26-74 — Comment Digest

The removal of legacy airborne restrictions on certain spectrum bands to facilitate UAS operations.

Filers split on: “The FCC should lift legacy airborne restrictions in bands like 800 MHz Cellular and CBRS to facilitate UAS operations.”

• Connected Devices for America Coalitionsupport — The commenter advocates for the FCC to eliminate airborne restrictions in spectrum bands allocated for flexible use to enhance UAS and Counter-UAS capabilities, prioritize UAS operations over existing LTE and 5G networks by revisiting outdated restrictions, specifically in the 800 MHz band, and asserts that the FCC can enable airborne operations without granting NextNav’s petition.pp. 2, 3
• Wireless Infrastructure Association WIAsupport — The commenter advocates for the FCC to affirm the rights of licensed spectrum holders while adopting flexible, technology-neutral policies that utilize existing commercial wireless infrastructure to foster innovation. They also emphasize the need to remove outdated regulatory barriers to UAS operations, ensure that new UAS capabilities do not interfere with licensed operations, and lift legacy airborne restrictions on spectrum bands to support modern UAS activities.pp. 2, 4, 5, 6
• Alliance for Telecommunications Industry Solutsupport — The FCC should lift legacy airborne restrictions in bands like 800 MHz Cellular and CBRS to facilitate UAS operations.p. 2
• Utilities Technology Councilmodify — The commenter advocates for the FCC to promote LTE and 5G networks for UAS operations due to their suitability for low-altitude use and lack of interference with other operations, ensure utilities have access to licensed spectrum for BVLOS UAS operations to enhance safety and communication, allow flexible-use of licensed spectrum for various applications rather than limiting it to drones, and remove regulatory restrictions on UAS operations in certain spectrum bands where interference is not a concern.pp. 2, 3, 4, 5
• ATT Servicessupport — The commenter advocates for the FCC to adopt a multi-band, multi-use approach to spectrum allocation for UAS operations, arguing against vertical restrictions on licensees' spectrum rights to prevent stifling innovation, and calls for the reevaluation and removal of existing airborne use prohibitions on flexible-use licenses to further enhance UAS operations.pp. 5, 7, 9
• AURA Network Systemsmodify — The commenter advocates for the FCC to promptly establish final rules for the 450 MHz band to alleviate spectrum constraints and facilitate UAS technology deployment, while also urging the Commission to firmly oppose any proposals to reallocate the 450 MHz AGRAS band, emphasizing the need to preserve its primary status for air-ground communications.pp. 3, 4

The modernization and streamlining of experimental licensing processes for UAS and C-UAS technologies.

Filers split on: “The FCC should modernize its experimental licensing framework for UAS and C-UAS to support industry growth and rapid deployment of technology.”

• Wireless Infrastructure Association WIAsupport — The FCC should streamline its experimental licensing processes to better accommodate modern UAS testing and development.p. 6
• D-Fend Solutionsmodify — The commenter advocates for the FCC to modernize its experimental licensing framework for UAS and C-UAS to facilitate industry growth and rapid technology deployment, including establishing pre-cleared test ranges near urban centers for realistic evaluations, extending license renewals to 5-7 years, and creating low-regulatory-burden pathways for C-UAS development and testing.p. 8
• Echodynemodify — The commenter advocates for the FCC to adopt flexible licensing approaches for UAS detection, modernize the experimental licensing process, implement a blanket experimental authorization with a modular approach, and allow flexible Special Temporary Authority grants for public-private UAS testbeds to enhance UAS detection capabilities.pp. 5, 6
• Ceres Airmodify — The commenter supports the implementation of streamlined experimental licensing for UAS operations, advocating for longer durations, expanded geographic coverage, expedited renewals, and a blanket authorization process, as well as the establishment of real-world test corridors and innovation zones to foster innovation and deployment.pp. 4, 5
• AeroVironmentmodify — The commenter advocates for the FCC to facilitate C-UAS technology development by allowing manufacturers to obtain experimental licenses without federal review, creating a safe harbor from Section 333 to prevent criminal prosecution, clarifying regulations for importing banned drones for testing, and establishing a process for selling sensitive drones directly to government entities.pp. 2, 3, 7, 9
• Association for Uncrewed Vehicle Systems Intermodify — The commenter advocates for the FCC to establish a new Innovation Zone license category for UAS and C-UAS developers, emphasizing the need for streamlined application processes and broader geographic coverage, as well as reforming Part 5 to create an Operational C-UAS authorization category that allows for testing and mitigation within registered zones under specific technical and safety parameters.pp. 11, 14

The acceleration and prioritization of UAS access to specific spectrum bands like 5030-5091 MHz and 450 MHz.

Filers split on: “The FCC should accelerate UAS access to the 5030-5091 MHz band to facilitate robust UAS operations.”

