Predator B UAS from its Dryden Flight 

Federal Agencies 

Have Used UASs in 

Many Ways and 

Expanded 

Government and 

Commercial Use Is 

Possible in the Future 

Federal Agencies Are 

Benefiting from Using 

UASs 

Page 10 GAO-08-511 Unmanned Aircraft Systems 
Research Center, in California, and used it to aid firefighting efforts in 

southern California in 2007. During 2005, the Department of Commerce’s 

National Oceanographic and Atmospheric Administration (NOAA) 

partnered with NASA and industry to use a UAS to fill data gaps in several

areas, including climate research, weather and water resources 

forecasting, ecosystem monitoring and management, and coastal mapping. 

During 2007, NOAA partnered with NASA to use an Aerosonde® UAS to 

gather data from Hurricane Noel and reported receiving valuable lowaltitude data that could aid future weather forecasts and potentially 

reduce property damage and save lives. 

Several other federal agencies have benefited from using UASs. DHS’s 

Customs and Border Protection (CBP) uses Predator B UASs to help 

conduct surveillance along portions of the U.S. border with Mexico. (See 

fig. 3.) CBP credits its UAS operations as helping its agents make over 

4,000 arrests and seize nearly 20,000 pounds of illegal drugs between 

September 2005 and March 2008. In the aftermath of Hurricane Katrina, 

UASs searched for survivors in an otherwise inaccessible area of 

Mississippi. Additionally, in 2004, the U.S. Geological Survey and the U.S. 

Forest Service used a UAS to study renewed volcanic activity at Mount St. 

Helens, Washington. The UAS proved useful in this study because it could 

operate above the extreme heat and toxic gases and solids emitted by the 

volcano. 

Figure 3: CBP’s Predator B UAS Inventory as of December 2007 

Source: DHS.

Page 11 GAO-08-511 Unmanned Aircraft Systems 
Recent events have contributed to increasing interest in expanding UAS 

operations. The nation’s industrial base has expanded to support current 

overseas conflicts. Moreover, personnel returning from duty in war 

theaters provide a growing number of trained UAS operators. Advances in 

computer technology, software development, light weight materials, global

navigation, advanced data links, sophisticated sensors, and component 

miniaturization also contribute to the heightened interest in using UASs in 

civilian roles. 

Interest Exists in 

Expanding UAS 

Operations to Obtain More 

Benefits 

In addition, the military’s use of UASs has raised the visibility of the 

possible benefits of using UASs in non-military applications. For example, 

the military recently demonstrated how operators can use UASs as 

communications platforms to bridge rugged terrain as shown in figure 4.

Disaster recovery officials could use UASs in a similar manner to help 

establish and maintain communications when the infrastructure is 

disabled or overloaded. The latter was an issue in the hours immediately 

following the terrorist attacks of September 11, 2001. 

Figure 4: UASs Used as Communications Relays 

Sources: GAO and DOD.

Ground station 1

Ground station 2

UAS 1 UAS 2

Line of sight

link

Line of sight

link

Line of sight link

Page 12 GAO-08-511 Unmanned Aircraft Systems 
An industry forecast anticipates that federal agencies will continue to be 

the main users of large UASs for much of the coming decade. CBP is 

expanding its fleet of Predator B UASs. The agency received its fourth 

aircraft in February 2008 and expects to acquire two more during fiscal 

year 2008. CBP also plans to expand its UAS operations along the southern 

U.S. border, and in the spring of 2008, begin operations along the northern 

U.S. border, and then eventually expand operations to the Great Lakes and 

Caribbean. CBP’s Air and Marine Operations Center in Riverside, 

California, will eventually control most of the agency’s UASs via satellite 

link. DHS’s Coast Guard is evaluating various UAS designs for future use 

in maritime border protection, law and treaty enforcement, and search and 

rescue. 

Expanded UAS use for scientific applications is also possible. According 

to NOAA, UASs have the potential to continue to fill critical observation 

gaps in climate change research, weather and water resources forecasting, 

ecosystem monitoring and management, and coastal mapping. NOAA also 

anticipates further use of UASs for hurricane observation. Figure 5 

illustrates how a high-altitude UAS might obtain hurricane data. The 

National Academies recently recommended that NASA should increasingly 

factor UAS technology into the nation’s strategic plan for Earth science. In

2007, NASA acquired two Global Hawk UASs from the Air Force for 

potential use in long endurance missions monitoring polar ice melt or for 

gathering data on hurricane development 2,500 miles off the U.S. Atlantic

coast. 

Page 13 GAO-08-511 Unmanned Aircraft Systems 
Figure 5: Illustration of UAS Use for Hurricane Data Collection

UAS flies above 

hurricane collecting

real-time data

Expendable 

sensors collect air 

and ocean data

Climb to altitude 

of 60,000 feet

Base of 

operations

Sources: GAO and AeroVironment.

1,500 nautical 

miles transit to 

hurricane (12-24 

hours)

Hurricane

State and local agencies and commercial users envision using smaller UAS 

models. To facilitate more rapid resolution of emergency situations, an 

official with the International Association of Chiefs of Police envisions 

police and firefighting units having small, hand-deployed UASs available to 

assist at crime scenes and wildfire locations. According to FAA, as of 

January 2008, about a dozen law enforcement agencies had contacted the 

agency to discuss potential use of UASs. An industry forecast of UAS 

growth from 2008 to 2017 predicts that interest among local law 

enforcement agencies in operating UASs could increase late in the forecast 

period.5

In the private sector, some entrepreneurs have become interested in 

obtaining authorization to use small UASs to provide real estate 

photography services. Small UASs could also help companies survey 

 5

Teal Group Corporation, World Unmanned Aerial Vehicle Systems (Fairfax, Va: 2008). 

Page 14 GAO-08-511 Unmanned Aircraft Systems 
pipeline or transportation infrastructure. However, an industry forecast 

noted that, for commercial applications, manned aircraft continue to be 

less costly than UASs. Consequently, demand for commercial applications

will be limited in the near term. While the forecast indicates that civil and 

commercial UAS markets will eventually emerge, the forecast notes that, 

for the next several years, a more likely scenario would be for a UAS 

leasing industry to emerge to serve the needs of businesses that do not 

want to invest in UAS ownership. 

UASs also could provide benefits to manned aviation. Efforts to move 

toward routine access for UASs could produce technological 

improvements in areas such as materials, fuel cells, antennae, and laser 

communications, which could also benefit manned aviation, according to

one study of UAS impact.6

 Some experts we surveyed had similar 

observations, noting that advancements in see and avoid technology could 

lead to reduced aircraft separation requirements and, in turn, to increased

airspace capacity. Five experts indicated that technological improvements 

could benefit the airspace, and four indicated that such improvements 

could benefit airports.7

 Additionally, five experts predicted that UASs 

could provide a variety of benefits by assuming some of the missions 

currently performed by manned aircraft or surface vehicles. These experts 

predicted that UASs might perform these missions in less congested 

airspace or with engines that burn less fuel or produce less air pollution. 

Some experts view the routine use of UASs in the national airspace system 

as a revolutionary change in aviation. According to one study, the state of

UASs today resembles the early days of manned aviation where innovation

and entrepreneurial spirit spawned a new market and permanently 

changed the transportation landscape. The UAS industry is poised to meet 

the potential demand for UASs. A 2004 study, prepared for JPDO, reported 

that 49 UAS manufacturers operated in the United States.8

 According to a 

2007 industry estimate, UAS development and components manufacturing 

 6

Matthew T. DeGarmo, Issues Concerning Integration of Unmanned Aerial Vehicles in

Civil Airspace (McLean, Va: The MITRE Corporation, Center for Advanced Aviation 

System Development, November 2004).

7

Three of these experts indicated that technology improvements could be applied to both 

airspace and airports.

8

In 2003, Congress created the Joint Planning and Development Office to plan for and 

coordinate, with federal and nonfederal stakeholders, a transformation from the current air

traffic control system to the next generation air transportation system by 2025. 

Page 15 GAO-08-511 Unmanned Aircraft Systems 
involved over 400 companies in the United States.9

 An industry forecast for 

UASs indicates that, over the coming decade, the United States will 

account for 73 percent of the world’s research and development 

investment for UAS technology.10 The aforementioned 2004 JPDO report 

notes that the emergence of a civil UAS industry could provide a number 

of economic, social, and national security benefits, such as extending U.S. 

aerospace leadership in the global UAS market; sustaining, and perhaps 

increasing, employment in the U.S. aerospace industry; contributing to 

expanding the U.S. economy by increasing domestic productivity and 

aerospace exports; and creating the potential for a UAS civil reserve fleet

for use in major national and international emergencies.11

Routine UAS access to the national airspace system poses a variety of 

technological, regulatory, workload, and coordination challenges. 

Technological challenges include developing a capability for UASs to 

detect, sense, and avoid other aircraft; addressing communications and 

physical security vulnerabilities; improving UAS reliability; and improving 

human factors considerations in UAS design. A lack of regulations for 

UASs limits their operations and leads to a lack of airspace for UAS testing 

and evaluation and a lack of data that would aid in setting standards. 

Increased workload would stem from FAA’s expectation of increased 

demand for UAS operations in the national airspace system without a 

regulatory framework in place. In addition, coordination of efforts is 

lacking among diverse federal agencies as well as academia and the 

private sector in moving UASs toward meeting the safety requirements of 

the national airspace system. 

Routine Access to the 

National Airspace 

System Poses 

Technological, 

Regulatory, Workload, 

and Coordination 

Challenges 

 9

Testimony of Steven M. Silwa, Chief Executive Officer and President of Insitu Inc., before 

the House Subcommittee on Aviation, Committee on Transportation and Infrastructure 

(Mar. 22, 2007). 

10Teal Group Corporation, 2008.

11Unmanned Aerial Vehicle National Task Force, The Impact of Unmanned Aerial Vehicles

on the Next Generation Air Transportation System: Preliminary Assessment 

(Oct. 22, 2004). 

