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Potential Privacy Concerns Would Facilitate Integration into the 
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[On September 18, 2012 we updated this report to reflect an additional 
addressee] 

United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

September 2012: 

Unmanned Aircraft Systems: 

Measuring Progress and Addressing Potential Privacy Concerns Would 
Facilitate Integration into the National Airspace System: 

GAO-12-981: 

GAO Highlights: 

Highlights of GAO-12-981, a report to congressional requesters. 

Why GAO Did This Study: 

UAS do not carry a pilot on board, but instead operate on pre-
programmed routes and by following commands from pilot-operated ground 
stations. UAS can be small, generally 55 pounds or less, or large. 
Current domestic uses include law enforcement, forest fire monitoring, 
border security, weather research, and scientific data collection. 
However, current uses are limited. FAA authorizes UAS operations on a 
case-by-case basis after conducting a safety review. FAA and the other 
federal agencies that have a role or interest in UAS are working to 
provide routine access for UAS into the national airspace system. 

As requested, this report discusses (1) the status of obstacles 
identified in GAO’s 2008 report to integrate UAS into the national 
airspace system, (2) FAA’s progress in meeting its congressional 
requirements for UAS, and (3) emerging issues. GAO reviewed and 
analyzed documents and interviewed relevant government, academic, and 
private-sector entities, as well as UAS users and civil liberties 
organizations. 

What GAO Found: 

Progress has been made, but additional work is needed to overcome many 
of the obstacles to the safe integration of unmanned aircraft systems 
(UAS) that GAO identified in 2008. GAO reported in 2008 that UAS could 
not meet the aviation safety requirements developed for manned 
aircraft and that this posed several obstacles to safe and routine 
operation in the national airspace system. These obstacles still exist 
and include the inability for UAS to sense and avoid other aircraft 
and airborne objects in a manner similar to manned aircraft; 
vulnerabilities in the command and control of UAS operations; the lack 
of technological and operational standards needed to guide safe and 
consistent performance of UAS; and final regulations to accelerate the 
safe integration of UAS into the national airspace system. The Joint 
Planning and Development Office of the FAA has provided UAS 
stakeholders with a framework to collaborate and coordinate their UAS 
integration efforts. 

Congress set forth specific requirements and deadlines in the FAA 
Modernization and Reform Act of 2012 for FAA to safely accelerate UAS 
integration. FAA, in coordination with stakeholders, has begun making 
progress toward completing those requirements, but has missed one 
deadline and could miss others. Many of the requirements entail 
significant work, including completing planning efforts and issuing a 
final rule for small UAS. Most of the requirements are to be achieved 
by December 2015. While FAA has taken steps to meet them, it is 
uncertain when the national airspace system will be prepared to 
accommodate UAS given that these efforts are occurring simultaneously 
and without monitoring to assess the quality of progress over time 
toward the deadlines Congress established. Better monitoring can help 
FAA understand what has been achieved and what remains to be done and 
can also help keep Congress informed about this significant change to 
the aviation landscape. 

Concerns about national security, privacy, and the interference in 
Global Positioning-System (GPS) signals have not been resolved and may 
influence acceptance of routine access for UAS in the national 
airspace system. The Department of Homeland Security’s (DHS) 
Transportation Security Administration (TSA) has the authority to 
regulate security of all modes of transportation, including non-
military UAS. Working with FAA and other federal agencies, TSA 
implements security procedures, such as airspace restrictions like 
those limiting operations into and out of Ronald Reagan National 
Airport. In 2008, GAO recommended that TSA examine the security 
implications of non-military UAS. According to a TSA official, it 
recently reviewed its UAS related advisories and determined that they 
are still applicable. TSA has not provided information on its efforts 
to mitigate security implications of UAS, and GAO believes TSA should 
act on this recommendation. Stakeholder privacy concerns include the 
potential for increased amounts of government surveillance using 
technologies placed on UAS, the collection and use of such data, and 
potential violations of constitutional Fourth Amendment protections 
against unreasonable search and seizures. Currently, no federal agency 
has specific statutory responsibility to regulate privacy matters 
relating to UAS for the entire federal government. Some stakeholders 
have suggested that DHS or the Department of Justice (DOJ) might be 
better positioned to address privacy issues since they generally stem 
from the operational uses of UAS for governmental surveillance and law 
enforcement purposes. Working proactively to address security and 
privacy concerns could help prevent further delays in UAS integration. 
Finally, non-military UAS GPS signals are unencrypted, risking 
potential interruption of the command and control of UAS. 

What GAO Recommends: 

FAA should incorporate regular monitoring of its efforts to assess 
progress toward fulfilling its statutory requirements. FAA, DHS, and 
DOJ should explore whether any actions are needed to guide the 
collection and use of UAS-acquired data. GAO provided a draft of this 
report to officials at DOT, DHS, DOJ, and three other agencies. DHS 
and DOJ concurred with the recommendation; DOT officials agreed to 
consider the recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-12-981]. For more 
information, contact Gerald L.Dillingham at (202) 512-2834 or 
dillinghamg@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Status of Obstacles to Safe and Routine Integration of UAS into the 
National Airspace System: 

FAA Progress toward UAS Integration Requirements: 

Emerging Issues Related to UAS Integration Include Potential Security 
and Privacy Concerns and GPS Jamming and Spoofing: 

Conclusions: 

Recommendations: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Federal Entities with Certificates of Waiver or 
Authorization Approved from January 1, 2012, to July 13, 2012: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Key Federal and Industry UAS Stakeholders and Their Roles: 

Table 2: Selected FAA Modernization and Reform Act of 2012 
Requirements for UAS Integration: 

Figures: 

Figure 1: Conceptual Rendering of Unmanned Aircraft System: 

Figure 2: Examples of Current Uses for UAS and their Altitudes of 
Operation: 

Figure 3: Non-Federal Recipients of Certificates of Waiver or 
Authorization and Special Airworthiness Certificates in the 
Experimental Category and the Location, as of July 13, 2012: 

Figure 4: Illustration of UAS Use for Hurricane Data Collection: 

Abbreviations list: 

2012 Act: FAA Modernization and Reform Act of 2012: 

ADS-B: automatic dependent surveillance-broadcast: 

ASTM International: formerly known as the American Society for Testing 
and Materials: 

CBP: Customs and Border Protection: 

COA: Certificate of Waiver or Authorization: 

DHS: Department of Homeland Security: 

DOD: Department of Defense: 

DOJ: Department of Justice: 

DOT: Department of Transportation: 

EUROCAE: European Organization for Civil Aviation Equipment: 

FAA: Federal Aviation Administration: 

GBSAA: ground-based sense and avoid: 

GPS: Global Positioning-System: 

GSA: General Services Administration: 

JPDO: Joint Planning Development Office: 

MASPS: minimum aviation system performance standards: 

MOPS: minimum operational performance standards: 

NASA: National Aeronautics and Space Administration: 

NDAA: National Defense Authorization Act: 

NextGen: Next Generation Air Transportation System: 

NPRM: Notice of Proposed Rule Making: 

PIA: privacy impact assessment: 

SC 203: Special Committee 203: 

RTCA: formerly the Radio Technical Commission for Aeronautics (now 
RTCA): 

TSA: Transportation Security Administration: 

UAS: unmanned aircraft systems: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

September 14, 2012: 

Congressional Requesters: 

Domestic use of unmanned aircraft systems (UAS) is expected to 
increase as federal, state, and local public safety entities have 
obtained greater access to the national airspace system and the 
Federal Aviation Administration (FAA) develops procedures to allow 
commercial UAS use. UAS aircraft do not carry a pilot onboard but 
instead operate on pre-programmed routes and by following commands 
from pilot-operated ground control stations. These aircraft are also 
referred to as "unmanned aerial vehicles," "remotely piloted 
aircraft," "unmanned aircraft," or "drones." The term "unmanned 
aircraft system" is used to recognize that UAS include not only the 
airframe and power plant, but also associated elements such as a 
ground control station and the communications links as shown in figure 
1. 

Figure 1: Conceptual Rendering of Unmanned Aircraft System: 

[Refer to PDF for image: illustration] 

Over-the-horizon link: 

Air vehicle element: 
* Airframe and structure; 
* Propulsion system; 
* Flight control system; 
* Communication suite; 
* Conflict avoidance system; 
* Navigation system; 
* Electrical system; 
* Flight recovery system. 

Data and voice communications element: 
* Landline or communication relay services; 
* Uplink/downlink spectrum. 

Line-of-sight link: 
     
Control element: 
* Mission planning; 
* Mission control and operations; 
* Conflict avoidance monitoring; 
* Weather avoidance monitoring; 
* Maintenance and logistics; 
* Supply and provisioning; 
* Support and training; 
* Launch and recovery; 
* Towing and taxiing. 

Sources: GAO and NASA. 

[End of figure] 

According to an industry forecast, the growth in the market for 
government and commercial UAS use could result in worldwide 
expenditures of as much as $89.1 billion ($28.5 billion for research 
and development and $60.6 billion for procurement) in aggregate over 
the next decade.[Footnote 1] While the U.S. military has been a 
catalyst for growth in the UAS market, the industry forecaster expects 
the civil UAS market to emerge first based on government use and a 
commercial non-governmental market to emerge more slowly as the 
airspace access issues are being resolved. The growth in the market 
relies in part on regulations that will ensure the safe and routine 
integration of UAS into the national airspace system. Congress and 
other stakeholders have expressed concerns that sufficient progress 
has not been made to allow for UAS to fly in the national airspace 
system in a manner similar to manned aircraft.[Footnote 2],[Footnote 
3] In 2008, we reported that safe and routine UAS access to the 
national airspace system poses several obstacles.[Footnote 4] The FAA 
Modernization and Reform Act (the 2012 Act), enacted in February 2012, 
brought greater focus to integrating UAS into the national airspace 
system, and FAA is working toward implementing the UAS-specific 
requirements set forth in that act.[Footnote 5] Concerns have been 
raised, by members of Congress and a civil liberties organization, 
about the potential implications of increased UAS use including 
potential privacy implications. 

In this context, you asked us to assess: 

1. the status of obstacles to the safe and routine integration of UAS 
into the national airspace system that we identified in our 2008 
report, 

2. FAA's progress in complying with the 2012 Act UAS requirements, and: 

3. emerging issues pertaining to UAS. 

This report focuses on issues related to non-military UAS and is based 
on our analysis of the efforts of FAA and other federal agencies to 
integrate UAS into the national airspace system as well as other 
emerging issues. To describe and assess the status of obstacles to 
safe integration that we previously identified in 2008, we reviewed 
documents provided by and interviewed officials of government, 
academic, and private-sector entities involved with UAS issues. To 
assess FAA's progress in meeting its statutory requirements for UAS 
integration, we reviewed relevant portions of the 2012 Act and 
obtained documents and conducted interviews with the Unmanned Aircraft 
Systems Integration Office at FAA. We also identified criteria for 
assessments from GAO's Standards for Internal Control in the Federal 
Government. We spoke with officials from the FAA's Joint Planning 
Development Office (JPDO) to understand UAS coordination efforts 
across the federal government and other stakeholders. To identify 
emerging issues related to UAS, we reviewed documents provided by and 
interviewed officials from federal, state, and local entities that use 
UAS as well as representatives from the Electronic Frontier Foundation 
and the American Civil Liberties Union regarding UAS security and 
privacy concerns. We also examined pertinent legal requirements to 
which federal agencies must adhere when collecting and using personal 
information. 