• Ceres Airsupport — The commenter advocates for the FCC to accelerate UAS access to the 5030-5091 MHz band, enhance and streamline interim access mechanisms for UAS operators, and authorize UAS operations across various commercial wireless spectrum bands, including CBRS and others.pp. 4, 12, 13
• Aerospace Industries Association Air Line Pilosupport — The commenter advocates for the FCC to prioritize finalizing existing proceedings for the 5030-5091 MHz and 450 MHz bands to expedite UAS development, support targeted UAS-related proceedings for specific frequency bands instead of a broad approach, explore mechanisms for simplifying operational access within the 5030-5091 MHz band, and move forward with final rules to authorize UAS communications in the 450 MHz band based on the favorable record of the 450 MHz Petition.pp. 8, 9, 10
• Association for Uncrewed Vehicle Systems Intersupport — The commenter advocates for the FCC to prioritize finalizing existing proceedings for the 5030-5091 MHz and 450 MHz bands due to their maturity and strong technical and safety records, expand the Interim Access Mechanism for the 5030-5091 MHz band for more intensive operations, modify technical rules for the 450 MHz band to support UAS communications, advance final rules on the 24.45-24.65 GHz band petitions, and consider Covered List status in the development of equipment authorization and spectrum access frameworks.pp. 4, 6, 7
• AURA Network Systemsmodify — The commenter advocates for the FCC to transition the 450 MHz band to a single nationwide geographic license to enhance UAS operations, prioritize it for UAS due to its unique propagation characteristics that support long-range connectivity, and expedite the finalization of rules to ensure safety-critical connectivity for UAS in controlled airspace.pp. 2, 3
• Utilities Technology Councilsupport — The FCC should provide utilities and critical infrastructure operators access to spectrum for UAS operations, including the 5030-5091 MHz band and the 450 MHz band, to support operational reliability and emergency response.p. 2
• Echodyne — The FCC should improve the speed of service for processing non-networked drone ground stations to facilitate timely deployment.p. 6

The creation of a formalized interagency coordination framework with FAA and NTIA for UAS operations.

Filers split on: “The FCC should establish a formalized interagency coordination framework with the FAA and NTIA to ensure alignment on spectrum allocations and aviation safety standards.”

• Aerospace Industries Association Air Line Pilosupport — The Commission should support the establishment of a formalized FCC-FAA-NTIA interagency coordination framework to ensure alignment on spectrum allocations and operational requirements for UAS.p. 7
• Wireless Infrastructure Association WIAmodify — The commenter advocates for the FCC to ensure effective coordination with the Federal Aviation Administration and other agencies to align regulatory frameworks for UAS operations, while also supporting the adoption of policies that promote the development and deployment of advanced wireless technologies to enhance UAS capabilities.pp. 6, 7
• Ceres Airmodify — The commenter advocates for the FCC to streamline coordination procedures among federal agencies to enhance UAS operations and reduce bottlenecks, and suggests implementing a unified database for UAS operators that would trigger simultaneous notifications to the FCC, FAA, and NTIA to further streamline these processes.pp. 15, 16
• Association for Uncrewed Vehicle Systems Intersupport — The commenter advocates for the FCC to create a formal interagency coordination framework with the FAA and NTIA for spectrum allocations and aviation safety, adopt a technology-neutral, performance-based framework for UAS communications that includes cellular connectivity, and establish a cross-agency process with NTIA and DoW for companies to notify the Commission of spectrum use without full public disclosure.pp. 2, 8, 10
• Alliance for Telecommunications Industry Solutmodify — The commenter advocates for the FCC to take prompt action on established consensus positions regarding cellular-based UAS integration, recognize the importance of a standards-based electronic conspicuity architecture for UAS operations, and facilitate structured engagement among the FCC, NTIA, FAA, and the 3GPP standards community to align on UAS standardization and policy implications.pp. 2, 3
• AeroVironment — The FCC should create a clear and uniform framework allowing lawful and safe counter-UAS testing, development, and demonstrations.p. 7

The design and implementation of dynamic frequency management systems (DFMS) for UAS operations.

Filers split on: “The FCC should establish a dynamic frequency management systems (DFMS) administrator selection process within 45 days to expedite UAS access to the 5030-5091 MHz band.”

• Utilities Technology Councilmodify — The commenter believes that the FCC should design dynamic frequency management systems (DFMS) to support long-range, multi-site missions across large service territories and ensure reliable access to spectrum for utility UAS operations, particularly during emergencies.p. 5
• Ceres Airsupport — The FCC should establish a dynamic frequency management systems (DFMS) administrator selection process within 45 days to expedite UAS access to the 5030-5091 MHz band.p. 12

The establishment of guidelines and authorization processes for C-UAS technologies for SLTT agencies.

Filers split on: “The FCC should establish a list of 'authorized systems' for SLTT agencies to clarify which C-UAS technologies are vetted and can be trusted in high-risk situations.”

• D-Fend Solutionssupport — The commenter advocates for the FCC to streamline authorization processes for qualified state, local, Tribal, and territorial law enforcement agencies to access federally approved C-UAS systems, establish a list of vetted 'authorized systems' for clarity in high-risk situations, provide guidance on acceptable technologies, and publish a trusted UAS and C-UAS list to support public safety efforts.p. 5
• Association for Uncrewed Vehicle Systems Inter — The FCC should issue a declaratory ruling clarifying the scope of Section 333 as applied to C-UAS technologies, distinguishing passive detection and tracking from active jamming and spoofing.p. 11