Page 16 GAO-08-511 Unmanned Aircraft Systems 
FAA requires UASs to meet the national airspace system’s safety 

requirements before they routinely access the system. However, UASs do 

not currently have the capability to detect, sense, and avoid other aircraft

and airborne objects in a manner similar to manned aircraft. UASs also 

have communications and physical security vulnerabilities. Moreover, 

some UASs have demonstrated reliability problems and lack humanmachine interface considerations in their design.

Although research, development, and testing of sense and avoid 

technologies has been ongoing for several years, no suitable technology 

has been identified that would provide UASs with the capability to meet 

the detect, sense, and avoid requirements of the national airspace system. 

These requirements call for a person operating an aircraft to maintain 

vigilance so as to see and avoid other aircraft. Without a pilot on board to 

scan the sky, UASs do not have an on-board capability to directly “see” 

other aircraft. Consequently, the UAS must possess the capability to sense 

and avoid the object using on-board equipment, or do so with assistance of 

a human on the ground or in a chase aircraft, or by using other means, 

such as radar. Many UASs, particularly smaller models, will likely operate

at altitudes below 18,000 feet, sharing airspace with other objects, such as 

gliders. Sensing and avoiding these other objects represents a particular 

challenge for UASs, since the other objects normally do not transmit an 

electronic signal to identify themselves and FAA cannot mandate that all 

aircraft or objects possess this capability so that UASs can operate safely. 

Many small UAS models do not have equipment to detect such signals and, 

in some cases, are too small to carry such equipment. The Aircraft Owners 

and Pilots Association,12 in a 2006 survey of its membership, found that 

UASs’ inability to see and avoid manned aircraft is a priority concern. 

Additionally, the experts we surveyed suggested, more frequently than any 

other alternative, conducting further work on detect, sense, and avoid 

technology as an interim step to facilitate UAS integration into the national 

airspace system while FAA develops a regulatory structure for routine 

UAS operations. 

Several Technological 

Issues Must Be Addressed 

before UASs Can Routinely 

Access the National 

Airspace System 

UASs Cannot Detect, Sense, 

and Avoid Other Aircraft in a 

Manner Similar to Manned 

Aircraft 

The effort to develop the Traffic Alert and Collision and Avoidance System 

(TCAS), used widely in manned aircraft to help prevent collisions, 

demonstrates the challenge of developing a detect, sense, and avoid 

capability for UASs. Although FAA, airlines, and several private-sector 

 12The Airline Owners and Pilots Association is a not-for-profit organization representing the 

interests of general aviation. 

Page 17 GAO-08-511 Unmanned Aircraft Systems 
companies developed TCAS over a 13-year period, at a cost of more than 

$500 million, FAA officials point out that the designers did not intend for 

TCAS to act as the sole means of avoiding collisions and that the on board 

pilot still has the responsibility for seeing and avoiding other aircraft. FAA 

officials also point out that TCAS computes collision avoidance solutions 

based on characteristics of manned aircraft, and does not incorporate 

UASs’ slower turn and climb rates in developing conflict solutions. 

Consequently, FAA officials and stakeholders we interviewed believe that 

developing the detect, sense, and avoid technology that UASs would need 

to operate routinely in the national airspace system poses an even greater 

challenge than TCAS did. FAA officials believe that an acceptable detect, 

sense, and avoid system for UASs could cost up to $2 billion to complete 

and is still many years away. 

Ensuring uninterrupted command and control for a UAS is important 

because without it, the UAS could collide with another aircraft or, if it 

crashes to the earth, cause injury or property damage. The lack of 

protected radio frequency spectrum for UAS operations heightens the 

possibility that an operator could lose command and control of the UAS. 

Unlike manned aircraft, which use dedicated, protected radio frequencies, 

UASs currently use unprotected radio spectrum and, like any other 

wireless technology, remain vulnerable to unintentional or intentional 

interference. This remains a key security vulnerability for UASs, because 

in contrast to a manned aircraft where the pilot has direct, physical 

control of the aircraft, interruption of radio frequency, such as by 

jamming, can sever the UASs’ only means of control. One of the experts 

we surveyed listed providing security and protected spectrum among the 

critical UAS integration technologies. 

UASs Have Communications, 

Command, Control, and 

Physical Security 

Vulnerabilities 

To address the potential interruption of command and control, UASs 

generally have pre-programmed maneuvers to follow if the command and 

control link becomes interrupted (called a “lost-link scenario”) and a 

means for safe return to the ground if operators cannot reestablish the 

communications link before the UAS runs out of fuel. However, these 

procedures are not standardized across all types of UASs and, therefore, 

remain unpredictable to air traffic controllers. Predictability of UAS 

performance under a lost link scenario is particularly important for air 

traffic controllers who have responsibility for ensuring safe separation of 

aircraft in their airspace.

Ensuring continuity of UAS command and control also depends on the 

physical security provided to UASs. Presently, UAS operations in the 

national airspace are limited and take place under closely controlled 

Page 18 GAO-08-511 Unmanned Aircraft Systems 
conditions. However, this could change if UASs have routine access to the 

national airspace. One study identifies security as a significant issue that 

could be exacerbated with the proliferation of UASs. TSA notes that in 

2004, terrorists flew a UAS over northern Israel.13 One stakeholder 

questioned how we could prevent this from happening in the United 

States. UASs have the capability to deliver nuclear, biological, or chemical 

payloads, and can be launched undetected from virtually any site. In 

response to the events of September 11, 2001, entry doors to passenger 

airplane cockpits were hardened to prevent unauthorized entry. However, 

no similar security requirements exist to prevent unauthorized access to 

UAS ground control stations—the UAS equivalent of the cockpit. Security

is a latent issue that could impede UAS developments even after all the

other challenges have been addressed, according to one study. 

Although DOD has obtained benefits from its UAS operations overseas, 

the agency notes in its Unmanned Systems Roadmap14 that UAS reliability 

is a key factor in integrating UASs into the national airspace system.15 Our 

analysis of information that DOD provided on 199 military UAS accidents, 

of varying degrees of severity, that occurred over 41⁄2 years during 

operations Enduring Freedom and Iraqi Freedom, indicates that reliability 

continues to be a challenge. About 65 percent of the accidents resulted 

from materiel issues, such as failures of UAS components.16

UASs Have Shown a Lack of 

Reliability 

Studies indicate that a number of factors could contribute to UAS 

reliability problems. Many UASs have been designed primarily as 

expendable or experimental vehicles, where factors such as cost, weight,

function, and performance outweigh reliability concerns, according to a 

 13Transportation Security Administration, Advisory – Security Information Regarding 

Remote Controlled Aircraft and Unmanned Aerial Vehicles (Arlington, Va: Nov. 22, 2004).

14Department of Defense, Unmanned Systems Roadmap 2007 – 2032, (Washington, D.C.:

Dec. 10, 2007). We did not evaluate the validity of information contained in the roadmap. 

15DOD defines reliability as (1) the probability that an item will perform its intended 

function for a specified time under stated conditions or (2) the ability of a system and its

parts to perform its mission without failure, degradation, or demand on the support system. 

16DOD classifies accidents according to severity. The accident data that DOD provided

included accidents in class A, B, C, and D. See appendix I for accident class definitions and 

further details on our methodology. We also determined that 17 percent of the accidents 

were due to human factors (i.e., issues associated with how humans interact with 

machines); 6 percent of the accidents were caused by environmental issues; and 12 percent 

of the accidents’ causes were undetermined. We did not evaluate the validity of the 

accident information that DOD provided. 

Page 19 GAO-08-511 Unmanned Aircraft Systems 
2004 study.17 The Congressional Research Service reported in 2006 that the 

lack of reliability stems from the fact that UAS technology is still evolving, 

and, consequently, less redundancy is built into the operating system of 

UASs than of manned aircraft, and until redundant systems are perfected, 

accident rates are expected to remain high.18 Reliability issues also stem 

from the nature of the components used in some UASs. A DOD report 

notes that there has been a tendency to design UASs at low cost using 

readily available materials that were not intended for use in an aviation

environment. For example, one UAS used by DOD was equipped with a 

wooden propeller that could disintegrate in the rain.19 A composite or 

metal propeller could cost two to three times more than a wooden 

propeller. 

UAS developers have not yet fully incorporated human factors engineering 

in their products. Such engineering incorporates what is known about 

people, their abilities, characteristics, and limitations in the design of the 

equipment they use, the environments in which they function, and the jobs

they perform. According to researchers and agency officials we 

interviewed, technology in its early developmental stages typically lacks 

human factors considerations. Researchers noted that UASs, similar to any

new technology, have been designed by engineers who focused on getting

the technology to work, without considering human factors, such as ease 

of use by non-engineers. FAA officials noted that UASs today are at a 

similar stage as personal computers in their early years before newer, 

more user-friendly operating systems became standard. Studies indicate 

that human factors issues have contributed to military UAS accidents and 

DOD has indicated the need for further work in this area.20 Our analysis of 

DOD’s data on UAS accidents during Operation Enduring Freedom and 

Operation Iraqi Freedom showed that 17 percent were due to human 

factors issues. 

Human Factors Deficiencies in 

UAS Design Have Caused 

Accidents 

 17The MITRE Corporation, 2004. 

18Congressional Research Service, Homeland Security: Unmanned Aerial Vehicles and

Border Surveillance (Washington, D.C.: 2006). 

19A DOD official commented that wooden propeller damage is managed by adding 

treatments to the wood and by regular maintenance and inspection. 

20Human factors, such as pilot error, have also been significant contributors to manned

aircraft accidents. 