We conducted this performance audit from November 2011 to September 
2012 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. Appendix I 
contains more detailed information on our objectives, scope, and 
methodology. 

Background: 

The national airspace system encompasses an average of more than 
100,000 aviation flights per day, including commercial air carriers, 
general aviation,[Footnote 6] and military aircraft. There are 
approximately 18,000 commercial aircraft and 230,000 active general 
aviation aircraft in the United States. Most commercial aircraft 
operate at altitudes between 18,000 and 60,000 feet,[Footnote 7] while 
general aviation aircraft can operate at various altitudes, depending 
on the type of aircraft. For example, the majority of single engine 
aircraft generally operate at altitudes below 10,000 feet, while multi-
engine jet aircraft operate at altitudes up to 50,000 feet. UAS also 
fly at all levels of airspace, generally based on their size. UAS are 
typically described in terms of weight, endurance, purpose of use, and 
altitude of operation. For the purposes of this report, we use the 
broad categories of "large" and "small" UAS. "Small" UAS typically 
weigh less than 55 pounds, fly below 400 feet above ground level, can 
stay airborne for several hours, and can be used for reconnaissance, 
inspection, and surveillance.[Footnote 8] However, some small UAS can 
have longer endurance and can operate beyond line-of-sight capability. 
"Large" UAS, depending on their size and mission, generally fly at 
altitudes up to or greater than 60,000 feet, some can remain airborne 
for multiple days, and are generally used for the purposes of 
surveillance, data gathering, and communications relay. Figure 2 
provides examples of UAS and the altitudes at which they operate. 
Below 18,000 feet, there is a wide variety of types of aircraft, 
including those taking off and landing, and levels of activity at 
different altitudes which impacts the integration of UAS into the 
national airspace system. This variety of flight activity will require 
coordination with various state and federal agencies, e.g., law 
enforcement, agricultural, environmental, and emergency response. The 
activity in this airspace is projected to experience significant 
growth in small independent UAS utilization because of the potential 
economic benefits for the users of UAS. 

Figure 2: Examples of Current Uses for UAS and their Altitudes of 
Operation: 

[Refer to PDF for image: illustration] 

Ground level to 400 feet: 
Small UAS: 
Search and rescue; 
Wildfire tracking; 
Crime scene surveillance. 

400 feet to 18,000 feet: 
Large UAS: 
DHS border surveillance. 

18,000 feet to 60,000 feet: 
Large UAS: 
DOD military training. 

60,000 feet and above: 
Large UAS: 
NASA research projects. 

Source: GAO. 

Note: As a technical reference for elevations, altitudes of 18,000 and 
60,000 feet are mean sea level and 400 feet is above ground level. 

Note: Both NASA and DOD operate at additional flight levels other than 
those depicted. 

[End of figure] 

Currently, FAA authorizes military and non-military (academic 
institutions; federal, state, and local governments including law 
enforcement entities; and private sector entities) UAS operations on a 
limited basis after conducting a case-by-case safety review. Only 
federal, state, and local government agencies can apply for and be 
granted a Certificate of Waiver or Authorization (COA); private sector 
entities (civil operators) may apply for special airworthiness 
certificates in the experimental category that allows them to operate 
UAS.[Footnote 9] Between January 1, 2012, and July 13, 2012, FAA 
issued 342 COAs to 106 federal, state, and local government entities 
across the United States, including law enforcement entities as well 
as academic institutions. Over the same time period, FAA issued 8 
special airworthiness certifications for experimental use to 4 UAS 
manufacturers. Presently, under COA or special airworthiness 
certification, UAS operations are permitted for specific time frames 
(generally 12 to 24 months), locations, and operations and thus the 
COA holder may fly multiple times under a specific COA. However, it is 
not uncommon for an entity to receive multiple COAs for various 
missions and locations. See figure 3 for the locations of COA's and 
special airworthiness certificates in the experimental category as of 
July 13, 2012. See appendix II for the list of federal entities with 
COAs. 

Figure 3: Non-Federal Recipients of Certificates of Waiver or 
Authorization and Special Airworthiness Certificates in the 
Experimental Category and the Location, as of July 13, 2012: 

[Refer to PDF for image: illustrated U.S. map] 

Map depicts locations of the following: 

Universities/academia: 19; 
Law Enforcement: 9; 
State: 1; 
Experimental waivers: 7. 

Source: FAA and Map Resource. 

[End of figure] 

Several federal agencies use UAS to fulfill their mission, including 
the Department of Homeland Security (DHS), the Department of Defense 
(DOD), the National Aeronautics and Space Administration (NASA), and 
the Department of Justice (DOJ). According to DHS officials, Customs 
and Border Protection (CBP) owns and uses nine UAS that it operates 
for its own border security missions as well as for missions in 
conjunction with other agencies, and would like to expand its fleet of 
UAS.[Footnote 10] DOD has successfully used UAS for intelligence, 
surveillance, reconnaissance, and combat missions,[Footnote 11] and 
the United States military services expect to conduct more UAS 
training flights across the contiguous United States, as combat 
operations in Afghanistan and elsewhere decrease.[Footnote 12] While 
many of DOD's UAS operations currently take place outside of the 
United States, the military services require access to the national 
airspace system to conduct UAS training. DOD has also assisted DHS in 
border security missions, including two missions since 2006 where the 
National Guard provided support in four southwestern Border States. 
NASA uses UAS primarily for research purposes, such as a large UAS 
(Predator B) for wildfire mapping and investigations as well as the 
collection of hurricane data (see figure 4). Entities within DOJ have 
used UAS to fulfill its law enforcement missions. 

Figure 4: Illustration of UAS Use for Hurricane Data Collection: 

[Refer to PDF for image: illustration] 

Base of operations: 

Climb to altitude of 60,000 feet; 
1,500 nautical miles transit to hurricane (12-24 hours); 
Expendable sensors collect air and ocean data; 
UAS flies above hurricane collecting real-time data. 

Sources: GAO and AeroVironment. 

[End of figure] 

Although current domestic uses of UAS are limited to include 
activities such as law enforcement, search and rescue, forensic 
photography, monitoring or fighting forest fires, border security, 
weather research, and scientific data collection, UAS also have a wide 
range of other potential uses. These include commercial uses such as 
pipeline, utility, and farm fence inspections; vehicular traffic 
monitoring; real-estate and construction-site photography; relaying 
telecommunication signals; fishery protection and monitoring; and crop 
dusting. FAA's goal is to eventually permit, to the greatest extent 
possible, routine UAS operations in the national airspace system while 
ensuring safety. As the list of potential uses for UAS grows, so do 
the concerns about how they might affect existing military and non-
military aviation as well as concerns about how they might be used. 

According to an industry forecast, the market for government and 
commercial use of UAS is expected to grow, with small UAS having the 
greatest growth potential.[Footnote 13] As previously stated, this 
forecast states that the worldwide expenditures on UAS and related 
research could be potentially as much as $89.1 billion in aggregate 
over the next decade. The associated worldwide research and 
development for production is estimated to be $28.5 billion of the 
$89.1 billion.[Footnote 14] The United States could account for 62 
percent of this research and development investment. A 2008 forecast 
noted that while civil and commercial UAS markets will eventually 
emerge, a likely scenario would be for a UAS-leasing industry to 
emerge first to serve the needs of businesses that do not want to 
invest in UAS ownership. 

Domestically, state and local law enforcement entities represent the 
greatest potential users of small UAS in the near term because they 
can offer a simple and cost effective solution for airborne law 
enforcement activities. For example, federal officials and one 
airborne law enforcement official said that a small UAS costing 
between $30,000 and $50,000 is more likely to be purchased by state 
and local law enforcement entities because the cost is nearly 
equivalent to that of a patrol car and much less than a manned 
aircraft. According to an industry trade group, local law enforcement 
can potentially choose from about 146 different types of small UAS 
being manufactured by about 69 different companies in the U.S. 

In addition to FAA, many federal and private sector entities have 
roles in the effort to integrate UAS into the national airspace 
system. For example, DHS's Transportation Security Administration 
(TSA) has authority to regulate the security of all transportation 
modes to ensure that appropriate safeguards are in place. According to 
TSA, its aviation security efforts include addressing risks, threats, 
and vulnerabilities related to non-military UAS. Table 1 provides an 
overview of key federal and industry UAS stakeholders' roles in the 
integration effort. 

Table 1: Key Federal and Industry UAS Stakeholders and Their Roles: 

Federal entity: 

Key stakeholders: FAA; 
UAS integration role: FAA's UAS Integration Office is responsible for 
ensuring that UAS operate safely in the national airspace system. 

Key stakeholders: DOD; 
UAS integration role: DOD provides FAA with UAS operational and safety 
data, as well as research and development support. 

Key stakeholders: NASA; 
UAS integration role: NASA provides research and development and 
testing on UAS integration efforts. 

Key stakeholders: JPDO; 
UAS integration role: FAA's JPDO provides a framework for UAS 
stakeholders to collaborate and coordinate on their UAS integration 
efforts. 

Key stakeholders: DHS; 
UAS integration role: DHS's CBP has provided flight demonstrations to 
FAA's Next Generation Air Transportation System (NextGen) Office. 

Key stakeholders: GSA; 
UAS integration role: The General Services Administration (GSA) is 
responsible for tracking the federal government's UAS inventory. 
Federal agencies that own or lease UAS report their UAS inventory, 
cost and utilization data to GSA. 

Key stakeholders: DOJ; 
UAS integration role: DOJ's National Institute of Justice is 
responsible, in part, for addressing the technology needs--including 
UAS--of local, state, and tribal law enforcement agencies. 

Key stakeholders: UAS Executive Committee[A]; 
UAS integration role: The UAS Executive Committee is composed of 
senior executives from federal agencies including FAA, DOD, NASA, and 
DHS and is responsible for identifying solutions to the range of 
technical, procedural, and policy concerns arising from UAS 
integration. 

Key stakeholders: UAS Aviation Rulemaking Committee[B]; 
UAS integration role: The UAS Aviation Rulemaking Committee was 
chartered in 2011 to provide a mechanism for industry and academic 
stakeholders as well as other federal, state, and local government 
entities to provide recommendations and standards to FAA on issues 
related to UAS integration. 

Standards making bodies: 

Key stakeholders: RTCA SC-203[C]; 
UAS integration role: RTCA is a private, not-for-profit organization 
consisting of industry experts. SC 203 is responsible for developing 
consensus-based recommendations and standards regarding UAS 
communications, navigation, surveillance, and air traffic management 
system issues. 

Key stakeholders: ASTM International Committee F38[D]; 
UAS integration role: ASTM International Committee F38 is a private 
organization consisting of industry experts that is responsible for 
developing standards and consensus based recommendations for small UAS 
integration into the national airspace system and worldwide. 

Source: GAO analysis of FAA data. 

[A] The UAS Executive Committee was formed as a result of the National 
Defense Authorization Act (NDAA) for Fiscal Year 2010 (Pub. L. No. 111-
84, 123 Stat. 2190 (2009)). Section 935 of 2010 NDAA states that "The 
Secretary of Defense and the Secretary of Transportation shall, after 
consultation with the Secretary of Homeland Security, jointly develop 
a plan for providing expanded access to the national airspace system 
for unmanned aircraft systems of the Department of Defense" and 
requires the Executive Committee members to provide Congress with, 
among other things, a communication plan, specific milestones for 
expanded access to the national airspace system, and report on their 
efforts. 

[B] FAA also chartered a small UAS Aviation Rulemaking Committee in 
2008, which made recommendations for the standards and regulations for 
the operation of small UAS in the national airspace system. 

