From Bars to Blue Sky: DOT Explores Cellular Networks for Drone Safety

Operation of unmanned aircraft systems (UAS) – commonly known as drones – is rapidly expanding into airspace traditionally occupied by manned aircraft, creating an urgent need for new safety technologies. In particular, the need for ensuring reliability of communications and navigation capabilities has prompted discussion. In response, the U.S. Department of Transportation (DOT) has launched the Mobile Network Aviation Assessment Program (MNAAP), an initiative that seeks to answer the question: Can the commercial cellular networks already used every day help keep aircraft – manned and unmanned – safely separated in shared airspace?

The Problem MNAAP Is Designed to Solve

Aviation safety has long relied on a patchwork of radar, human observers and Global Navigation Satellite System (GNSS)-dependent electronic conspicuity signals. These systems were largely designed to ensure safe operations around airports, where most manned flights begin and end. Drones, however, do not require airports or runways; multi-rotor systems can be launched and recovered from virtually anywhere. Much of this UAS activity occurs outside controlled airspace where aircraft are not required to transmit a conspicuity signal alerting other aircraft of their presence. The challenge, then, is how to ensure the safe separation of manned and unmanned aircraft in this increasingly shared airspace.

What Is MNAAP?

MNAAP is a testing and proof-of-concept program sponsored by the DOT's Highly Automated Systems Safety Center of Excellence. The program's mission is to assess and evaluate the capabilities of existing mobile network technologies to support aviation safety needs. MNAAP is considering whether commercial wireless networks, satellite direct-to-device services and sidelink technology can support aviation-based safety services, including electronic conspicuity, remote identification, counter-UAS detection and identification, UAS command and control, and autonomous detect-and-avoid systems.

To conduct testing of communications service quality and availability, MNAAP created a mobile application (MNAAP App) and a module for use in UAS (MNAAP Module). The MNAAP App will be available on standard, commercially available smartphones and other wireless devices for up to 2,000 general aviation pilots at one time, while the purpose-built MNAAP Module will be deployed on up to 200 UAS at one time, supporting targeted testing across a wide range of locations and altitudes. The MNAAP Module must complete the Federal Communications Commission (FCC) equipment authorization process and receive approval through mobile carrier certification programs. Both the App and the Module will gather data about mobile broadband service quality and report results to a centralized DOT-managed database.

The FCC Clears the Way

The FCC marked a critical milestone on September 11, 2026, when it issued a temporary waiver enabling MNAAP testing. The waiver was necessary because FCC rules permit airborne communications in some commercial spectrum bands but prohibit them in others. Modern wireless devices automatically select available frequencies based on network conditions – meaning an airborne device could inadvertently transmit over restricted spectrum. Through October 1, 2029, the temporary waiver permits authorized participants to use certain otherwise prohibited commercial spectrum bands when their devices automatically select frequencies based on network conditions.

Why It Matters

MNAAP has particular relevance for routine beyond visual line of sight (BVLOS) operations – arguably the most significant growth frontier for commercial drone use. Scalable BVLOS missions require communications that remain reliable across changing locations, altitudes and network boundaries. If MNAAP demonstrates that commercial wireless networks can serve as part of the safety infrastructure for drone operations, it could dramatically lower the cost and complexity of safely scaling UAS activities nationwide. As stated in a prior Holland & Knight alert, the proposed Federal Aviation Administration (FAA) rule to normalize BVLOS operations would require each drone operating BVLOS to have an electronic conspicuity device that enables surrounding aircraft to remain aware of the drone.

The FCC has signaled that MNAAP's findings will inform its future decisions on commercial spectrum use for UAS. Though the program will not resolve every question surrounding cellular-connected drones, it could provide the national, real-world data that regulators need to make informed policy decisions about the future of airspace connectivity.

Looking Ahead

MNAAP testing is expected to continue through September 30, 2029. The program's results will help federal agencies – including the DOT, FCC and FAA – assess whether and how commercial mobile networks can become a reliable pillar of aviation safety infrastructure. For an industry eager to move beyond line of sight, MNAAP could turn cellular connectivity from a concept into a cornerstone of the next generation of the national airspace system.

Holland & Knight's Drone Team continues to monitor developments in the UAS sector. If you have questions about the potential impact on your business or other matters relating to UAS regulation and critical infrastructure protection, contact the authors or another member of the team.