Page 20 GAO-08-511 Unmanned Aircraft Systems 
Several human factors issues have yet to be resolved. For example, the 

number of UASs that a single ground-based pilot can safely operate 

remains undetermined, as some future scenarios envision a single pilot 

operating several UASs simultaneously. Other unresolved issues include 

how pilots or air traffic controllers respond to the lag in communication of 

information from the UAS, the skill set and medical qualifications required 

for UAS pilots,21 and UAS pilot training requirements.22

The variety of ground control station designs across UASs is another 

human factors concern. For example, pilots of the Predator B UAS control 

the aircraft by using a stick and pedals, similar to the actions of pilots of 

manned aircraft. In contrast, pilots of the Global Hawk UAS use a 

keyboard and mouse to control the aircraft. Differences in UAS missions 

could require some variation among control station designs, but the extent 

to which regulations should require commonalities across all ground 

control stations awaits further research. 

The transition from one crew to another while UASs are airborne serves as 

another human factors issue needing resolution. Because UASs have the

capability of extended flight, one crew can hand off control to another 

during a mission. Several military UAS accidents have occurred during 

these handoffs, according to a 2005 research study.23 The National 

Transportation Safety Board cited a similar issue in its report on the April 

26, 2006, crash of CBP’s Predator B UAS. According to the report, the pilot 

inadvertently cut off the UAS’s fuel supply when he switched from a 

malfunctioning console to a functioning one.24 When the switch was made, 

a lever on the second console remained in a position that would cut off the 

fuel supply if an operator used the console to control the aircraft. 

Although procedures required that the controls on the two consoles be 

matched prior to making such a switch, this procedure was not followed. 

CBP reports that it has taken action to address this issue and has also 

 21FAA currently requires that UAS pilots and observers have in their possession a current

second class or higher airman medical certificate issued under chapter 14, Code of Federal 

Regulations part 67. 

22Jason S. McCarley and Christopher D. Wickens, Human Factors Implications of UAVs in

the National Airspace (Institute of Aviation, Aviation Human Factors Division, University 

of Illinois at Urbana-Champaign, 2005). 

23McCarley and Wickens, 2005.

24The second console can be used to operate the Predator’s camera or to control the 

aircraft. 

Page 21 GAO-08-511 Unmanned Aircraft Systems 
addressed nearly all of the board’s other recommendations stemming from 

this accident. 

A remote pilot’s lack of situational awareness serves as another human 

factors-related challenge for the safe operation of UASs. For example, FAA 

officials have noted that situational awareness remains a key factor for 

operators to detect and appropriately respond to turbulence. A pilot on 

board an aircraft can physically sense and assess the severity of 

turbulence being encountered, whereas a remote pilot cannot. A UAS 

could break apart and become a hazard to other aircraft or to persons or 

property on the ground if the pilot has no indication of turbulence or its 

severity. Even if a remote pilot had an awareness of the turbulence, the 

level of risk that the pilot might accept needs further study. Because a 

pilot does not risk his own safety when operating a UAS, the pilot may 

operate the UAS in situations unsuitable for the aircraft, such as flying 

through turbulence strong enough to destroy the UAS’s airframe. 

Although many experts and aviation stakeholders believe that the 

technical issues discussed above represent difficult challenges for UAS 

integration into the national airspace system, others do not. For example, 

DOD’s Unmanned Systems Roadmap asserts that the technology for 

detecting and maneuvering to avoid objects does not present a major 

obstacle. Some experts responding to our survey expressed similar 

opinions. For example, one noted that technology needed to safely 

integrate UASs into the national airspace system exists today and that 

implementation should be the focus. Another said that FAA is too slow in

adopting new technology and that sense and avoid techniques are 

available today that, when used in combination with a qualified pilot at the 

ground station’s controls, would be sufficient to allow free access for 

larger UASs. However, FAA expects to continue its current practice of 

allowing UAS access to the national airspace system on a case-by-case

basis, after a safety review, until technology, research, and regulations 

mature. 

A Lack of Regulations 

Limits UAS Operations 

The U.S. Code of Federal Regulations25 prescribes rules governing the 

operation of most aircraft in the national airspace system. However, these

regulations were developed for manned aircraft. Minimum performance 

standards for UAS detect, sense, and avoid and communications, 

 25Part 91 of title 14. 

Page 22 GAO-08-511 Unmanned Aircraft Systems 
command, and control capabilities, as well as regulations that incorporate 

these minimum standards, do not exist. Moreover, existing regulations 

may need changes or additions to address the unique characteristics of 

UASs. For example, because UASs do not need to be large or powerful 

enough to carry a pilot, they can be much smaller than any aircraft that 

today routinely operates in the national airspace system. Existing 

regulations were developed for aircraft large enough to carry a human. 

The lack of a regulatory framework has limited the amount of UAS 

operations in the national airspace system, which has, in turn, contributed 

to a lack of operational data on UASs and a lack of airspace in which 

developers can test and evaluate their products. An industry forecast 

indicates that growth in a civil UAS market is not likely until regulations 

exist that allow UASs to operate routinely. The forecast assumes that such 

regulations would be in place by 2012, but notes that few civil-use UASs 

would be produced in the near term, with numbers increasing towards 

2017. (See fig. 6.) 

Figure 6: Forecast of Civil UASs Produced, 2008 through 2017 

0

20

40

60

80

100

120

140

160

180

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Civil UASs produced

Source: Teal Group Corporation, 2008.

Year

Studies indicate that the lack of regulations can affect liability risk of UAS 

operations, which can increase insurance costs. For example, without 

airworthiness standards, insurers would be even more concerned about 

the liability hazard of UASs crashing in a dense urban environment. The 

Page 23 GAO-08-511 Unmanned Aircraft Systems 
lack of regulations to govern access to airspace has also posed challenges

for developers of civil UASs. Officials of associations representing UAS 

developers told us of difficulties in finding airspace in which to test and 

evaluate UASs. One of these officials noted that some manufacturers have

their own test ranges, and some have access to restricted military 

airspace, but other UAS developers have not had this access. Additionally, 

because UAS operations in the national airspace have been limited, 

operational data is scarce. Having data on UAS operations is an important 

element in developing regulations. 

Because UASs have never routinely operated in the national airspace 

system, the level of public acceptance is unknown. One researcher 

observed that as UASs expand into the non-defense sector, there will 

inevitably be public debate over the need for and motives behind such 

proliferation. One expert we surveyed commented that some individuals 

may raise privacy concerns about a small aircraft that is “spying” on them, 

whether operated by law enforcement officials or by private organizations, 

and raised the question of what federal agency would have the 

responsibility for addressing these privacy concerns. On the other hand, a 

study for JPDO noted that if UASs were increasingly used to produce 

public benefits in large-scale emergency response efforts, public 

acceptance could grow as the public notes the benefits that UASs can 

provide.26

Coordinating with Other 

Countries’ Efforts to 

Integrate UASs Is a Key 

Task

As other countries work toward integrating UASs in their respective 

airspaces, FAA faces a challenge to work with the international 

community in developing harmonized standards and operational 

procedures so that UASs can seamlessly cross international borders and 

U.S. manufacturers can sell their products in the global marketplace. 

International bodies such as the European Organization for Civil Aviation

Equipment (EUROCAE), and the European Organization for the Safety of

Air Navigation (EUROCONTROL), as well as individual countries face 

challenges similar to those that the United States faces in integrating UASs 

into their respective airspaces. 

EUROCAE formed a working group—WG-73—in 2006 to focus on UAS 

issues. The working group completed its first product in January 2007—a 

preliminary inventory of airworthiness certification and operational 

 26Unmanned Aerial Vehicle National Task Force, 2004. 

Page 24 GAO-08-511 Unmanned Aircraft Systems 
approval items that need to be addressed. The working group also plans to 

develop a work plan that lays out work packages and timelines; a concept 

for UAS airworthiness certification and operational approval that will 

provide recommendations and a framework for safe UAS operations in 

non-segregated airspace;27 requirements for command, control, and 

communications, as well as for sense and avoid systems; and a catalog of 

UAS-air traffic management incompatibility issues that need to be 

addressed. 

EUROCONTROL has established a UAS Air Traffic Management Activity 

and is hosting workshops to seek feedback, suggestions, and advice from a 

broad range of aviation stakeholders on its approach to UAS integration 

into European airspace. The second workshop is scheduled for May 2008 

and is open to all interested civil and military stakeholders, including air 

navigation service providers, UAS operators and manufacturers, 

regulators, as well as associations and professional bodies. EURCONTROL 

has also established an Operational Air Traffic Task Force that has 

developed high-level specifications for military UASs operating outside 

segregated airspace in a form suitable for European states to incorporate 

into their national regulations. The specifications state that UAS 

operations should not increase the risk to other airspace users, that air 

traffic management procedures should mirror those applicable to manned 

aircraft, and that the provision of air traffic services to UASs should be 

transparent to air traffic controllers. 

Table 1 illustrates the variety of individual country efforts to integrate 

UASs into their respective airspaces. With the variety of ongoing efforts 

around the world, FAA and other countries face a challenge in

harmonizing UAS standards and procedures. 

 27Non-segregated airspace is airspace that is available for all aircraft. 

Page 25 GAO-08-511 Unmanned Aircraft Systems 
Table 1: Examples of UAS Integration Efforts in Other Countries 

Country UAS integration efforts

United Kingdom “The Autonomous Systems Technology Related Airborne Evaluation and Assessment” project is 

focusing on the technologies, systems, facilities, and procedures that will allow UASs to operate 

safely and routinely in United Kingdom airspace. The project has received funding from the British 

government, industries, and universities and work has commenced to address topics such as 

communications, collision avoidance, operating rules and procedures, and integration with the 

operating environment. 

Australia/New Zealand An Australian aerospace firm has commissioned a program, Unmanned Aircraft Technology 

Applications Research, to organize efforts to address UAS issues. The program has, in turn, 

established an Australian/New Zealand working group to use demonstration programs to solve the 

critical issues currently inhibiting commercial UAS operations. The working group includes global, 

regional, and Australian UAS manufacturers and operators, researchers, military aviation, and an

international insurance underwriter. 