[C] RTCA, formerly the Radio Technical Commission for Aeronautics, 
serves as a federal advisory committee, and its recommendations are 
the basis for a number of FAA's policy, program, and regulatory 
decisions. 

[D] ASTM International, formerly known as the American Society for 
Testing and Materials, works to deliver the test methods, 
specifications, guides, and practices that support industries and 
governments worldwide. 

[End of table] 

FAA has also historically partnered with a range of industry, federal 
research entities, universities, and international organizations for 
research on UAS. These types of research and development agreements 
are categorized as Federally Funded Research and Development Centers, 
[Footnote 15] Cooperative Research and Development Agreements, 
[Footnote 16] and International Agreements.[Footnote 17] These 
agreements typically require the agency, organization, or company to 
perform types of research and provide FAA with the data in exchange 
for funding. For example, FAA established an agreement with the 
European Union to initiate, coordinate, and prioritize the activities 
necessary for supporting the development of provisions required for 
the evolution of UAS to full recognition as a legitimate category-of-
airspace user. 

In 2008, we reported that federal actions were needed to ensure safety 
and expand the potential uses of UAS within the national airspace 
system.[Footnote 18] We stated that Congress should consider creating 
an overarching body within FAA to address obstacles for routine 
access. While such a body has not been created, as discussed in this 
report, FAA is combining its UAS safety and air traffic staff under 
one executive, and JPDO has provided UAS stakeholders with a framework 
to collaborate and coordinate their UAS integration efforts. FAA 
implemented our recommendations that it (1) finalize and issue a UAS 
program plan to address the future of UAS and (2) analyze the data FAA 
collects on UAS operations under its COAs and establish a process to 
analyze DOD's data on its UAS research, development, and operations. 
In addition, to ensure that appropriate UAS security controls are in 
place when civil-use UAS have routine access to the national airspace 
system, we recommended 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. As discussed later in this report, TSA 
has taken some steps but we have not yet closed this recommendation. 

Status of Obstacles to Safe and Routine Integration of UAS into the 
National Airspace System: 

In 2008, we reported that UAS could not meet the aviation safety 
requirements developed for manned aircraft and that UAS posed several 
obstacles to operating safely and routinely in the national airspace 
system. FAA and others have continued their efforts to address these 
obstacles, but many still remain, including: 

1. the inability for UAS to detect, sense, and avoid other aircraft 
and airborne objects in a manner similar to "see and avoid" by a pilot 
in a manned aircraft; 

2. vulnerabilities in the command and control of UAS operations; 

3. the limited human factors engineering incorporated into UAS 
technologies; 

4. unreliable UAS performance; 

5. the lack of technological and operational standards needed to guide 
the safe and consistent performance of UAS; 

6. the lack of final regulations to guide the safe integration of UAS 
into the national airspace system; and: 

7. the transition to NextGen.[Footnote 19] 

Sense and Avoid Technologies: 

To date, no suitable technology has been deployed that would provide 
UAS with the capability to sense and avoid other aircraft and airborne 
objects and to comply completely with FAA regulatory requirements of 
the national airspace system.[Footnote 20] However, research and 
development efforts by FAA, DOD, NASA, and MITRE[Footnote 21], among 
others, suggests that potential solutions to the sense and avoid 
obstacle may be available in the near term. With no pilot to scan the 
sky, most UAS do not have an on-board capability to directly "see" 
other aircraft. Consequently, UAS must possess the capability to sense 
and avoid an object using on-board equipment, or within the line-of-
sight of a human on the ground or in a chase aircraft,[Footnote 22] or 
by other means, such as ground-based sense and avoid (GBSAA).[Footnote 
23] Many UAS, particularly smaller models, will likely operate at 
altitudes below 18,000 feet, sharing airspace with other aircraft or 
flight objects. Sensing and avoiding other vehicles or objects through 
the use of technology represents a particular challenge for small UAS 
because aircraft, obstructions, or flight objects at low altitude 
often do not transmit an electronic signal to identify themselves, and 
even if they did, many small UAS do not have equipment to detect such 
signals and may be too small to carry such equipment. Since 2008, FAA 
and other federal agencies have managed several research activities to 
support meeting the sense and avoid requirements. DOD officials told 
us that the Department of the Army is working on a GBSAA system that 
will detect other airborne objects and allow the pilot to direct the 
UAS to maneuver to a safe location. The Army has successfully tested 
one GBSAA system, but this system may not be usable on all types of 
UAS. Another potential system to address this obstacle is an airborne 
sense and avoid system, which could equip UAS with the same Global 
Positioning System (GPS)-based transponder system that will be used in 
FAA's NextGen air-traffic-management system and with which some manned 
aircraft are starting to be equipped. UAS could also be equipped with 
other systems comprised of sensors for detecting airborne aircraft or 
other objects, computer software to track and potentially resolve 
collision threats and displays to provide maneuvering advice and/or 
information to the pilot. In 2012, NASA researchers at Dryden Flight 
Research Center successfully tested an automatic dependent 
surveillance-broadcast (ADS-B) transponder system on its Ikhana UAS. 
[Footnote 24] [Footnote 25] An airborne sense and avoid system could 
include ADS-B, along with other sensors such as optical/infrared 
cameras and radar. However, not all aircraft will be required to be 
equipped with ADS-B. Until technical solutions for UAS to sense and 
avoid are tested and validated, both small and large UAS will continue 
to mitigate the "see and avoid" obstacle by operating within line-of-
sight, using a chase aircraft, or operating in segregated airspace. 

Command and Control Communications: 

Similar to what we reported in 2008, ensuring uninterrupted command 
and control for both small and large UAS remains a key obstacle for 
safe and routine integration into the national airspace system. Since 
UAS fly based on pre-programmed flight paths and by commands from a 
pilot-operated ground control station, the ability to maintain the 
integrity of command and control signals are critically important to 
ensure that the UAS operates as expected and as intended. 

"Lost Link" Scenarios: 

FAA and MITRE have been researching solutions to lost link, but the 
standardization of lost link procedures, for both small and large UAS, 
has not been finalized. In a "lost link" scenario, the command and 
control link between the UAS and the ground control station is broken 
because of either environmental or technological issues, which could 
lead to loss of control of the UAS. To address this type of situation, 
UAS generally have pre-programmed maneuvers that may direct the UAS to 
first hover or circle in the airspace for a certain period of time to 
reestablish its radio link. If the link is not reestablished, then the 
UAS will return to "home" or the location from which it was launched, 
or execute an unintentional flight termination at its current 
location. It is important that air traffic controllers know where and 
how all aircraft are operating so they can ensure the safe separation 
of aircraft in their airspace.[Footnote 26] Currently, according to 
FAA, each COA has a specific lost link procedure unique to that 
particular operation and air traffic controllers should have a copy 
for reference at all times. Until procedures for a lost link scenario 
have been standardized across all types of UAS, air traffic 
controllers must rely on the lost link procedures established in each 
COA to know what a particular UAS will do in such a scenario. 

Dedicated Radio-Frequency Spectrum: 

Progress has been made in obtaining additional dedicated radio-
frequency spectrum for UAS operations, but additional dedicated 
spectrum, including satellite spectrum, is still needed to ensure 
secure and continuous communications for both small and large UAS 
operations. In 2008, we reported that the lack of protected radio-
frequency spectrum for UAS operations heightens the possibility that 
an pilot could lose command and control of a UAS. Unlike manned 
aircraft--which use dedicated, protected radio frequencies--UAS 
currently use unprotected radio spectrum and, like any other wireless 
technology, remain vulnerable to unintentional or intentional 
interference. This remains a key security and safety vulnerability 
because, in contrast to a manned aircraft in which the pilot has 
direct physical control of the aircraft, interruption of radio 
transmissions can sever the UAS's only means of control. At the 2011 
World Radio Conference, additional aviation protected spectrum was 
allocated for line of sight control of for both public and civil UAS 
operations. 

UAS stakeholders are working to develop and validate hardware and 
standards for communications operating in allocated spectrum. 
Specifically, according to NASA, it is developing, in conjunction with 
Rockwell Collins, a radio for control and a non-payload communications 
data link that would provide secure communications. In addition, FAA's 
UAS Research Management Plan identified 13 activities designed to 
mitigate command, control, and communication obstacles. One effort 
focused on characterizing the capacity and performance impact of UAS 
operations on air-traffic-control communications systems. In addition, 
a demonstration led by Embry-Riddle Aeronautical University in 2010 
simulated a national airspace communications system[Footnote 27] to 
demonstrate the process and ability of a UAS pilot to establish 
alternate voice communications with air traffic control if the primary 
radio communications link were lost. NASA is also performing 
additional command and control research. As part of its 5-year UAS 
Integration in the National Airspace System Project, NASA is working 
to develop and verify a communications system prototype to support the 
allocation of spectrum for safe UAS operations. 

Human Factors: 

UAS stakeholders have been developing solutions to human factor issues 
for both small and large UAS. According to FAA, human factors are 
defined as a broad field that examines the interaction between people, 
machines, and the environment for the purpose of improving performance 
and reducing errors. Human factors are important for UAS operations as 
the pilot and aircraft are not collocated. The separation of pilot and 
aircraft creates a number of issues, including loss of sensory cues 
valuable for flight control, delays in control and communications 
loops, and difficulty in scanning the visual environment surrounding 
the unmanned aircraft. In 2008, we reported that UAS developers had 
not fully incorporated human factors engineering in their products. 
Such engineering incorporates what is known about people, their 
abilities, characteristics, and limitations into the design of the 
equipment they use, the environments in which they function, and the 
jobs they perform. Several human factors issues have not yet been 
resolved. Specifically, 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,and UAS pilot-
training requirements. As part of NASA's UAS Integration in the 
National Airspace System Project, NASA is working to develop human 
factor guidelines for ground control stations. NASA plans to share the 
results with RTCA SC-203 to inform the recommended guidelines. In 
addition, the U.S. Army is working to develop universal ground control 
stations, which would allow UAS pilots to fly different types of UAS 
without having to be trained on multiple configurations of a ground 
control station. 

Reliability: 

FAA and NASA are taking steps to ensure the reliability of both small 
and large UAS by developing a certification process specific to UAS. 
Currently, FAA has a process and regulations in place for certifying 
any new aircraft type and allowing it access to the national airspace 
system. UAS stakeholders we interviewed stated that this process is 
costly and manpower intensive, and does not assure certification. One 
manufacturer that tried certifying a UAS through this process noted 
that it took one year and cost $1 million to permit a single airframe 
to have access to the national airspace system. According to FAA, 
another manufacturer recently started this process. FAA's Research and 
Development office is working to identify the substantive differences 
in how to meet the certification standards for manned and unmanned 
aircraft. According to its Research Management Plan, the office has 
six activities under way that support the development of UAS-specific 
certification and airworthiness standards. One such activity brought 
subject matter experts together to examine how the varied requirements 
of certification[Footnote 28] relate to operations of UAS in the 
national airspace system. A 2007 study examined the relevant federal 
regulations, statutes, orders, and policies applicable to UAS 
operating in the national airspace. It found that 30 percent of the 
certification regulations would apply to UAS, 16 percent would not 
apply, and it was unclear whether the remaining 54 percent would apply. 

