The American Public Power Association, National Rural Electric Cooperative Association, Edison Electric Institute, and the Large Public Power Council filed comments in response to Federal Communications Commission (FCC) notice GN Docket No. 26-74, “Unleashing American Drone Dominance.” 

The FCC issued this notice on April 16 to gather public input on reforms that would accelerate U.S. drone leadership by reducing regulatory barriers, expanding access to reliable spectrum, modernizing experimental licensing, and supporting domestic manufacturing and innovation.

The associations’ comments said that electric utilities are among the most advanced and consequential users of unmanned aircraft systems (UAS; drones) and therefore central to the FCC’s effort to “unleash American drone dominance.” 

They emphasized that utilities already rely on drones for safety critical missions such as transmission and distribution inspection, wildfire mitigation, storm response, vegetation management, and grid restoration. The associations said because utilities plan infrastructure on decades long horizons, they represent stable anchor customers capable of supporting domestic manufacturing and workforce development.

The associations said that utilities cannot scale from pilot projects to routine, infrastructure wide UAS operations without reliable, predictable, aviation grade communications. They stressed that unlicensed spectrum is insufficient for safety critical missions, particularly during emergencies when interference is most likely. 

They strongly support the FCC’s 5030–5091 MHz (5 GHz) framework for command and control (CNPC) operations but argue that the current interim, case by case access model is too slow and administratively burdensome. 

They stated that “utilities lack a practical means of securing predictable, repeatable access for routine operations and emergency response” until dynamic frequency management systems (DFMS) are approved and operational. They urged the FCC to accelerate DFMS administrator approval, establish infrastructure focused pilots, and provide clear reliability expectations.

The associations also argued that mid band spectrum alone cannot meet utilities’ operational needs across diverse geographies. They urged the FCC to authorize UAS CNPC operations in the 450 MHz band, citing its superior propagation for long range, rural, remote, and disaster affected environments, making it a necessary complement to the 5 GHz aviation layer. They further request clarity that utilities may operate UAS over their private LTE and emerging 5G networks, which are engineered for high reliability and controlled device environments, and distinguishing them from public commercial mobile networks historically subject to airborne use restrictions.

The comments also call for modernization of experimental licensing, clearer regulatory pathways for counter UAS and infrastructure protection measures, and creation of an FCC “one stop shop” for UAS regulatory guidance. 

The associations argued that Part 5 experimental licensing is poorly suited to utilities’ incremental, operationally integrated deployments and recommend longer term authorizations, streamlined modifications, and improved coordination between the FCC and the Federal Aviation Administration. 

They also highlighted the need for clear rules governing defensive technologies to protect critical infrastructure from malicious drones.
 

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