Japan In 2004, a consortium of Japanese manufacturers and a government ministry completed formulation 

of safety guidelines for using unmanned helicopters for commercial purposes over unpopulated

areas. This consortium became an association that includes additional manufacturers and individuals 

from universities and research agencies and plans to develop safety guidelines for UASs. Japan 

currently uses unmanned helicopters for pesticide spraying. 

Canada In 2007, Transport Canada issued the Final Report of its Unmanned Air Vehicle Working Group. The 

working group developed a plan to safely integrate unmanned air vehicles into the Canadian airspace 

system. The working group included representation from government, defense, and private-sector 

entities. 

Germany Germany has established a working group called “UAS-Deutschland” to facilitate the operation of 

UASs in German airspace. The working group is tasked with developing a national opinion

concerning enabling the integration of UAS operations in non-segregated airspace and preparing for 

and fostering international harmonization. Another working group called “UAV DACH” has been 

established for German-speaking countries—Austria, Germany, the Netherlands, and Switzerland—

to develop standards for national and international regulations for civil and military UAS flights. The 

group is also charged with finding solutions for UAS technical challenges such as sensing and 

avoiding other aircraft. 

Source: FAA documents, Internet Web pages, a press release, and a UAS expert.

FAA Faces Increased 

Workload to Process COA 

and Special Airworthiness 

Certificate Applications for 

UAS Operations 

FAA could face a workload challenge in conducting an increasing number 

of case-by-case safety reviews for proposed UAS operations in the national 

airspace system. FAA is already having difficulty in meeting its 60-calendar 

day goal for processing COAs, used for government requests to operate 

UASs. From December 2006 through January 2008, FAA’s COA processing 

time averaged 66 calendar days.28 FAA anticipates a substantial increase in 

requests for COAs, as well as for special airworthiness certificates, used 

by private-sector entities proposing UAS operations in the national 

 28FAA does not start calculating the processing time until officials have determined that the

application is administratively correct and that the proposed UAS operation is feasible. 

Page 26 GAO-08-511 Unmanned Aircraft Systems 
airspace system, by 2010. (See figs. 7 and 8.) Increased demand could 

result in even longer processing times for COAs. 

Figure 7: Applications for Certificates of Waiver or Authorization, Received in

Calendar Years 2004–2007, and Projected through 2010 

0

50

100

150

200

250

300

350

400

450

2004 2005 2006 2007 2008 2009 2010

Applications received

Source: FAA.

Years

Page 27 GAO-08-511 Unmanned Aircraft Systems 
Figure 8: Applications for Special Airworthiness Certificates, Received in Fiscal 

Years 2004–2007, and Projected through 2010 

0

5

10

15

20

25

30

35

40

2004 2005 2006 2007 2008 2009 2010

Applications received

Source: FAA.

Years

A lack of knowledge of the number of federally-owned or -leased UASs 

adds uncertainty to FAA’s expected future workload. The number of COAs 

does not provide a count of federally-owned or -leased UASs because each 

COA reflects an authorization to operate a UAS, not the number of UASs 

owned or leased by an agency. According to FAA, an agency could have 

multiple copies of the same type of UAS whose operation is approved in a 

COA. Moreover, having multiple UASs of the same type could drive 

additional workload for FAA if the agency requests authorization to 

operate its UASs under different operating scenarios, each of which would 

require a separate COA. An agency could also have only one UAS, but 

more than one COA, if the agency required and received approval for the

UAS to operate under different sets of conditions. GSA has responsibility 

for maintaining the inventory of federally-owned and -leased aircraft, but 

its regulations on reporting these aircraft have not been updated to require 

federal agencies to report UASs. 

Coordination among 

Federal Agencies and 

Others Is Lacking 

Coordinating the efforts of numerous federal agencies, academic 

institutions, and private-sector entities that have UAS expertise or a stake 

in routine access to the national airspace system is a challenge. As 

discussed above, several federal agencies are involved to varying degrees

Page 28 GAO-08-511 Unmanned Aircraft Systems 
in UAS issues. Additionally, academic institutions have UAS expertise to 

contribute and UAS manufacturers have a stake in supplying the demand 

for UASs that routine access could create. FAA and experts referenced the 

Access-5 program that, in the past, served as an overarching coordinating

body and provided a useful community forum. While some experts believe 

that Access-5’s focus on high-altitude, long-endurance UASs is no longer 

appropriate, the program’s institutional arrangements demonstrated how 

federal government and the private-sector resources could be combined to

focus on a common goal. 

Stakeholders and experts we surveyed believe that coordination and focus 

are lacking among the diverse entities working on UAS issues, and 

expressed concerns that the potential public and economic benefits of 

UASs could be delayed while FAA develops the safety regulations required 

to enable routine UASs operations in the national airspace system. They 

noted the numerous potential uses in public safety, law enforcement, 

weather forecasting, and national security, discussed previously, stating 

that these benefits will be delayed until standards are developed. Some 

also noted that economic benefits realized through industry growth and 

productivity gains in the commercial sector would also be delayed. 

Additionally, some experts believe that, at the current pace of progress, 

the United States would lose its leadership position and manufacturers 

would move to other countries where the regulatory climate is more 

receptive. However, as previously noted, an industry forecast indicates 

that the United States will account for about two-thirds of the worldwide 

UAS research and development in the coming decade. 

FAA and other agencies have roles in addressing technological, regulatory,

and workload challenges, but no entity is in charge of coordinating these 

efforts. FAA and DOD are addressing some technological challenges, but 

TSA has not addressed the security implications of routine UAS 

operations. FAA is establishing a regulatory framework, but routine UAS 

access to the national airspace may not occur for over a decade. FAA is 

mitigating its expected increased workload by automating some of its COA 

processing steps. GSA is updating its federal aircraft reporting 

requirements to include UASs. Experts and stakeholders believe that an 

overarching entity could add focus to these diverse efforts and facilitate 

routine UAS access to the national airspace system. 

Fully Addressing UAS 

Challenges Involves 

Several Agencies and 

Could Take a Decade 

or Longer 

Page 29 GAO-08-511 Unmanned Aircraft Systems 
FAA is addressing technological issues by sponsoring research and taking

steps to address UAS vulnerabilities in communications, command, and 

control. DOD is taking steps toward improving UAS reliability and the 

extent of human factors consideration in UAS design. An FAA-sponsored

federal advisory committee is developing technical standards for FAA to 

use in developing UAS regulations. Although TSA issued an advisory 

circular in 2004 on UAS security concerns, it has not addressed the 

security implications of routine UAS access in the national airspace 

system. 

FAA has budgeted $4.7 million for fiscal years 2007 through 2009 for 

further UAS research on topics such as detect, sense, and avoid; command 

and control; and system safety management. NASA, FAA, and others have 

conducted tests to determine the capabilities of and potential 

improvements to detect, sense, and avoid technology. For example, in 

2003, NASA installed radar on a manned aircraft that was equipped for 

optional control from the ground. The tests indicated that the radar 

detected intruding aircraft earlier than the onboard pilot, but also revealed 

the need for further work on the onboard sensing equipment to ensure 

adequate response time for the remote pilot. In another example, FAA and 

the Air Force Research Laboratory collaborated to execute flight tests for 

sense and avoid technology between October 2006 and January 2007. 

According to a summary of the lessons learned from these tests, the 

results showed some promise, but indicated that much work and 

technology maturation would need to occur before the tested system 

could be deemed ready for operational use. 

Addressing the challenge of radio frequency allocation for UAS operations 

is moving forward, but may not be completed for several years. The 

International Telecommunication Union allocates radio frequency 

spectrum and deliberates such issues at periodic World 

Radiocommunication Conferences, the most recent of which was held in 

the fall of 2007. To obtain spectrum allocation for UASs, FAA has 

participated with the Department of Commerce in a national preparation 

process to place spectrum allocation decisions on the conference’s future

agenda. At the 2007 conference, delegates agreed to discuss at the next 

conference, in 2011, the spectrum requirements and possible regulatory 

actions, including spectrum allocations, needed to support the safe 

operation of UASs. The Department of Commerce and the Federal 

Communications Commission would jointly implement and manage the 

Federal Agencies Are 

Addressing Some 

Technological Issues 

FAA Is Sponsoring Research 

on Detect, Sense, and Avoid 

Technologies and Other Topics 

FAA Has Begun to Address 

Radio Frequency Spectrum 

Allocation for UASs to 

Ensure Uninterrupted 

Communications, Command, 

and Control 

Page 30 GAO-08-511 Unmanned Aircraft Systems 
spectrum allocation decisions made at the 2011 conference, as these 

agencies manage, respectively, federal and non-federal use of frequency 

spectrum. 29

DOD is urging manufacturers to increase UAS reliability while keeping 

costs low by using such practices as standard systems engineering, 

ensuring that replacement parts are readily available, and using redundant, 

fail-safe designs. DOD also notes in its Unmanned Systems Roadmap that, 

although UASs suffer accidents at one to two orders of magnitude greater 

than the rate incurred by manned military aircraft, accident rates have 

declined as operational experience increased. For some UASs, the 

accident rates have become similar to or lower than that of the manned 

F-16 fighter jet, according to the roadmap. According to a study by The

MITRE Corporation, General Atomics designed the Predator B UAS with 

reliability in mind, and the Altair UAS, which is a modified version of the 

Predator, has, among other things, triple redundant avionics to increase 

reliability. 

DOD Is Working to Improve 

UAS Reliability and Incorporate 

Human Factors in UAS Design 

The Army has made some progress in limiting the variety of ground 

control station designs for unmanned aircraft—a human factors concern—

by developing its “One System®,” which involves a single ground control 

station capable of operating a variety of UASs. Further increasing 

standardization and interoperability across all unmanned systems is a 

continuing DOD goal. 

The Radio Technical Commission for Aeronautics (RTCA), a federal 

advisory committee sponsored by FAA,30 is establishing minimum 

performance standards for FAA to use in developing UAS regulations. 