Standards: 

Standards-making bodies are working to develop safety, reliability, 
and performance standards for UAS. The complexities of the issues to 
be addressed and the lack of operational and safety data have hindered 
the standards development process. Minimum aviation system performance 
standards (MASPS) and minimum operational performance standards (MOPS) 
are needed in the areas of: operational and navigational performance; 
command and control communications; and sense and avoid capabilities. 
RTCA, a standards-making body chartered by FAA, established a federal 
advisory committee called the Special Committee 203 (or SC 203), to 
establish MASPS and MOPS for FAA to use in developing UAS regulations. 
Individuals from academia and the private sector serve on the 
committee, along with FAA, NASA, and DOD officials. According to an 
RTCA official, both DOD and NASA are sharing the results of their UAS 
flight experience and research and development efforts to assist RTCA 
in the standards development process. In addition, an international 
voluntary consensus standards-making body known as ASTM International 
Committee F38 on UAS, is working with FAA to develop standards to 
support the integration of small UAS into the national airspace 
system. An official from RTCA suggested that the standards-making 
process might be accelerated if RTCA SC 203 could start by producing 
an initial set of standards for a specific UAS with a clearly defined 
mission. RTCA SC 203 could then utilize those initial standards, along 
with the subsequent safety and performance data from those operations, 
to develop additional standards for increasingly complex UAS functions 
and missions. 

While FAA officials stated that the agency's efforts to develop 
standards have been slowed by the lack of operational data, FAA has 
not utilized the operational data it does possess. In 2008, we 
recommended that FAA expedite efforts to ensure that UAS have routine 
access to the national airspace system by analyzing the data FAA 
collects on UAS operations as part of its COA process and establish a 
process to analyze DOD data on its UAS research, development, and 
operations.[Footnote 29] Safety and operational data can directly 
support the development of UAS technology. For example, in the 
development and validation of UAS technology, GBSAA for example, the 
FAA requires data to demonstrate that cooperative and non-cooperative 
aircraft can be consistently identified at all operational altitudes 
and ranges, and the proposed system can effectively avoid a potential 
collision. To date, FAA has not utilized the operational data 
available to the agency as part of the COA process for the development 
of standards. According to a DOD official, it started providing, FAA 
with 7 years of operational and safety data in September 2011. 
[Footnote 30] However, according to FAA officials, the agency has been 
unable to use the data to support its standards development because 
the data was not in a usable format. As of June 2012, FAA was still 
defining the data fields it needed and how the data will be used to 
support the development of performance or certification standards and 
the regulatory process for UAS. FAA officials have since communicated 
their data requirements to DOD and also provided us with a list of 
general data requirements. Furthermore, FAA officials also noted that 
the agency currently has a contract with MITRE to address these data 
challenges in fiscal year 2013. 

Regulations: 

According to FAA, its draft Notice of Proposed Rule Making (NPRM) that 
would define and govern how small UAS would potentially operate in the 
national airspace system will be issued at the end of 2012. Concerns 
relating to the process and potential timeline for publishing the 
final small UAS rule will be discussed later in this report. FAA 
regulations govern the routine operation of most aircraft in the 
national airspace system.[Footnote 31] However, these regulations do 
not contain provisions that explicitly address issues relating to UAS. 
As we highlighted in our 2008 report, existing regulations may need to 
be modified to address the unique characteristics of UAS to prevent 
"undue harm to manned aircraft." Today, UAS continue to operate as 
exceptions to the regulatory framework rather than being governed by 
it. Without specific and permanent regulations for safe operation of 
UAS, federal stakeholders, including DOD, continue to face challenges 
and limitations on their UAS operations. The lack of final regulations 
could hinder the acceleration of safe and routine integration of UAS 
into the national airspace system. In addition, as we stated earlier, 
the market for government and commercial use of UAS is expected to 
grow with small UAS having the greatest potential and a market 
forecast indicates that the United States could account for 62 percent 
of the world's research and development investment for UAS technology 
over the coming decade. 

Transition to NextGen: 

As FAA and others continue to address the challenges to UAS 
integration, they must do so with the expected changes to the 
operations of the national airspace system as a result of NextGen in 
mind. As UAS operations are expected to proliferate, it is important 
that they are able to safely operate in the NextGen environment. Both 
FAA's NextGen Integration Office and JPDO are working to coordinate 
UAS and NextGen research and development. NextGen is a new satellite-
based air traffic management system that will replace the current 
radar-based system for a variety of aircraft types, including UAS. 
NextGen is expected to enhance the safety and capacity of the air 
transport system and will provide a number of operational, technical, 
economic, and environmental opportunities and challenges for all 
national airspace system users. NextGen will use technological 
advancements to identify the location of aircraft as they travel in 
the national airspace system and develop efficient flight paths. The 
transition to NextGen and the integration of UAS into the national 
airspace system entail many of the same technological issues. We have 
previously reported on research gaps,[Footnote 32] and the Department 
of Transportation's Office of Inspector General recently reported that 
significant research and development issues remain unresolved, 
including developing cross-agency requirements, standards, procedures, 
and avionics for introducing UAS into the NextGen environment, among 
others.[Footnote 33] According to a JPDO official, UAS and NextGen 
stakeholders should focus on critical and cross-cutting long-term 
research and development issues. These include UAS technologies, human 
factors, ground-control stations, communications, and sense and avoid, 
all associated with UAS flying with manned aircraft in a future 
NextGen airspace. 

In addition, the NextGen Integration Office recently published its 
NextGen Implementation Plan. The Implementation Plan identified a 
number of NextGen-related efforts that could benefit UAS integration. 
For example, in July 2011, FAA achieved initial operating capability 
with ADS-B transponder-system data integrated into the air traffic 
control's automations system at the New York Terminal Radar Approach 
Control facility. As we stated earlier in this report, developing and 
testing ADS-B transponder-system technology may be a key aspect of an 
airborne sense and avoid system, which will allow for pilots of UAS to 
see and avoid other aircraft. Furthermore, the Office of Management 
and Budget recently tasked the NextGen partner agencies to develop a 
strategic, multiagency, NextGen UAS road map with assistance from the 
JPDO.[Footnote 34] This road map would identify the most critical 
technology issues involved in establishing a plan for UAS operations 
as a part of NextGen. Coordinating UAS integration and NextGen 
implementation efforts could lead to opportunities to cost-share 
demonstrations, eliminate duplicate investments and efforts, and 
accelerate the FAA's use of data and requirements to develop standards 
and regulations. 

Similar to FAA's NextGen efforts, other countries are also looking to 
modernize their air traffic control systems and develop standards for 
UAS. FAA has worked with the international community and Europe in 
particular on harmonization of their systems to ensure that airplanes 
can seamlessly fly and transfer between different air traffic control 
systems. As other countries work toward integrating UAS in their 
respective airspaces, similar harmonization efforts will be critical 
to developing standards and operational procedures that could enable 
UAS to seamlessly cross international borders and U.S. manufacturers 
to sell their products in the global marketplace. International bodies 
and individual countries face challenges similar to those that the 
United States faces in integrating UAS into their respective airspaces 
and have similar efforts underway to develop UAS standards. The 
European Organization for Civil Aviation Equipment (EUROCAE) working 
group 73 is developing standards for large UAS (above 150 kilograms) 
that would be adopted by the European Union as a whole; and working 
group 93 is developing standards for small UAS (under 150 kilograms) 
that would be approved on a country-by-country basis. Both EUROCAE 
working groups are coordinating with RTCA SC 203 and ASTM F38 to try 
to ensure harmonized standards. In addition, as of April 2012, the 
International Civil Aviation Organization amended its International 
Standards, Rules of the Air to identify high level requirements 
related to UAS while noting that certification and licensing standards 
have not yet been developed. 

FAA Progress toward UAS Integration Requirements: 

Concerned with the pace of progress of UAS integration, Congress set 
forth specific requirements and deadlines for FAA to safely accelerate 
UAS integration in the 2012 Act. FAA--with its federal and other 
stakeholders--has begun making progress toward completing those 
requirements, but has missed one deadline and could miss others. Many 
of the requirements will require significant work on the part of FAA 
and its stakeholders to complete. This work involves developing 
detailed steps for achieving safe and routine access to the national 
airspace system, including defining the characteristics of safe 
integration, identifying needed research and development to achieve 
integration, and identifying the information needed to issue 
regulations, among other tasks. By meeting these requirements, FAA 
will be better positioned not only to address the obstacles cited 
earlier, but to achieve UAS integration. 

The requirements in the 2012 Act include streamlining the existing COA 
process for public safety entities, developing test ranges for 
developing and validating UAS technologies and potential standards to 
completing planning efforts and issuing a final rule for small UAS. 
Most of the requirements must be achieved between May 2012 and 
December 2015 (see table 2), and FAA is working to identify the 
actions and resources needed to meet those requirements. The 2012 Act 
sets an aggressive time frame for FAA to integrate UAS into the 
national airspace system. In our 2008 report, we recommended that FAA 
expedite efforts to ensure that UAS have routine access to the 
national airspace system by finalizing and issuing a program plan to 
address future issues. In 2010, FAA implemented our recommendation by 
issuing a 2-page road map highlighting steps towards UAS integration, 
which included the goal of UAS having routine access to the national 
airspace system after 2020. 

Table 2: Selected FAA Modernization and Reform Act of 2012 
Requirements for UAS Integration: 

Approximate deadline[A]: 05/14/2012; 
FAA Modernization and Reform Act of 2012 requirement: Enter into 
agreements with appropriate government agencies to simplify the 
process for issuing COAs or waivers for public UAS; 
Status of action: In process. 

Approximate deadline[A]: 08/12/2012; 
FAA Modernization and Reform Act of 2012 requirement: Establish a 
program to integrate UAS into the national airspace system at 6 test 
ranges. This program is to terminate 5 years after date of enactment; 
Status of action: In process. 

Approximate deadline[A]: 08/12/2012; 
FAA Modernization and Reform Act of 2012 requirement: Develop an 
Arctic UAS operation plan and initiate a process to work with relevant 
federal agencies and national and international communities to 
designate permanent areas in the Arctic where small unmanned aircraft 
may operate 24 hours per day for research and commercial purposes; 
Status of action: In process. 

Approximate deadline[A]: 08/12/2012; 
FAA Modernization and Reform Act of 2012 requirement: Determine 
whether certain UAS can fly safely in the national airspace system 
before the completion of the Act's requirements for a comprehensive 
plan and rulemaking to safely accelerate the integration of civil UAS 
into the national airspace system or the Act's requirement for 
issuance of guidance regarding the operation of public UAS including 
operating a UAS with a COA or waiver; 
Status of action: In process. 

Approximate deadline[A]: 11/10/2012; 
FAA Modernization and Reform Act of 2012 requirement: Expedite the 
issuance of a COA for public safety entities; 
Status of action: Completed. 

Approximate deadline[A]: 11/10/2012; 
FAA Modernization and Reform Act of 2012 requirement: Develop a 
comprehensive plan to safely accelerate integration of civil UAS into 
national airspace system; 
Status of action: In process. 

Approximate deadline[A]: 11/10/2012; 
FAA Modernization and Reform Act of 2012 requirement: Issue guidance 
regarding operation of civil UAS to expedite COA process; 
provide collaborative process with public agencies to allow an 
incremental expansion of access into the national airspace system as 
technology matures and the necessary safety analysis and data become 
available and until standards are completed and technology issues are 
resolved; facilitate capability of public entities to develop and use 
test ranges; provide guidance on public entities' responsibility for 
operation; 
Status of action: In process. 

Approximate deadline[A]: 02/14/2013; 
FAA Modernization and Reform Act of 2012 requirement: Approve and make 
publicly available a 5-year road map for the introduction of civil UAS 
into national airspace system, to be updated annually; 
Status of action: In process. 

Approximate deadline[A]: 02/14/2013; 
FAA Modernization and Reform Act of 2012 requirement: Submit to 
Congress a copy of the comprehensive plan; 
Status of action: In process. 

Approximate deadline[A]: 02/12/2013; 
FAA Modernization and Reform Act of 2012 requirement: Make operational 
at least one project at a test range; 
Status of action: None to date. 

Approximate deadline[A]: 08/14/2014; 
FAA Modernization and Reform Act of 2012 requirement: Publish in the 
Federal Register the Final Rule on small UAS; 
Status of action: In process. 

Approximate deadline[A]: 08/14/2014; 
FAA Modernization and Reform Act of 2012 requirement: Publish in the 
Federal Register a Notice of Proposed Rulemaking to implement 
recommendations of the comprehensive plan; 
Status of action: None to date. 

Approximate deadline[A]: 08/14/2014; 
FAA Modernization and Reform Act of 2012 requirement: Publish in the 
Federal Register an update to the Administration's policy statement on 
UAS in Docket No. FAA-2006-25714; 
Status of action: None to date. 

Approximate deadline[A]: 09/30/2015; 
FAA Modernization and Reform Act of 2012 requirement: Achieve safe 
integration of civil UAS into the national airspace system; 
Status of action: In process. 

Approximate deadline[A]: 12/14/2015; 
FAA Modernization and Reform Act of 2012 requirement: Publish in the 
Federal Register a Final Rule to implement the recommendations of the 
comprehensive plan; 
Status of action: None to date. 

Approximate deadline[A]: 12/31/2015; 
FAA Modernization and Reform Act of 2012 requirement: Develop and 
implement operational and certification requirements for public UAS in 
national airspace system; 
Status of action: In process. 

Approximate deadline[A]: 02/14/2017; 
FAA Modernization and Reform Act of 2012 requirement: Report to 
Congress on the test ranges; 
Status of action: None to date. 

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

[A] Some of these deadlines are approximate. For example, while the 
2012 Act requires that a program to integrate UAS at 6 test ranges is 
to be established no later than 08/12/2012, such test ranges could 
conceivably be established prior to that date. The date such a program 
is actually established triggers a deadline for an additional 
requirement. 

[End of table] 

FAA has several efforts under way to satisfy its statutory 
requirements for safe integration of UAS. These include four broad 
categories of requirements, including: (1) developing plans for the 
integration of UAS into the national airspace system; (2) changes to 
the COA process; (3) efforts to develop UAS test ranges; and (4) 
developing, revising, or finalizing regulations and policies related 
to UAS. 

* Comprehensive plan and road map. FAA, with the assistance of JPDO, 
is developing several planning documents required by the 2012 Act, 
including a 5-year roadmap and comprehensive plan to outline the steps 
toward safe integration. The road map, which FAA must complete and 
make publicly available by February 2013, is intended to help 
facilitate UAS integration into the national airspace system. Given 
its unique role in managing partnerships among federal agencies for 
NextGen, JPDO is leading the development of a comprehensive plan for 
UAS on behalf of FAA. As required by law, this plan shall contain, 
among other elements, recommendations on the small UAS rulemaking, a 
phased-in approach to and timeline for the integration of civil UAS 
into the national airspace system, and the establishment of a process 
to develop certification, flight standards, and air traffic 
requirements at UAS test ranges. To assist in the development of the 
comprehensive plan, FAA is developing a Concept of Operations to guide 
efficient federal resources planning for UAS integration. To date, FAA 
has not developed measures for assessing the various efforts to 
achieve safe integration by September 2015. The 2012 Act specifies 
content for a more comprehensive plan than what was laid out in the 2-
page road map, but it does not set forth any expectation for 
monitoring to assess the quality of progress over time toward meeting 
the range of activities to be outlined in the plan. Our Standards for 
Internal Control in the Federal Government provide the overall 
framework for establishing and maintaining internal control and for 
identifying and addressing major performance and management challenges 
and areas at greatest risk of fraud, waste, abuse, and mismanagement. 
[Footnote 35] One of those standards is monitoring, which is an 
internal control designed to assess the quality of performance over 
time. This internal control should generally be designed to assure 
that ongoing monitoring occurs in the course of normal operations and 
that it is performed continually and is ingrained in the agency's 
operations. In light of the time frames and complicated tasks ahead, 
the absence of regular monitoring precludes the agency and Congress 
from assessing progress toward completion of the 2012 Act requirements. 

* Changes to the COA process. FAA has changed the existing COA process 
in response to the 2012 Act, including taking steps to expedite COAs 
for public safety entities and finalizing agreements with government 
agencies to expedite the COA or waiver process for UAS. First, FAA 
extended the length of UAS authorization from a 12-month period to a 
24-month period so that those entities receiving COAs do not have to 
reapply as frequently. Second, FAA worked with DOJ's National 
Institute of Justice to develop a process through a memorandum of 
understanding to meet the operational requirements of law enforcement 
entities, which are expected to be early adopters of small UAS. 
According to FAA, two law enforcement entities currently use small UAS 
on a consistent basis for their missions and operations. Officials 
from both FAA and DOJ have reached agreement on a draft version of the 
memorandum of understanding establishing this process; the memorandum 
of understanding is still under legal review. The process would allow 
law enforcement entities to receive a COA for training and performance 
evaluation. When the entity has shown proficiency in operating its 
UAS, it would then receive an operational COA allowing it to operate 
small UAS for a range of missions. While this process adds an 
additional step for entities applying to operate a UAS, once an entity 
receives the operational COA, it has more latitude for where and when 
it can operate its UAS. According to FAA data, as of July 2012, 12 
state and local law enforcement entities have a COA. An official at 
the DOJ said that approximately 100 law enforcement entities have 
expressed interest in using UAS for some of their missions. According 
to law enforcement officials with whom we spoke, small UAS are ideal 
for certain types of law enforcement activities. Officials anticipate 
that small UAS could provide support for tactical teams, post-event 
crime scene analysis, and critical infrastructure photography. 
Officials do not anticipate using small UAS for routine patrols or 
missions that would require flights over extended distances or time 
periods. 

* Test ranges. FAA has taken steps to develop, but has not yet 
established, a program to integrate UAS at six test ranges, as 
required by the 2012 Act. FAA must establish six test ranges, and as 
part of these ranges, FAA must safely designate airspace for 
integrated manned and unmanned flight operations, develop 
certification standards and air traffic requirements for UAS, ensure 
the program is coordinated with NextGen, and verify the safety of UAS 
and related navigation procedures before integrating them into the 
national airspace system. FAA expects data obtained from these test 
ranges will contribute to the continued development of standards for 
the safe and routine integration of UAS. In March 2012, FAA issued a 
Request for Comments in the Federal Register and subsequently received 
227 comments from congressional members, state and local governments, 
industry firms, academic and other entities, and individuals. The 
comments addressed questions such as what certification requirements 
should be set for aircraft as part of the test ranges, who should 
manage the airspace and what restrictions should be placed on those 
using the test ranges, and where test ranges should be located. For 
example, FAA has proposed outsourcing the management of the test 
ranges; however, some commenters preferred FAA or another public 
entity to maintain oversight responsibility. Some commenters also said 
that test ranges should be selected based on locations with existing 
facilities and infrastructure, given the absence of any funding 
available for the set-up, management, or oversight of the test ranges. 
FAA officials told us they are still working to meet all of the 
specified requirements for the test ranges and had expected to issue a 
Request for Proposals in July 2012. However, because of privacy 
concerns regarding the collection and use of UAS-acquired data 
expressed by commenters, the internal review process was delayed, and 
FAA officials do not know when they will issue the Request for 
Proposals. The 2012 Act requires the FAA to have at least one project 
at a test range operational 180 days after the date the project is 
established. 

* Rulemaking. While FAA has efforts under way supporting a rulemaking 
for small UAS, as required by the 2012 Act, it is uncertain whether 
FAA will be able to meet the established deadline. The agency's 
rulemaking efforts for UAS date back more than 5 years, when it 
established the small UAS Aviation Rulemaking Committee in 2008. In 
August 2011, FAA provided the Secretary of Transportation with its 
draft NPRM for the first time. Since then, the Office of the Secretary 
has provided several rounds of comments to FAA to further refine the 
NPRM. FAA expected to publish the NPRM in late 2011, but FAA officials 
told us in August 2012 that the Office of the Secretary of 
Transportation was still reviewing the draft and that FAA does not 
expect to publish it in the Federal Register before the end of the 
year.[Footnote 36] FAA is required by the 2012 Act to publish a final 
rule governing small UAS in the Federal Register by August 2014. 

While FAA has made some progress to meet the requirements from the 
2012 Act to date, those requirements that remain will require 
significant work from the agency to meet the established deadlines. 
FAA has reorganized to provide more focus on its UAS integration 
efforts; however, because the reorganization has not yet been fully 
implemented, it remains unclear whether it will provide the support 
needed to complete the work. FAA's UAS efforts rely on expertise and 
resources from several offices within FAA, such as the Aviation Safety 
Organization, the Air Traffic Organization, the Research and 
Development Integration Office, JPDO, and the NextGen Office. FAA has 
reorganized its office that oversees UAS activities several times over 
the past few years, but had not previously assigned a single and 
visible leader to this effort. We have previously reported the need 
for stable leadership at FAA for major aviation efforts.[Footnote 37] 
More recently, FAA has taken steps to provide the organizational 
leadership needed to facilitate progress to safely accelerate UAS 
integration into the national airspace system. In March 2012, FAA 
assigned an Executive Manager for its newly created UAS Integration 
Office, which is expected to combine UAS-related activities from the 
agency's Air Traffic Organization and Aviation Safety Organization. 
However, as of July 2012, the UAS Integration Office had not yet been 
finalized within FAA and no employees had been officially assigned to 
the UAS Integration Office. FAA officials told us that they expect 
approximately 50 federal employees and contractors eventually will be 
assigned to the office; however, the officials are still evaluating 
the number of personnel needed.[Footnote 38] 

While FAA has taken steps to meet the requirements set forth in the 
2012 Act, it is uncertain when the national airspace system will be 
prepared to accommodate UAS. FAA's efforts and activities are 
occurring simultaneously and without monitoring to assess the quality 
of progress over time toward the deadlines Congress established as 
well as the activities to occur over the next 5 years, as outlined in 
FAA's road map. 

Emerging Issues Related to UAS Integration Include Potential Security 
and Privacy Concerns and GPS Jamming and Spoofing: 

Although not new, concerns about national security, privacy issues, 
and GPS jamming and spoofing related to UAS have not been resolved and 
may influence the acceptance of routine access for UAS in the current 
national airspace system or the forthcoming transition to NextGen. 

Security of Domestic UAS Use: 

In 2008, we reported that TSA had not examined the security 
implications of routine UAS access in the national airspace system, an 
assessment that remains unchanged. Within DHS, TSA has authority to 
regulate security of all transportation modes to ensure that 
appropriate security safeguards are in place. According to TSA, its 
aviation security efforts include addressing risks, threats, and 
vulnerabilities related to non-military UAS. Working with FAA and 
other federal agencies, TSA implements security procedures, such as 
allowing some flights into restricted airspace (e.g., allowing certain 
operations into and out of Ronald Reagan National Airport).[Footnote 
39] TSA also coordinates and provides notice about threats to 
transportation in addition to carrying out other security-related 
responsibilities. 