RTCA established Special Committee 203 in October 2004 to develop such

standards for UAS detect, sense, and avoid and for UAS communications, 

command, and control. Individuals from academia and the private sector 

serve on the committee without government compensation along with 

FAA, NASA, and DOD officials. 

A Federal Advisory Body Is 

Developing Technical 

Standards 

 29The National Telecommunications and Information Administration of the Department of

Commerce manages federal use of spectrum. 

30RTCA is a private, not-for-profit corporation that develops consensus-based performance 

standards regarding communications, navigation, surveillance, and air traffic management

system issues. RTCA serves as a federal advisory committee, and its recommendations are

the basis for a number of FAA’s policy, program, and regulatory decisions. 

Page 31 GAO-08-511 Unmanned Aircraft Systems 
Special Committee 203 has begun assessing the technological and 

regulatory landscape as it pertains to UASs to determine the scope of its 

task. The committee published guidance materials to provide a framework 

for its standards development effort and to help UAS designers, 

manufacturers, installers, service providers, and users understand the 

breadth of operational concepts and systems being considered for 

integration into the national airspace system.31 The committee anticipates 

that the guidance will be further refined and validated as the standards 

development process moves along. 

According to a committee co-chair, the committee did not realize, at the 

outset, that developing technical standards for UASs would be a project of

unprecedented complexity and scope for RTCA. RTCA’s projects have 

been narrower in scope in the past, he said. Although the committee 

officials had previously estimated that the standards would be completed 

by 2011 or 2012, the completion date is now between 2017 and 2019. The 

additional time has been added to apply a data-driven, systems engineering 

approach that will require the collaborative efforts of FAA, DOD, and 

MITRE’s Center for Advanced Aviation System Development.32

RTCA anticipates that reliability and human factors requirements will be 

integrated into its minimum performance standards. The guidance 

materials note that UASs must meet the same reliability as manned 

aircraft, and that reliability is an important component of safety; flight

control systems; certification requirements for detect, sense, and avoid 

avionics; and for command and control systems such as the UAS’s 

autopilot. According to RTCA officials, human factors will be an 

overarching consideration in standards development. 

Although UASs remain vulnerable to many of the same security risks as 

manned aircraft, little attention has been afforded to UAS security. In 2004, 

TSA issued an advisory that described possible terrorist interest in using 

UASs as weapons. The advisory noted the potential for UASs to carry 

explosives or disperse chemical or biological weapons. However, the 

advisory noted that there was no credible evidence to suggest that 

Security Implications of

Routine UAS Access to the 

National Airspace System 

Have Not Been Addressed 

 31RTCA Special Committee 203, Guidance Material and Considerations for Unmanned

Aircraft Systems (Washington, D.C.: 2007). 

32MITRE’s Center for Advanced Aviation System Development is a federally-funded 

research and development center that performs systems research and development work

for FAA and other civil aviation authorities. 

Page 32 GAO-08-511 Unmanned Aircraft Systems 
terrorist organizations plan to use UASs in the United States and advised

operators to stay alert for UASs with unusual or unauthorized 

modifications or persons observed loitering in the vicinity of UAS 

operations, loading unusual cargo into a UAS, appearing to be under 

stress, showing identification that appeared to be altered, or asking 

detailed questions about UAS capabilities. In 2007, the agency advised 

model aircraft clubs to fly their aircraft only at chartered club facilities or 

at administered sites and to notify local authorities of scheduled flying 

events. 

TSA considers these actions appropriate to address the security threat 

posed by UASs. According to TSA, the agency uses a threat based, risk 

management approach to prioritize risk, threats, and vulnerabilities in 

order to appropriately apply resources and implement security 

enhancements. TSA informed us that the agency continues to monitor 

threat information regarding UASs and has processes in place to act 

quickly to mitigate and respond to any identified vulnerabilities. While 

these actions may be appropriate for the low tempo of today’s UAS 

operations, growth forecasts indicate that UASs could proliferate in the

national airspace in the future. Such a proliferation could increase the risk 

of UASs being used by terrorists for attacks in the United States. A lack of

analysis of security issues, while FAA develops the regulatory framework, 

could lead to further delays in allowing UASs routine access to the 

national airspace system.

FAA Is Establishing a 

Regulatory Framework, 

but Routine UAS Access to 

the National Airspace May 

Not Occur for a Decade or 

More 

FAA has established a UAS program office and is reviewing the body of 

manned aviation regulations to determine the modifications needed to

address UASs, but these modifications may not be completed until 2020. 

As an interim step, FAA has begun an effort to provide increased access to 

the national airspace system for small UASs. FAA is taking steps to 

develop data to use in developing standards, but has been slow to analyze 

the data that it has already collected. FAA is also coordinating with other 

countries to harmonize regulations. 

In February 2006, FAA created the Unmanned Aircraft Program Office 

(UAPO) to develop policies and regulations to ensure that UASs operate 

safely in the national airspace system. With 19 staff, UAPO serves as FAA’s 

focal point to coordinate efforts to address UAS technical and regulatory 

challenges and for outreach to other government agencies, the private 

sector, and other countries and international bodies working on UASs 

integration challenges. UAPO is developing a program plan to inform the 

aviation community of FAA’s perspective on all that needs to be 

accomplished and the time frames required to create a regulatory 

FAA Has Created an Unmanned 

Aircraft Program Office to 

Ensure That UASs Operate 

Safely 

Page 33 GAO-08-511 Unmanned Aircraft Systems 
framework that will ensure UAS safety and allow UASs to have routine 

access to the national airspace system. Although officials informed us that 

this plan was in progress in December 2006, as of March 2008 the plan was

awaiting final approval for release. Issuing the program plan could provide 

industry and potential UAS users with a framework that describes FAA’s 

vision and plans for integrating UASs into the national airspace system. 

While RTCA is developing minimum performance standards for UASs, 

FAA has begun to review the existing body of regulations for manned 

aviation to determine what regulations need to be modified or whether 

new regulations are needed to address the unique characteristics of UASs. 

Some of the rules for manned aircraft may not apply to UASs. For 

example, the rule requiring that oxygen be on board for passenger use on

all aircraft operating above 14,000 feet would not apply to a UAS. On the 

other hand, new standards may be needed. For example, while FAA has 

developed standards for manned airframe stress, no similar standard 

exists for UASs. UASs may require unique standards because, as 

mentioned previously in this report, a remote pilot cannot physically 

experience and judge the severity of turbulence that could potentially 

harm the airframe and cause an accident. 

However, UASs may not receive routine access to the national airspace 

system until 2020. FAA’s final step in developing UAS regulations must 

wait until the 2017 to 2019 time frame, after RTCA’s Special Committee 

203 develops minimum technical standards for UASs. FAA would then 

conduct a rulemaking to adopt the committee’s standards, which would 

require an additional year, according to an FAA official. 

As an interim effort to increase UAS access to the national airspace 

system, FAA began an effort in 2007 to establish regulations to

incrementally allow small UASs to operate in the national airspace system, 

under low-risk conditions without undergoing the case-by-case approval

process that is currently required. FAA has established a plan to publish a 

notice of proposed rulemaking by July 2009 and a final rule by 2010 or 

2011. Although FAA has not reached any final decisions, FAA may limit 

these regulations to UASs weighing less than 30 pounds, operating within 

line of sight, and traveling at speeds less than 40 knots, according to an 

FAA official.33 FAA is considering using a nontraditional certification 

 33DOD defines a small UAS as one that weighs less than 55 pounds, flies slower than 

100 knots, and operates at altitudes below 1,000 feet. 

Page 34 GAO-08-511 Unmanned Aircraft Systems 
approach that would allow applicants to register small UASs using a Webbased tool. FAA anticipates that, following the rulemaking, it will obtain 

data and experience with UAS operations that could lead to further 

gradual expansion of small UAS access to the national airspace system. 

Allowing incremental access of certain UASs that pose low risks is 

consistent with pending legislation34 and local government agencies and 

potential commercial operators have expressed much interest in operating 

small UASs. However, FAA recognizes that some small UASs may never 

have routine access to the national airspace system because their small 

size limits their ability to carry detect, sense, and avoid equipment. 

Additionally, FAA notes that, like all UASs, small UASs will require secure 

radio frequency spectrum for command and control, and this issue has not 

yet been resolved. 

The absence of a comprehensive database on UAS safety and reliability 

that could inform the standards and regulations development process 

hinders FAA’s efforts to establish a regulatory framework for UASs. FAA 

has been working to leverage DOD’s decades of experience with UASs. 

Collaboration between FAA and DOD could provide mutual benefits. DOD 

plans to spend over $7 billion in research, development, test, and 

evaluation funds for UASs between fiscal years 2007 and 2013. Data from 

these efforts could facilitate FAA’s development of a regulatory

framework to allow UASs to have routine access to the national airspace

system. DOD would benefit from this access by being able to operate its

UASs in the national airspace, without first obtaining a COA, as UASs 

transit from home bases to training areas or to overseas deployment. To 

this end, FAA and DOD finalized a memorandum of agreement in 

September 2007 that provides a formal mechanism for FAA to request, and 

DOD to provide, data on UAS operations to support safety studies. 

Through the memorandum, FAA will share the results of its studies with 

DOD and vice versa. FAA also participates with DOD on a joint integrated 

product team that is focusing on obtaining military UAS access to the 

national airspace system. According to DOD’s Unmanned Systems 

Roadmap, the team’s activities include modeling and simulation, 

technology development, acquisition, demonstrations, and flight tests. 

FAA Seeks Data on UAS 

Operations, but Progress 

Is Slow 

While DOD’s extensive experience with UAS operations and its 

accumulated data represent potentially rich sources of information on 

 34H.R. 2881, § 322. 