In 2008, we recommended that TSA examine the security implications of 
future, non-military UAS operations in the national airspace system 
and take any actions deemed appropriate. At the time, TSA indicated 
that it used a risk management approach to identify and address 
security threats, but had not completed a UAS risk assessment. In 
response to our recommendation, DHS referenced the 2007 National 
Strategy for Aviation Security, which requires regular reviews of 
national aviation security programs as a whole to identify conflicting 
procedures, changes to threats, vulnerabilities, and resulting 
consequences, and coordinate mitigation measures but does not 
specifically address UAS. Since 2008, TSA has identified and 
documented the potential threat posed by UAS and remote controlled 
aircraft on several occasions. In its 2004 advisory, TSA noted the 
potential for UAS to carry explosives or biological weapons and 
advised individuals to report any suspicious activities to local law 
enforcement and the TSA General Aviation Hotline.[Footnote 40] 
According to a TSA official, it recently reviewed its UAS related 
advisories and determined that they are still applicable. However, TSA 
has not provided information on specific steps it has taken to 
mitigate the potential threats, but believes its current practices are 
sufficient to address UAS security. A recent incident in which a man 
pled guilty to plotting to use a large remote-controlled model 
aircraft filled with plastic explosives to attack the Pentagon and 
U.S. Capitol highlights the potential for UAS being used as weapons. 

Security remains a significant issue that could be exacerbated with an 
increase in the number of UAS. TSA's practices might be sufficient in 
the current UAS environment of limited operations taking place under 
closely controlled conditions, but these controlled conditions will 
change as FAA and others continue to work toward allowing routine UAS 
operations in the national airspace system. Without an assessment of 
TSA's current security practices, TSA is not equipped to know whether 
any changes to its practices are needed. As a partner agency of JPDO, 
DHS--and specifically TSA--have an opportunity to shape the security 
requirements for UAS from the outset. For example, TSA has not yet 
taken steps to develop security requirements for UAS ground control 
stations, which are the UAS equivalent of cockpits. 

Another emerging issue is the operation of model aircraft--aircraft 
flown for hobby or recreation. Congress defined the term "model 
aircraft" in the 2012 Act as an unmanned aircraft that is capable of 
sustained flight in the atmosphere, flown within visual line of sight 
of the person operating the aircraft, and flown for hobby or 
recreational purposes. Model aircraft and small UAS--the latter for 
which FAA is currently developing rules--may essentially be the same 
aircraft with the critical difference being that the operator of the 
model aircraft is a hobbyist and the small UAS is being operated for 
an authorized purpose such as a search and rescue mission. According 
to FAA officials, model aircraft, which are subject to special 
statutory conditions outlined in the 2012 Act, can be larger and 
faster and fly at higher altitudes than UAS that are expected to 
operate under the proposed rule for small UAS. FAA provided guidance 
on voluntary safety standards to model aircraft operators in 1981 in 
its Advisory Circular 91-57. A model aircraft association has also 
published voluntary guidance documents for its members.[Footnote 41] 
Voluntary guidance, however, is not enforceable and, according to FAA 
officials, does not address the increased size and performance 
capability of model aircraft. Owners of model aircraft do not require 
a COA to operate their aircraft. Pursuant to the 2012 Act, FAA is 
prohibited from developing any rule or regulation for model aircraft 
that fly under a specified set of conditions.[Footnote 42] Regardless 
of the statutory prohibition against promulgating a rule or regulation 
for model aircraft, FAA maintains the authority to take enforcement 
action against the operator of a model aircraft who endangers the 
safety of the national airspace system or persons and property on the 
ground. For example, in April 2012, FAA took such action against a 
person who operated a small remote controlled model aircraft on the 
campus of the University of Virginia in close proximity of 
pedestrians. FAA fined the operator $10,000, citing public safety 
concerns based on video footage of the aircraft flying close to 
pedestrians, cyclists, and property. 

We continue to believe that our 2008 recommendation--that TSA examine 
the security implications of future, non-military UAS operations in 
the national airspace system and take any actions deemed appropriate--
remains relevant and that TSA should take steps to implement the 
recommendation. 

Privacy Concerns over the Collection and Use of UAS-Acquired Data: 

Recently, members of Congress, a civil liberties organization, and 
others expressed concern that the potential increased use of small UAS 
for surveillance and other purposes in the national airspace system 
has potential privacy implications. Concerns include the potential for 
increased amounts of government surveillance using technologies placed 
on UAS, the collection and use of such data, and potential violations 
of constitutional Fourth Amendment protections against unreasonable 
search and seizure.[Footnote 43] Additionally, a June 2012 poll 
conducted by Monmouth University reported that 42 percent of those 
sampled were very concerned about their own privacy if U.S. law 
enforcement started using UAS with high tech cameras, while 15 percent 
said they were not at all concerned. However, the poll reported that 
of those sampled, 80 percent said they supported the use of UAS for 
search and rescue missions while 67 percent said they oppose the use 
of UAS to issue speeding tickets.[Footnote 44] While the 2012 Act 
contains provisions designed to accelerate the safe integration of UAS 
into the national airspace system, proposed legislation in the 112th 
session of Congress seeks to limit or serve as a check on government 
use of UAS by, for example, limiting the ability of the federal 
government to use UAS to gather information pertaining to criminal 
conduct without a warrant.[Footnote 45] 

Many stakeholders we interviewed projected how past Supreme Court 
cases that address privacy issues related to government surveillance 
might apply to UAS. While the Supreme Court has not addressed privacy 
issues related to governmental UAS surveillance, the Court has, 
however, upheld several instances involving government aerial 
surveillance from manned aircraft.[Footnote 46] Several other Supreme 
Court governmental surveillance cases, while not aerial surveillance 
cases, specifically relate to technology (one involving a GPS tracking 
device and the other a thermal imaging device) and have included some 
general discussion of the interplay between evolving technology and 
privacy.[Footnote 47] In the 2012 GPS case, for example, one Justice 
observed, in part, that with respect to privacy expectations, 
"technology can change those expectations" and that "dramatic 
technological changes may lead to periods in which popular 
expectations are in flux and may ultimately produce significant 
changes in popular attitudes. New technology may provide increased 
convenience or security at the expense of privacy, and many people may 
find the tradeoff worthwhile."[Footnote 48] These manned aircraft and 
advanced surveillance technology cases may present some issues similar 
to those that may be raised as governmental use of UAS becomes more 
widespread. 

At the individual agency level, there are multiple federal laws 
designed to provide protections for personal information collected and 
used by federal agencies. As we have previously reported,[Footnote 49] 
privacy protections for personal information collected or used by 
federal agencies is governed primarily by two laws: the Privacy Act of 
1974[Footnote 50] and the privacy provisions of the E-Government Act 
of 2002.[Footnote 51] The Privacy Act, as amended, places limitations 
on agencies' collection, disclosure, and use of personal information 
maintained in systems of records. The E-Government Act of 2002 was 
passed, among other reasons, to enhance the protection for personal 
information in government information systems or information 
collections by requiring that agencies conduct privacy impact 
assessments (PIA). PIAs are analyses of how personal information is 
collected, stored, shared, and managed in a federal system. In 
addition, a number of federal agencies including the Department of 
Transportation (DOT), DHS, and DOJ, are statutorily required to 
establish a privacy office and/or Chief Privacy Officers to assess 
their agency programs, including proposed programs, systems, 
technologies, or rule-makings for privacy risks. DHS reports that its 
associated privacy office also provides policy and programmatic 
oversight across the agency. DHS was the first federal agency to be 
statutorily required to establish a privacy officer. With respect to 
the individual agencies, both DOT's and DHS's privacy officers 
responsibilities include "assuring that the use of technologies 
sustain, and do not erode, privacy protections relating to the use, 
collection, and disclosure" of personal information. 

We recently testified that while laws and guidance set minimum 
requirements for agencies, they may not protect personal information 
in all circumstances in which it is collected and used throughout the 
government and may not fully adhere to key privacy principles. 
[Footnote 52] We have previously suggested that Congress consider 
amending applicable privacy laws to address identified issues in three 
major areas: applying privacy protections consistently to all federal 
collection and use of personal information, ensuring that use of 
personally identifiable information is limited to a stated purpose, 
and establishing effective mechanisms for informing the public about 
privacy protections. We have also made numerous recommendations to 
agencies over the last several years to address weaknesses in policies 
and procedures related to privacy and to strengthen their information 
security programs.[Footnote 53] In addition, at a July 2012 testimony 
before the Senate Homeland Security and Governmental Affairs 
committee, a law professor testified that the Congress should create a 
Chief Privacy Officer to coordinate privacy policy across federal 
agencies.[Footnote 54] 

Currently, no single federal agency has been statutorily designated 
with specific responsibility to regulate privacy matters relating to 
UAS for the entire federal government. UAS stakeholders with whom we 
spoke disagreed as to whether the regulation of UAS privacy-related 
issues should be centralized within one federal agency and, if 
centralized, which agency would be best positioned to handle such a 
responsibility. Representatives from a civil liberties organization 
told us that since FAA has responsibility to regulate the national 
airspace system, it could be positioned to handle responsibility for 
incorporating rules that govern UAS use and data collection. However, 
FAA officials and others have suggested that regulating privacy issues 
in connection with equipment carried on UAS, such as surveillance 
sensors that do not affect safety, is outside FAA's mission, which is 
primarily focused on aviation safety. DHS or DOJ might be better 
positioned to address UAS privacy issues since they generally stem 
from the operational uses of UAS for surveillance and law enforcement 
purposes. While is it not clear what entity should be responsible for 
addressing privacy concerns across the federal government, many 
stakeholders believe that there should be federal regulations for the 
types of allowable uses of UAS to specifically protect the privacy of 
individuals as well as rules for the conditions and types of data that 
UAS can collect. As government use of UAS is expected to increase with 
FAA's development of standards and rules to allow routine access to 
the national airspace system, the safety of personal information 
collected by federal agencies using UAS is an emerging issue and the 
government can take a number of steps to potentially address some of 
these privacy issues. Some stakeholders have suggested that FAA has 
the opportunity and responsibility to incorporate such privacy issues 
into the small UAS NPRM that is currently under development and in 
future rulemaking procedures. In addition, stakeholders we interviewed 
stated that developing guidelines for technology use on UAS ahead of 
widespread adoption by law enforcement entities could preclude abuses 
of the technology that could lead to a negative public perception of 
UAS and possibly affect their acceptance and use. 

GPS Jamming and Spoofing: 

The jamming of the GPS signal being transmitted to the UAS could also 
interrupt the command and control of UAS operations. In a GPS jamming 
scenario, the UAS could potentially lose its ability to determine its 
location, altitude, and the direction in which it is traveling. Low 
cost devices that jam GPS signals are prevalent. According to one 
industry expert, GPS jamming would become a larger problem if GPS is 
the only method for navigating a UAS. This problem can be mitigated by 
having a second or redundant navigation system onboard the UAS that is 
not reliant on GPS, which is the case with larger UAS typically 
operated by DOD and DHS. In addition, a number of federal UAS 
stakeholders we interviewed stated that GPS jamming is not an issue 
for the larger, military-type UAS, as they have redundant inertial 
navigation systems on the aircraft. A stakeholder noted that GPS 
jamming can be mitigated for small UAS by encrypting its 
communications, but the costs and weight associated with encryption 
may make it infeasible. 

GPS spoofing has also been identified as an emerging issue. Encrypting 
civil GPS signals could make it more difficult to "spoof" or 
counterfeit a GPS signal that could interfere with the navigation of a 
UAS. Non-military GPS signals, unlike military GPS signals, are not 
encrypted and transparency and predictability make them vulnerable to 
being counterfeited, or spoofed. In a GPS-spoofing scenario, the GPS 
signal going from the ground control station to the UAS is first 
counterfeited and then overpowered. Once the authentic (original) GPS 
signal is overpowered, the UAS is under the control of the "spoofer." 
This type of scenario was recently demonstrated by researchers at the 
University of Texas at Austin at the behest of DHS. During the 
demonstration at the White Sands Missile Range, researchers spoofed 
one element of the unencrypted GPS signal of a fairly sophisticated 
small UAS (mini-helicopter) and induced it to plummet toward the 
desert floor. The research team found that it was straightforward to 
mount an intermediate-level spoofing attack, such as controlling the 
altitude of the UAS, but difficult and expensive to mount a more 
sophisticated attack. The research team recommended that spoof-
resistant navigation systems be required on UAS exceeding 18 pounds. 
[Footnote 55] 

Conclusions: 

By establishing statutory requirements for FAA, Congress highlighted 
the importance of accelerating the safe integration of UAS into the 
national airspace system. However, FAA faces the daunting task of 
ensuring that all of the various efforts within its own agency, as 
well as across agencies and other entities, will align and converge in 
a timely fashion. The pace of progress toward UAS integration that 
occurred prior to the 2012 Act and questions about the agency's 
ability to meet deadline requirements raise concerns about when UAS 
integration in the national airspace system will be achieved. 
Incorporating regular monitoring will help to assess progress toward 
goals identified in the comprehensive plan and 5-year road map that 
can help FAA understand what has been achieved and what remains to be 
done. Monitoring can also help keep Congress informed about this 
significant change to the domestic aviation landscape. 

Concerns regarding the potential security and privacy implications of 
UAS are growing. As the number of UAS operating in the national 
airspace system increases, questions about how the security of the 
national airspace system will be protected and how data captured by 
UAS will be used by governmental or commercial entities will continue 
to arise. Federal agencies have not yet stepped forward to proactively 
address these issues. This lack of activity may result from agency 
officials' belief that they do not have direct authority to regulate 
privacy issues for UAS or the current level of UAS activity in the 
national airspace system. However, not working to proactively address 
security and privacy concerns could lead to further delays in the 
integration of UAS into the national airspace system. 

Recommendations: 

We recommend that the Secretary of Transportation direct the FAA 
Administrator to incorporate, in FAA's comprehensive plan (to be 
completed in November 2012) and the 5-year road map for UAS 
integration (to be completed in February 2013), mechanisms that allow 
for regular monitoring to assess progress toward safe and routine 
access of UAS into the national airspace system. 

We recommend that the Secretaries of Transportation and Homeland 
Security and the Attorney General initiate discussions, prior to the 
integration of UAS into the national airspace system, to explore 
whether any actions should be taken to guide the collection and use of 
UAS-acquired data. 

Agency Comments: 

We provided a draft of this report to officials at Commerce, DHS, DOD, 
DOJ, DOT, and NASA. DHS and DOJ concurred with our recommendation. DOT 
officials agreed to consider our recommendations. DHS, DOJ, DOD and 
DOT provided comments that were technical or clarifying in nature, 
which were incorporated into the report as appropriate. NASA and 
Commerce had no comments on the draft report. 

We are sending copies of this report to interested congressional 
committees, the Secretary of the Department of Transportation, 
Secretary of the Department of Homeland Security, Secretary of the 
Department of Commerce, Secretary of the Department of Defense, the 
Attorney General, and the Administrator of the National Aeronautics 
and Space Administration. In addition, this report will be available 
at no charge on GAO's Web site at [hyperlink, http://www.gao.gov]. 

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 key 
contributions to this report are listed in appendix III. 

Signed by: 

Gerald L. Dillingham, Ph.D. 
Director: 
Physical Infrastructure Issues: 

List of Congressional Committees: 

The Honorable John D. Rockefeller IV: 
Chairman: 
The Honorable Kay Bailey Hutchison: 
Ranking Member: 
Committee on Commerce, Science and Transportation: 
United States Senate: 

The Honorable John L. Mica: 
Chairman: 
The Honorable Nick J. Rahall II: 
Ranking Member: 
Committee on Transportation and Infrastructure: 
House of Representatives: 

The Honorable Bennie G. Thompson: 
Ranking Member: 
Committee on Homeland Security: 
House of Representatives: 

The Honorable Thomas E. Petri: 
Chairman: 
The Honorable Jerry F. Costello: 
Ranking Member: 
Subcommittee on Aviation: 
Committee on Transportation and Infrastructure: 
House of Representatives: 

The Honorable Michael T. McCaul: 
Chairman: 
Subcommittee on Oversight, Investigations, and Management: 
House of Representatives: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This report describes (1) the status of obstacles we identified in our 
previous report to the safe and routine integration of UAS into the 
national airspace system, (2) FAA's progress in complying with FAA 
Modernization and Reform Act of 2012 requirements, and (3) emerging 
issues pertaining to UAS. 

To describe and assess the status of obstacles to safe integration 
that we previously identified, we reviewed documents provided by and 
interviewed officials of government, academic, and private-sector 
entities involved with UAS issues. We reviewed relevant GAO reports 
and interviewed internal stakeholders working on related engagements. 
We also interviewed officials at federal agencies, including the FAA's 
Unmanned Aircraft Systems Integration and Research and Development 
Offices, DOD, NASA, Department of Commerce's International Trade 
Administration, DHS, and the Department of Justice. We interviewed 
representatives from related federal advisory groups including FAA's 
JPDO, RTCA Special Committee 203, the Interagency Taskforce on 
Unmanned Systems, and the DOD's Air Force Research Lab as well as 
independent standards setting organizations RTCA and ASTM F38. 
Additionally, we interviewed representatives from universities with 
centers of research on UAS technology and issues, including the 
University of North Dakota and New Mexico State University, as well as 
a representative from the Mesa County, Colorado Sherriff's Office. We 
interviewed private sector representatives from MITRE, Rockwell 
Collins, and Raytheon. We interviewed representatives from the 
Association for Unmanned Vehicle Systems International, Aircraft 
Owners and Pilots Association, General Aviation Manufacturers 
Association, and the Airborne Law Enforcement Association. To obtain 
information on current civil UAS use, we obtained information from the 
FAA on the certificates of authority and special airworthiness 
certificates issued from January 2012 to July 2012. 

To assess FAA's progress in meeting its reauthorization requirements 
and to understand UAS coordination efforts across and federal 
government and private stakeholder, we reviewed relevant portions of 
the FAA Modernization and Reform Act of 2012 and the Federal Register. 
We identified criteria for assessments from GAO's Standards for 
Internal Control in the Federal Government. We also reviewed documents 
provided by and conducted interviews with FAA's Unmanned Aircraft 
Systems Integration Office and JPDO. Additionally, we participated in 
several public webinars that addressed privacy concerns over non-
military UAS use and FAA's request for comment on the UAS test range 
program. 

To assess issues regarding privacy concerns over the use of UAS 
acquired data, we reviewed documents provided by and interviewed UAS 
federal, state, and local stakeholders as well as representatives from 
the Electronic Frontier Foundation and the American Civil Liberties 
Union. To obtain information about UAS security considerations, we 
reviewed documents from the Academy of Model Aeronautics and the 
Federal Law Enforcement Training Center and spoke with officials from 
FAA, DHS, and the Association for Unmanned Vehicles Systems 
International. We also examined legal requirements to which federal 
agencies should adhere when collecting and using personal information. 

We conducted this performance audit from November 2011 through 
September 2012 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. 

[End of section] 

Appendix II: Federal Entities with Certificates of Waiver or 
Authorization Approved from January 1, 2012, to July 13, 2012: 

Federal Entities with Approved COAs: DARPA; 
Number of Groups within Federal Entities with COAs: 1; 
Number of approved COAs: 3. 

Federal Entities with Approved COAs: Department of State; 
Number of Groups within Federal Entities with COAs: 1; 
Number of approved COAs: 1. 

Federal Entities with Approved COAs: Department of Homeland Security; 
Number of Groups within Federal Entities with COAs: 2; 
Number of approved COAs: 17. 

Federal Entities with Approved COAs: DOD - U.S. Special Operations 
Command; 
Number of Groups within Federal Entities with COAs: 1; 
Number of approved COAs: 32. 

Federal Entities with Approved COAs: DOD - Navy-USMC; 
Number of Groups within Federal Entities with COAs: 12; 
Number of approved COAs: 18. 

Federal Entities with Approved COAs: DOD - U.S. Air Force; 
Number of Groups within Federal Entities with COAs: 16; 
Number of approved COAs: 56. 

Federal Entities with Approved COAs: DOD - U.S. Army; 
Number of Groups within Federal Entities with COAs: 33; 
Number of approved COAs: 54. 

Federal Entities with Approved COAs: Department of Energy - National 
Laboratories; 
Number of Groups within Federal Entities with COAs: 2; 
Number of approved COAs: 6. 

Federal Entities with Approved COAs: Department of Justice - Federal 
Bureau of Investigation; 
Number of Groups within Federal Entities with COAs: 1; 
Number of approved COAs: 3. 

Federal Entities with Approved COAs: Department of Interior; 
Number of Groups within Federal Entities with COAs: 1; 
Number of approved COAs: 7. 

Federal Entities with Approved COAs: NASA; 
Number of Groups within Federal Entities with COAs: 5; 
Number of approved COAs: 30. 

Federal Entities with Approved COAs: Total Federal Entities with 
approved COAs between January 1, 2012 and July 13, 2012; 
Number of Groups within Federal Entities with COAs: 75; 
Number of approved COAs: 227. 

Source: GAO analysis of FAA data. 

Note: Federal agencies have COAs in multiple locations across the U.S. 

[End of table] 

[End of section] 

Appendix II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

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

Staff Acknowledgments: 

Individuals making key contributions to this report include Maria 
Edelstein, Assistant Director; Amy Abramowitz; Gary Bianchi; Cristina 
Chaplain; Erin Cohen; Elizabeth Curda; John de Ferrari; Colin Fallon; 
Rebecca Gambler; Geoffrey Hamilton; David Hooper; Daniel Hoy; Joe 
Kirschbaum; Patricia Lentini; Brian Lepore; SaraAnn Moessbauer; Faye 
Morrison; Brian Mullins; Madhav Panwar; David Plocher; and Tina Won 
Sherman. 

[End of section] 

Footnotes: 

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

[2] The Congressional Unmanned Systems Caucus, consisting of 60 
members, was formed to educate members of Congress and the public on 
the strategic, tactical, and scientific value of unmanned systems; 
actively support further development and acquisition of more systems, 
and to more effectively engage the civilian aviation community on 
unmanned system use and safety. 

[3] The Congressional Research Service issued a report discussing the 
evolution of UAS and UAS related considerations for Congress. 
Congressional Research Service, Pilotless Drones: Background and 
Considerations for Congress Regarding Unmanned Aircraft Operations in 
the National Airspace System, R42718 (Washington, D.C.: September 
2012). 

[4] GAO, Unmanned Aircraft Systems: Federal Actions Needed to Ensure 
Safety and Expand Their Potential Uses within the National Airspace 
System, [hyperlink, http://www.gao.gov/products/GAO-08-511] 
(Washington, D.C.: May 15, 2008). 

[5] FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95, §§ 
332-334, 126 Stat. 11 (2012). 

[6] According to the General Aviation Manufacturers Association, 
general aviation is all aviation other than military and commercial 
airlines that is not available to the general public for transport. 
General aviation includes nonscheduled aircraft operations such as air 
medical-ambulance, corporate aviation, and privately owned aircraft. 