Page 35 GAO-08-511 Unmanned Aircraft Systems 
UAS operations, regulators should use such information with the 

understanding that it comes from a wartime operating environment. FAA 

and DOD officials acknowledge that military experience and operational 

data on UASs are not always directly transferable to operations in the 

national airspace system. The military’s use of UASs is focused on 

mitigating the danger to troops. Safety and reliability risks that may be 

appropriate in a war zone to protect troops may not be acceptable in the 

national airspace system. 

FAA’s efforts to develop and analyze UAS operations data are a good start,

but FAA has not yet analyzed the data that it has already collected. The 

COA requires the applicant to provide FAA with a variety of operational 

data, such as the number of flights conducted, the pilot duty time per 

flight, equipment malfunctions, and information on any accidents. FAA has 

been archiving this information as it is received, but has not analyzed it 

because of resource constraints, according to a UAPO official. Analyzing

this data could add to the information available for developing standards. 

As a vehicle for collecting data on UAS operations and to address the 

challenge that UAS developers have had in finding airspace for testing and

evaluating their products, FAA has established a UAS test center at New 

Mexico State University in Las Cruces, New Mexico. FAA expects that 

UAS operations at the test center, which opened in the spring of 2008, will 

provide FAA with some of the data needed to develop standards and 

regulations for allowing routine UAS access to the national airspace 

system. The university will operate the 12,000 square mile test center, 

where UASs can operate at altitudes up to 18,000 feet. (See fig. 9.) The 

university has several years of experience in demonstrating, testing, and 

evaluating UAS technologies. The New Mexico environment has the 

advantage of a very low population density and a low volume of air traffic,

and the test center is located over mostly undeveloped government-owned 

land. FAA will provide oversight of the test center operation by way of 

announced and unannounced visits, according to an FAA official. 

Page 36 GAO-08-511 Unmanned Aircraft Systems 
Page 37 GAO-08-511 Unmanned Aircraft Systems 

Figure 9: UAS Test Center at New Mexico State University 

To address the challenge of coordinating U.S. efforts with those of other 

countries, FAA is working with international aviation bodies and 

maintaining contact with other countries as they also work to overcome 

the challenges of integrating UASs into their respective airspaces. For 

example, the manager of FAA’s UAPO serves as a vice chairman of 

EUROCAE’s WG-73,35 and FAA has established a collaborative effort with 

 35EUROCAE formed WG-73 in 2006 to focus on UAS issues. 

FAA Is Coordinating with Other 

Countries to Harmonize 

Regulations 

60

180

180

25

10

Sources: GAO and FAA.

El Paso El Paso

New Mexico

Texas El Paso

Holloman

Air Force Base

Stallion Army Airfield

Alamogordo

Socorro

50 mi

Arizona

MEXICO

Las Cruces Airport

Area of detail

Biggs Army Airfield

Condron Army Condron Army

Airfield Airfield

New Mexico

Condron Army

Airfield
EUROCONTROL to leverage mutual expertise and resources. FAA told us 

that the International Civil Aviation Organization (ICAO)36 has formed a 

study group to identify changes needed in global standards and practices

to address UAS issues. FAA has also established a memorandum of 

cooperation with the Netherlands’ Civil Aviation Authority to work on 

UAS technology, hazards, and risks. FAA plans to contribute, subject to 

appropriations, $1 million during fiscal years 2007 through 2011, to provide 

the Netherlands with data and expertise, while the Netherlands plans to 

contribute €160,000 ($251,279).37 FAA has received briefings on Japan’s use 

of UASs for pesticide spraying and has collaborated with several countries 

to address UAS issues with ICAO. 

FAA’s efforts to work with the international community could facilitate 

mutual sharing of experiences and substantially increase the amount of 

information available to all countries. One stakeholder suggested Israel as 

a potential source of data, as that country has had extensive experience 

with UAS operations. An Israel Space Agency official, noting the growing 

importance of UASs in that country, stated that the numbers of unmanned 

aircraft in the Israel Air Force will outnumber manned aircraft within 20 

years. The official also stated that in a recent conflict, Israel’s UASs 

compiled more flying hours than manned aircraft. 

FAA Is Mitigating 

Anticipated Workload 

Increase by Automating 

Some COA Processing 

Steps, and GSA Is Working 

to Develop an Inventory of 

Federal UASs 

FAA has taken some actions to mitigate the workload challenge stemming 

from an anticipated increase in requests for COAs to operate UASs in the 

national airspace system. During the spring of 2007, FAA began to 

introduce more automation into its COA review process for UASs and has 

plans for increasing automation. For example, FAA established a Webbased COA application, which became mandatory for applicants’ use on 

July 1, 2007. FAA officials believe that the Web-based process allows 

applicants to more easily determine the application’s requirements, 

thereby eliminating rework and repeated reviews before FAA accepts the 

application. FAA also expects that the September 2007 memorandum of 

agreement with DOD will reduce the number of COA applications because

it allows DOD to conduct certain operations with UASs weighing 20 

pounds or less over military installations and in other specified airspace 

 36ICAO is the global forum for civil aviation. ICAO works to achieve its vision of safe, 

secure, and sustainable development of civil aviation through the cooperation of its

member States. 

37Based on conversion rate as of April 9, 2008.

Page 38 GAO-08-511 Unmanned Aircraft Systems 
without obtaining a COA.38 Additionally, FAA is working to identify 

characteristics of routine COA applications, which FAA estimates 

constitute up to 80 percent of total COA applications, enabling agency staff 

to focus limited resources on non routine cases. Focusing less attention on 

routine cases is consistent with comments from three of our experts who 

noted the need for an expedited process for obtaining COAs and special 

airworthiness certificates. FAA officials also stated that because 

applicants are becoming more familiar with COA requirements, a higher 

percentage of applications do not need additional work and review. 

Knowledge of the number of federally-owned or -leased UASs could help 

FAA to plan for future workload. Forecasters indicate that UASs operated 

by federal agencies could be a major component of UAS growth in the 

immediate future. Although the current number of federally-owned or 

-leased UASs is unknown, GSA is taking steps to obtain this information. 

In response to our requests for data on the number of federally-owned or 

-leased UASs, GSA sent letters to federal agencies in February 2008, 

clarifying that FAA defines a UAS as an aircraft and requesting agencies to

report their UASs by March 31, 2008. GSA is also in the process of revising 

regulations to require federal agencies to include owned or leased UASs in 

their aircraft inventory reports. GSA expects to have its regulation updated

by February 2009. GSA anticipates that the first public reporting of UASs 

will be in the fiscal year 2008 Federal Aviation Report, due by March 31, 

2009. This report could add a degree of certainty to FAA’s future workload 

requirements. 

Experts and Stakeholders 

Believe an Overarching 

Entity Could Facilitate 

Efforts to Achieve Routine 

UAS Access to the 

National Airspace System 

In addition to FAA, DOD, TSA, and GSA, other federal agencies, academia, 

and the private sector also have UAS expertise or a stake in obtaining 

routine UAS access to the national airspace system. For example, RTCA 

notes that developing standards will require collaboration with DOD’s 

joint integrated product team and technical expertise from staff in 

MITRE’s Center for Advanced Aviation System Development. DOD seeks 

expanded access to the national airspace and, as previously discussed, has 

extensive experience with operating its own UASs. Beyond DOD and FAA, 

other entities also have UAS expertise or a stake in achieving routine UAS 

access to the national airspace system. For example, DHS’s CBP and Coast 

Guard need UAS access to the national airspace system to perform their 

 38Previously, UAS operations could occur without a COA only within DOD’s restricted 

airspace or warning areas. 

Page 39 GAO-08-511 Unmanned Aircraft Systems 
missions. Several academic institutions have been involved in developing 

UAS technology in areas such as vehicle design and detect, sense, and 

avoid capability. Additionally, the private sector has a stake in being ready 

to respond to the anticipated market that could emerge when FAA makes 

routine access available to most UASs. Although FAA’s UAPO serves as a 

focal point within FAA, the office has no authority over other agencies’ 

efforts. 

Experts and stakeholders suggested that an overarching body might 

facilitate progress toward integrating UASs into the national airspace 

system. DOD, as the major user of UASs, is taking such an approach. DOD 

has recognized the need for coordination of UAS activities within its own 

sphere of influence, as each service has recognized the value of UASs for 

its respective missions. Consequently, DOD established an Unmanned 

Aircraft Systems Task Force to coordinate critical issues related to UAS 

acquisition and management within DOD. According to DOD, the task 

force will establish new teams or lead or coordinate existing Army, Navy, 

and Air Force teams to enhance operations, enable interdependencies, and

streamline acquisitions. FAA is participating in a joint integrated product 

team that is part of this task force, and DOD has invited DHS to join the 

task force. 

The European Defense Agency has also recognized the challenge of 

channeling diverse entities, as well as multiple nation-states, toward the 

common goal of UAS access to non-segregated airspace. In January 2008,

the agency announced that it had awarded a contract to a consortium of 

defense and aerospace companies to develop a detailed roadmap for 

integrating, by 2015, UASs into European airspace. The project is intended 

to help European stakeholders such as airworthiness authorities, air 

traffic management bodies, procurement agencies, industry, and research 

institutes to develop a joint agenda for common European UAS activities. 

The consortium held its first workshop in February 2008 and has since 

prepared a roadmap outline based on the needs and requirements 

expressed by the stakeholders. The consortium has also identified as a 

baseline, key actions to be undertaken and key topics for further 

investigation. The consortium has invited stakeholders to discuss this 

common baseline at a second workshop, scheduled for May 2008. 

Congress addressed a similar coordination challenge in 2003 when it 

passed legislation to create JPDO to plan for and coordinate a 

transformation of the nation’s current air traffic control system to the next 

generation air transportation system (NextGen) by 2025. NextGen involves

a complex mix of precision satellite navigation; digital, networked 

Page 40 GAO-08-511 Unmanned Aircraft Systems 
communications; an integrated weather system; layered, adaptive security; 

and more. 

NextGen’s coordination and planning challenges are similar to those posed 

by UASs. For example, as required for UAS integration, the expertise and 

technology required for NextGen resides in several federal agencies, 

academia, and the private sector. DOD has expertise in “network centric” 

systems, originally developed for the battlefield, which are being 

considered as a framework to provide all users of the national airspace 

system with a common view of that system. JPDO’s responsibilities 

include coordinating goals, priorities, and research activities of several 

partner agencies, including DOD, FAA, the Department of Commerce, 

DHS, and NASA with aviation and aeronautical firms. Congress directed 

JPDO to prepare an integrated plan that would include, among other 

things, a national vision statement and a multiagency research and 

development roadmap for creating NextGen. The legislation called for the 

roadmap to identify obstacles, the research and development necessary to

overcome them, and the roles of each agency, corporations, and 

universities. 

The impact of routine UAS operations on the national airspace system and 

the environment depends on a number of factors and remains generally

speculative. UAS impact will depend on factors such as the number of 

UASs purchased for civil uses and the altitudes and geographic locations 

where they are used. Stakeholders whom we interviewed provided a 

variety of perspectives on UASs’ potential impact. One official told us that 

UASs that use airports will impact air traffic control, while the impact of 

small UASs that do not need to use airports is less clear. Officials also 

noted that the level of risk depends on factors such as the UAS’s weight 

and horsepower. For example, a small, 2- or 3-pound UAS would pose little 

risk to aircraft or people on the ground, but UASs weighing more than 

20 pounds could do significant damage to an aircraft. Officials also noted 

that a UAS used over a sparsely populated area would have less impact 

than UAS operations over densely populated areas. 

Impact of Routine 

UAS Operations Is 

Unknown 

Predictions of the impact of UASs on the national airspace system are 

speculative because there are few data upon which to base predictions. 

Predictions become even more speculative in view of RTCA’s recent 

estimate that minimum standards for UASs—a prerequisite for routine 

UAS access to the national airspace system—will require about another 10 

years to complete. One study notes that more needs to be known about the 

needs and capabilities of future UASs as well as the potential market, but 

Page 41 GAO-08-511 Unmanned Aircraft Systems 
concluded that their operations could have a significant and potentially 

disruptive impact on aviation by affecting capacity and introducing more 

complexity. In 2007, RTCA’s Special Committee 203 reported similar 

concerns, indicating that UASs will create some unique challenges 

because they operate differently from typical manned aircraft. While 

manned aircraft generally go from one location to another, UASs may 

hover or circle in one location for a significant time. Additionally, UAS 

speed, maneuverability, climb rate and other performance characteristics 

may differ substantially from those of conventional aircraft. The 

committee believes that these characteristics could affect air traffic flow, 

air traffic controller workload, and departure and arrival procedures, 

among other things. Similarly, FAA officials noted that UASs pose airport 

safety and capacity questions that require further analysis. 

Most of the experts stated that the impact of UAS’s would be at least as 

significant as that of additional manned aircraft on airspace, airports, and 

air traffic control. For example, they predicted that, as with manned 

aircraft, UASs would add to the number of aircraft and, therefore, affect 

airspace and airport capacity and add to the workload of air traffic 

controllers. However, the experts also predicted that UASs could have a 

beneficial impact on the environment. The experts predicted that UASs 

could assume some missions currently performed by manned aircraft, but 

could perform these missions using engines that burn less fuel or produce 

less air pollution. 

Although ensuring that UASs operate safely in the national airspace 

system is a new and complex challenge for FAA, the national airspace 

system should be prepared to accommodate them. Understanding the 

issues, trends, and influences of UASs will be critical in strategically 

planning for the future airspace system. FAA is making progress in 

addressing the challenges. Establishing a UAS test center to provide UAS 

developers with airspace in which to test, evaluate, and refine their 

aircraft designs, and initiating efforts to increase airspace access for small 

UASs are significant steps. Moving forward, issuing FAA’s long-awaited 

program plan should benefit the aviation community by communicating 

FAA’s strategy of how it plans to address the interactive complexities and 

unique properties of UASs and how it plans to leverage the resources of 

multiple entities that have expertise and experience in this area. FAA’s 

efforts to accumulate and analyze data will be important to facilitate the 

regulatory development process. However, analyzing the data that it 

already has collected from recent UAS operations would further support 

decisions on the new regulations. FAA’s new estimate that the regulatory 

Conclusion 

Page 42 GAO-08-511 Unmanned Aircraft Systems 
framework is not likely to be completed until sometime near 2020—about 

8 years later than the date assumed by the industry forecast cited in this 

report—could further delay the time frame when civil-use UAS production 

begins to increase. While TSA’s risk assessment of UASs may be 

appropriate for today’s UAS environment, a national airspace system that 

allows routine UAS access for all government and private UASs will 

require increased safeguards to protect against security vulnerabilities like 

those exposed in the events of September 11, 2001. Proactively assessing 

and addressing these issues will help ensure that the benefits of UASs are 

not further delayed pending resolution of security challenges. Additionally, 

it will be important for GSA to follow through and ensure that federal 

agencies report all of their owned or leased UASs, so that FAA has a more 

accurate basis for workload planning. It remains to be seen whether 

Europe will be successful in integrating UASs into its airspace by 2015, 

which is considerably sooner than the 2020 time frame expected in the 

United States. An overarching entity, modeled after JPDO and set up to 

coordinate federal, academic, and private-sector entities, could facilitate 

progress in moving toward UASs having routine access to our national 

airspace system. 

To coordinate and focus the efforts of federal agencies and harness the 

capabilities of the private sector so that the nation may obtain further 

benefits from UASs as soon as possible, Congress should consider creating 

an overarching body within FAA, as it did when it established JPDO, to 

coordinate federal, academic, and private-sector efforts in meeting the 

safety challenges of allowing routine UAS access to the national airspace 

system. 

To obtain further benefits from UASs, we are recommending that the 

Secretary of Transportation direct the FAA Administrator to expedite 

efforts to ensure that UASs have routine access to the national airspace 

system by taking the following two actions: 

Matter for 

Congressional 

Consideration 

Recommendations for 

Executive Action 

1. Finalize and issue a UAS program plan to address the future of UASs. 

2. Analyze the data FAA collects on UAS operations under its COAs and 

establish a process to analyze DOD data on its UAS research, 

development, and operations. 

To ensure that appropriate UAS security controls are in place when civiluse UASs have routine access to the national airspace system, we are 

Page 43 GAO-08-511 Unmanned Aircraft Systems 
recommending that the Secretary of Homeland Security direct the TSA 

Administrator to examine the security implications of future, non-military 

UAS operations in the national airspace system and take any actions 

deemed appropriate. 

We provided a draft of this report to DOT, DHS, DOD, GSA, NASA, and the 

Department of Commerce. DOT agreed to consider our recommendations 

as it moves forward in addressing UASs and DHS agreed with our 

recommendation to it. GSA commented that, although our report 

contained no recommendations to the agency, it will continue to work 

with federal agencies to ensure that FAA has accurate information on the 

number of federally-owned or –leased UASs. DOT commented that the

report would benefit from additional information on the impact of UASs 

on airports. We revised the report to include DOT’s concern that the 

impact of UASs on safety and capacity at airports requires further study. 

DOT, DOD, and DHS provided technical comments, which we 

incorporated as appropriate. NASA and the Department of Commerce had 

no comments. 

We are sending electronic copies of this report to FAA, DHS, DOD, GSA, 

NASA, the Department of Commerce, and interested congressional 

committees. We also will make electronic copies available to others upon 

request. In addition, the report will be available at no charge on the GAO 

Web site at http://www.gao.gov. 

Agency Comments 

If you or your staff have any questions about this report, please contact me 

at (202) 512-2834 or dillinghamg@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 major contributions to this report 

are listed in appendix IV.

Gerald L. Dillingham, Ph.D. 

Director, Physical Infrastructure Issues 

Page 44 GAO-08-511 Unmanned Aircraft Systems 
Appendix I: Scope and Methods

Page 45 GAO-08-511 Unmanned Aircraft Systems 

Appendix I: Scope and Methods 

Our objective was to assess the Federal Aviation Administration’s (FAA) 

efforts to ensure that unmanned aircraft systems (UAS) are safely 

integrated into the national airspace system and the potential impact of 

UASs on the national airspace system and the environment after 

integration occurs. To meet this objective, we developed the following 

research questions: (1) What are the current and potential uses and 

benefits of UASs? (2) What challenges exist in operating UASs safely and 

routinely in the national airspace system? (3) What is the federal 

government’s response to these challenges? and (4) Assuming that UASs 

have routine access to the national airspace system, how might they 

impact the system and the environment? 

To address these questions, we surveyed the literature and also obtained 

and reviewed documents and interviewed officials of government, 

academic, and private-sector entities involved with UAS issues. We 

discussed current and future use of UASs with officials at FAA, 

Department of Defense (DOD), National Aeronautics and Space 

Administration (NASA), and Department of Homeland Security (DHS). We 

interviewed leaders of the Radio Technical Commission for Aeronautics’

(RTCA) Special Committee 203, which is developing UAS standards, and 

met with officials from a federally-funded research and development 

center. We discussed potential use of UASs for cargo transport with the 

United Parcel Service and Federal Express. We also discussed our 

questions with officials of associations of UAS manufacturers and users of 

the national airspace system, specifically, the Air Transport Association; 

Aerospace Industries Association; Association for Unmanned Vehicle 

Systems International; Aircraft Owners and Pilots Association; Air Line 

Pilots Association, International; American Institute of Aeronautics and 

Astronautics; ASTM International, originally known as the American 

Society for Testing and Materials; Palm Bay Police Department; and Los 

Angeles Sheriff Department. We discussed UAS operations with officials 

and observed UAS operations at Fort Huachuca, Arizona, and met with 

DHS’s Customs and Border Protection (CBP) officials in Arizona to 

discuss UAS use in border protection. Additionally, we obtained industry 

forecasts of UAS growth and interviewed a senior analyst involved in 

preparing Teal Group Corporation’s UAS market profile and forecast. We 

also observed a demonstration of unmanned systems at Webster Field, St.