[7] Altitudes 18,000 and 60,000 feet are reported as mean sea level, 
which is the average height of the surface of the sea for all stages 
of the tide; used as a reference for elevations. 

[8] According to an industry association, small UAS are expected to 
comprise the majority of UAS that will operate in the national 
airspace system. 

[9] COAs and special airworthiness certifications in the experimental 
category represent exceptions to the usual aircraft certification 
process. FAA examines the facts and circumstances of a proposed UAS to 
ensure that the prospective pilot has acceptably mitigated the safety 
risks. 

[10] The DHS Inspector General reviewed CBP's actions to establish its 
UAS program, the purpose of which is to provide reconnaissance, 
surveillance, targeting, and acquisition capabilities across all CBP 
areas of responsibility. The Inspector General assessed whether CBP 
has established an adequate operation plan to define, prioritize, and 
execute its unmanned aircraft mission. The Inspector General's May 
2012 report found that CBP had not achieved its scheduled or desired 
level of flight hours for its UAS. The report estimated that CBP used 
its UAS less than 40 percent of the time it would have expected. The 
report made four recommendations intended to improve CBP's planning of 
its UAS program to address its level of operation, program funding, 
and resource requirements along with stakeholder needs. Department of 
Homeland Security, Office of Inspector General, CBP's Use of Unmanned 
Aircraft Systems in the Nation's Border Security, OIG-12-85 
(Washington, DC: May 30, 2012). 

[11] GAO, Unmanned Aircraft Systems: Comprehensive Planning and a 
Results-Oriented Training Strategy Are Needed to Support Growing 
Inventories, [hyperlink, http://www.gao.gov/products/GAO-10-331] 
(Washington, D.C.: Mar. 26, 2010). 

[12] House Permanent Select Committee on Intelligence, Performance 
Audit of the Department of Defense Intelligence, Surveillance, and 
Reconnaissance (Washington, DC: Apr. 2012). 

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

[14] The other portion of the estimate, $60.6 billion, is for the 
procurement of UAS. 

[15] FAA's Federally Funded Research and Development Centers are 
located at MITRE, MIT's Lincoln Lab, and the Air Force Research Lab. 

[16] FAA has Cooperative Research and Development Agreements with 
academic institutions such as New Mexico State University, Rutgers 
University, Auburn University, University of North Dakota, Stanford 
University, University of Alaska Fairbanks, Colorado University, 
Wichita State University, and Embry Riddle University. FAA also has 
Cooperative Research and Development Agreements with General Atomics, 
AAI Corporation, GE Aviation Systems LLC, Boeing Inc, and Georgia Tech 
Research Corporation. 

[17] FAA's international agreements include the Netherlands, the 
German Aerospace Center, and the European Union. 

[18] [hyperlink, http://www.gao.gov/products/GAO-08-511]. 

[19] NextGen is a new satellite-based air traffic management system 
that will replace the current radar-based system 

[20] The FAA regulations include 14 C.F.R § 91.111, "Operating near 
other aircraft," with reference to "create a collision hazard," and 14 
C.F.R. § 91.113, "Right-of-way rules." 

[21] MITRE is a public interest company that works in partnership with 
the federal government applying systems engineering and advanced 
technology to address issues of national importance. 

[22] A chase aircraft is a manned aircraft that is used to follow a 
UAS and serves as the see-and-avoid function for total flight safety. 
The pilot of the chase aircraft monitors for conflicting aircraft and 
is in constant radio contact with the pilot in command of the UAS who 
is on the ground. 

[23] GBSAA is an air surveillance radar that provides positional 
information via a display of traffic information to the UAS flight 
crew. 

[24] ADS-B transponder system uses GPS signals along with aircraft 
avionics to transmit the aircraft's location to ground receivers. The 
ground receivers then transmit that information to controller screens 
and cockpit displays on aircraft equipped with automatic dependent 
surveillance-broadcast transponder system avionics. 

[25] Ikhana is a large UAS that NASA has used for a number of research 
activities, such as monitoring and tracking wildfires and expects to 
use for an arctic mission to assess the surface sea ice next year. 

[26] Air traffic controllers monitor and coordinate the movement of 
air traffic. They communicate with pilots of aircraft, including UAS, 
but do not directly control the operations of aircraft. 

[27] A National Airspace System Voice System is a new flexible 
networkable voice communications system with flexible networking 
capabilities that will be required for future air traffic operations, 
as envisioned by NextGen. The National Airspace System Voice System is 
the key voice communication component for NextGen, as many of the 
seventeen different switches currently used in the national airspace 
are already experiencing severe obsolescence issues. 

[28] Title 14, Code of Federal Regulations (14 C.F.R.) part 91, titled 
"General Operating and Flight Rules." 

[29] [hyperlink, http://www.gao.gov/products/GAO-08-511]. 

[30] In June 2011, FAA and DOD signed a memorandum of agreement that 
specified the data that would be provided. 

[31] Title 14 of Code of Federal Regulations. 

[32] GAO, Transportation: Integration of Current Implementation 
Efforts with Long-term Planning for the Next Generation Air 
Transportation System, [hyperlink, 
http://www.gao.gov/products/GAO-11-132R] (Washington, D.C.: Nov. 22, 
2010). 

[33] Department of Transportation, Office of Inspector General, Timely 
Actions Needed to Advance the Next Generation Air Transportation 
System, Report Number AV-2010-068 (Washington, D.C.: June 16, 2010). 

[34] The NextGen partner agencies include the Departments of 
Transportation, Commerce, Defense, and Homeland Security, FAA, NASA, 
White House Office of Science and Technology Policy, and the Office of 
the Director of National Intelligence. 

[35] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[36] In general, after OMB reviews a proposed rule, the proposed rule 
is issued and the public provides comments generally within a 60-day 
period. This is followed by the agency's preparation and OMB's review 
of the final rule, concluding with the agency publishing the final 
rule in the Federal Register. 

[37] GAO, Joint Planning and Development Office: Progress and Key 
Issues in Planning the Transition to the Next Generation Air 
Transportation System, [hyperlink, 
http://www.gao.gov/products/GAO-07-693T] (Washington, D.C.: Mar. 29, 
2007). 

[38] Presently, the Air Traffic Organization and the Flight Standards 
Organization are developing a Service Level Agreement (SLA) that will 
define the reporting protocols for Air Traffic Organization employees 
who would be reporting to the Aviation Safety Organization, which 
structurally houses the UAS Integration Office. 

[39] After the attacks of September 11, 2001, the FAA maintained 
flight restrictions over certain cities and sensitive sites, including 
Washington D.C., Ronald Reagan National Airport. While commercial 
aircraft operators with full TSA security programs were permitted to 
resume at Ronald Reagan National Airport, commercial operators without 
full programs and general aviation operators were largely prohibited 
from operating into and out of the airport. In order to fly into these 
restricted airspace areas, certain aircraft operators must seek a 
waiver from TSA, which provides an analysis of the security aspects of 
requests for waivers. 

[40] Department of Homeland Security, TSA Advisory: Security 
Information Regarding Remote Controlled Aircraft and Unmanned Aerial 
Vehicles (Washington, DC: Nov. 22, 2004). 

[41] FAA's Advisory Circular 91-57 sets out model aircraft operating 
standards that encourage voluntary compliance with specified safety 
standards for model aircraft operators. 

[42] This prohibition on FAA model aircraft rules or regulations only 
applies where the aircraft is: (1) flown strictly for hobby or 
recreational use; (2) operated in accordance with a community-based 
set of safety guidelines and within the programming of a nationwide 
community-based organization; (3) limited to not more than 55 pounds 
(unless otherwise certified through a design, construction, 
inspection, flight test, and operational safety program administered 
by a community-based organization); (4) operated in a manner that does 
not interfere with and gives way to any manned aircraft; and (5) when 
flown within 5 miles of an airport, operated under prior notice to the 
airport operator and the air traffic control tower. 

[43] The Congressional Research Service has issued a report assessing 
the use of UAS under the Fourth Amendment. Congressional Research 
Service, Drones in Domestic Surveillance Operations: Fourth Amendment 
Implications and Legislative Responses, R42701 (Washington, D.C.: 
September 2012). 

[44] The Monmouth University Polling Institute reported that it 
conducted the poll on June 4 to 6, 2012 with a national random sample 
of 1,708 adults age 18 and older, including 607 via live interview on 
a landline telephone, 675 via interactive voice response on a 
landline, and 426 via live interview on a cell phone. Monmouth 
University Poll, "U.S. Supports Some Domestic Drone Use, But Public 
Registers Concern About Own Privacy" (June 12, 2012). 

[45] Preserving Freedom from Unwarranted Surveillance Act of 2012, S. 
3287, 112TH Cong. (2012) and Farmer's Privacy Act of 2012, H.R. 5961, 
112TH Cong. (2012). 

[46] See, e.g., California v. Ciraolo, 476 U.S. 207 (1986); Dow 
Chemical Co. v. United States, 476 U.S. 227 (1986): and Florida v. 
Riley, 488 U.S. 445 (1989). 

[47] See, Kyllo v. United States, 533 U.S. 27 (2001); United States v. 
Jones, 132 S. Ct. 945 (2012). 

[48] United States v. Jones, 132 S. Ct. 945, 962 (2012) (Alito, J., 
concurring). In Kyllo, a justice stated, in part, that "it would be 
foolish to contend that the degree of privacy secured to citizens by 
the Fourth Amendment has been entirely unaffected by the advance of 
technology. For example, the technology enabling human flight has 
exposed to public view (and hence, we have said, to official 
observation) uncovered portions of the house and its curtilage that 
once were private." Kyllo v. United States, 533 U.S. 27, 33-34 (2001) 

[49] See, GAO, Privacy: OPM Should Better Monitor Implementation of 
Privacy-Related Policies and Procedures for Background Investigations 
[hyperlink, http://www.gao.gov/products/GAO-10-849] (Washington, D.C.: 
Sep. 7, 2010). 

[50] Pub. L. No. 93-579, 88 Stat. 1896 (1974). 

[51] Pub. L. No. 107-347, 116 Stat. 2899 (2002). 

[52] Federal agency collection or use of personal information is 
governed primarily by two laws: the Privacy Act of 1974 and the 
privacy provisions of the E-Government Act of 2002. The Privacy Act 
places limitations on agencies' collection, disclosure, and use of 
personal information maintained in systems of records. The E-
Government Act of 2002 was passed, among other reasons, to enhance the 
protection for personal information in government information systems 
or information collections by requiring that agencies conduct PIAs. 
PIAs are analyses of how personal information is collected, stored, 
shared, and managed in a federal system. 

[53] [hyperlink, http://www.gao.gov/products/GAO-12-961T].  

[54] Statement of Peter Swire, "State of Federal Privacy and Data 
Security Law: Lagging Behind the Times?," Subcommittee on Oversight of 
Government Management, the Federal Workforce and the District of 
Columbia, July 31, 2012. 

[55] The presentation "Assessing the Civil GPS Spoofing Threat" by 
Todd Humphreys, Jahshan Bhatti, Brent Ledvina, Mark Psiaki, Brady 
O'Hanlon, Paul Kintner, and Paul Montgomery sought to assess the 
spoofing threat of a small civil UAS. The team built a civilian GPS 
spoofer and tested some countermeasures. They concluded that GPS 
spoofing is a threat to communications security and civil spoofing has 
not been the focus of research in open literature. 

[End of section] 

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