Inigoes, Maryland. 
Appendix I: Scope and Methods

To obtain additional information on the challenges that must be overcome

before UASs can safely and routinely operate in the national airspace 

system, we leveraged information that was originally obtained and 

analyzed for a related GAO engagement.1

 For that engagement, we 

contacted the Army Combat Readiness Center, Naval Safety Center, and 

Air Force Safety Center to obtain data on each service’s UAS accidents 

from October 2001 to April or May 2006, depending on when the services 

queried their databases. The services provided data on class A, B, C, and D

accidents.2

 Using the descriptive information that the services provided for 

each accident, we determined whether human, materiel, environmental, or 

undetermined factors caused the accident and categorized each 

accordingly. We used the definitions of human, materiel, and 

environmental factors provided in Army Regulation 385-40, Accident 

Reporting and Records. We classified accidents as “undetermined” when

descriptive information did not fall within one of the first three categories 

of factors. We discussed the results of our analysis with DOD officials and

incorporated their comments as appropriate. 

To obtain additional information on the federal response to the challenge 

of integrating UASs into the national airspace system and the impact that 

UASs might have on the system after they have routine access, we 

reviewed agency documents and interviewed officials of the General 

Services Administration and the Department of Commerce’s National 

Telecommunications and Information Administration. We also obtained 

information from DHS’s Transportation Security Administration. 

 1

See GAO, Unmanned Aircraft Systems: Advance Coordination and Increased Visibility

Needed to Optimize Capabilities, GAO-07-836 (Washington, D.C.: July 11, 2007). The data, 

although not used in this report, was obtained and analyzed using generally accepted 

government auditing standards. 

2

DOD classifies accidents in categories A, B, and C, based on the severity of resulting 

injury, occupational illness, or property damage. Property damage severity is generally 

expressed in terms of cost and is calculated as the sum of the costs associated with DOD 

property and non-DOD property that is damaged in a DOD accident. Class A accidents

result in damages of $1 million or more, total loss of a DOD aircraft, or a fatality or 

permanent total disability. Class B accidents result in damages of $200,000 or more, but 

less than $1 million, a permanent partial disability, or hospitalization of three or more

personnel. Class C accidents result in damages of $20,000 or more, but less than $200,000, a 

nonfatal injury that causes any loss of time from work beyond the day or shift on which it

occurred, or a nonfatal occupational illness or disability that causes loss of time from work 

or disability at any time. Additionally, the services have varying classifications of less 

severe accidents. Only the Army provided accident data for Class D accidents, which the

Army defines as those which result in property damage of $2,000 or more but less than 

$20,000, or a nonfatal injury that does not meet the criteria of a Class C accident. 

Page 46 GAO-08-511 Unmanned Aircraft Systems 
Appendix I: Scope and Methods

Additionally, we surveyed 23 UAS experts, whose names were identified 

with the assistance of the National Academies. We asked the experts to 

provide, in narrative format, their views on the interim regulatory, 

technological, research, or other efforts that could be undertaken for 

UASs to operate, if not routinely, then to the maximum extent possible in 

the national airspace system while FAA develops the regulatory structure 

to enable all UASs to have routine access to the system. We also asked the 

experts to provide their predictions on how small and large UASs might 

impact the national airspace, airports, air traffic control, noise, and air 

quality, using a 7-point scale from large adverse impact to large beneficial

impact, and asked that they explain their answers. Appendix II discusses 

how we developed and conducted the survey. The complete survey 

instrument appears as appendix III. 

We conducted this performance audit from October 2006 to May 2008, 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. 

Page 47 GAO-08-511 Unmanned Aircraft Systems 
Appendix II: Survey Methods 

Page 48 GAO-08-511 Unmanned Aircraft Systems 

We administered a Web-based survey to gather the professional views of 

experts on the impact of UASs on the national airspace system and the 

actions needed to move toward safe and routine UAS operations. The 

structured survey questions ensured that all individuals had the 

opportunity to provide information in response to the same questions and 

enabled us to quantify the results. 

We contracted with the National Academies to identify experts to 

participate in our survey. Using criteria to ensure adequate representation 

across the criteria that we had specified, the National Academies 

identified 26 experts. The criteria ensured that we achieved: 

• balance in terms of the type of expertise (i.e., aircraft and avionics 

manufacturing officials, association representatives, engineers, academics, 

foreign civil aviation authorities, and researchers involved in aviation 

safety); 

• balance of knowledge across relevant content areas (i.e., aviation 

regulations and safety, UAS technology, next generation air transportation 

system planning, airport operations, human factors, and international 

issues); and 

• balance in representation of relevant organizations (i.e., academia, 

business, government, and professional organizations). 

The survey responses represent the professional views of the experts. 

Their expertise can be derived from formal education, professional 

experience, or both. The experts were identified by the National 

Academies as individuals who are recognized by others who work in the 

same subject matter area as having knowledge that is greater in scope or 

depth than that of most people working in the area. The experts included 

researchers, consultants, vice presidents, directors, and professors who 

were associated with private sector firms, associations, or academic 

institutions involved with UASs. Some of the experts were retired federal 

officials. 

We recognize that it is likely that no one individual possessed complete 

knowledge in each of the content areas addressed in the survey. However, 

through our selection criteria, we attempted to identify a set of individuals 

who, when their responses were considered in the aggregate, could be 

viewed as representing the breadth of knowledge in each of the areas 

addressed in the survey. 

Appendix II: Survey Methods 
Appendix II: Survey Methods 

Page 49 GAO-08-511 Unmanned Aircraft Systems 

We identified the information to collect in our surveys based on our 

congressional request, Internet and literature searches, professional 

conferences we attended, background interviews, and through discussions 

with external expert advisors. A social science survey specialist 

collaborated with staff with subject matter expertise on the development 

of the surveys. 

We pretested the survey to ensure that the questions appropriately 

addressed the topics, were clearly stated, easy to comprehend, unbiased, 

and did not place undue burden on respondents. We also evaluated the 

usability of the Web-based survey. Based on the pretest results, we made 

necessary changes to the survey prior to implementation. 

We administered the Web-based survey during August and September 

2007. We used email to inform the respondents of the survey 

administration, and provided them with the Web link for the survey and 

their log-in name and password. In the email message, we informed 

respondents that our report will not contain individual survey responses; 

instead, it may present the aggregated results of all participants. To 

maximize the response rate, we sent follow up email reminders and 

followed up by telephone as necessary to encourage survey participation. 

The survey was sent to 26 experts; three did not respond, giving the survey 

a response rate of 89 percent. 

The narrative responses in question 1 and the explanations for the closedended items in questions 2 and 3 were analyzed and coded into categories. 

A reviewer checked the resulting categories and coded responses and, 

where interpretations differed, agreement was reached between the initial 

coder and the reviewer. The coded results were tallied and provide the 

basis for our survey findings for these items. Because we did not report on 

aggregate responses to question 4, we did not perform content analysis on 

this question. 

The number of responses reported for the closed-ended questions may 

vary by question because a number of experts responded “Don’t know” or 

“No basis to judge,” or did not answer specific questions. 

The survey was administered via the Web and is reproduced as a graphic 

image in appendix III. 
Appendix III: Survey of Experts on Unmanned 

Aircraft Systems 

Page 50 GAO-08-511 Unmanned Aircraft Systems 

Appendix III: Survey of Experts on 

Unmanned Aircraft Systems 

Survey of Experts on Unmanned Aircraft Systems 

U.S. Government Accountability Office 

Welcome to the U.S. Government Accountability Office's (GAO) Survey of 

Experts on Unmanned Aircraft Systems (UAS). GAO is conducting this survey as 

a part of our study on the future of UASs in the national airspace system which 

was requested by the Aviation Subcommittee of the House Committee on 

Transportation and Infrastructure. The purpose of the survey is to collect 

information on the impact of UASs on the national airspace sytem and the actions 

needed to move toward safe and routine UAS operations.

To begin, you will need the user name and password from the e-mail message we 

sent you. In addition, please click here to download important information that will 

help you complete the questionnaire.

The questionnaire will be available on the web for one week. During this time, you 

may log into the questionnaire to enter and edit information as often as you like. It 

will take between 30 and 45 minutes to complete the questionnaire.

You may bookmark this page to make it easier to start the questionnaire again.

If you want to print a blank questionnaire for reference, you will need the 

Adobe Acrobat Reader software to do this. If you do not already have this 

software, click on the Adobe icon to download the software. 

If you want to print a blank questionnaire for reference, click here to download a 

copy. You will not be able to enter responses into this PDF file. 

If you have questions, please contact: Ed Menoche (menochee@gao.gov) at 202-

512-3420 or Teresa Spisak (spisakt@gao.gov) at 202-512-3952.

Click on the button below to start this questionnaire.

Start log in
Appendix III: Survey of Experts on Unmanned 

Aircraft Systems 

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Appendix III: Survey of Experts on Unmanned 

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Page 56 GAO-08-511 Unmanned Aircraft Systems 
Appendix III: Survey of Experts on Unmanned 

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Appendix III: Survey of Experts on Unmanned 

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Page 66 GAO-08-511 Unmanned Aircraft Systems 
Appendix IV: 

A

GAO Contact and Staff 

cknowledgments 

Page 67 GAO-08-511 Unmanned Aircraft Systems 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

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

In addition to the contact named above, Teresa Spisak, Assistant Director; 

Edmond Menoche, Senior Analyst; Colin Fallon; Jim Geibel; Evan Gilman; 

David Hooper; Jamie Khanna; Patty Lentini; Josh Ormond; Manhav 

Panwar; and Larry Thomas made significant contributions to this report. 

GAO Contact 

Staff 

Acknowledgements 

(540138) 
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