The Federal Aviation Administration (FAA) ensures safe shared use of the airspace by military and civilian aircraft, and also helps to regulate pilot certification, manage the air traffic control system, ensure aircraft safety, and distribute funding for airport infrastructure. The FAA and its regulation of civil aviation predates the US Department of Transportation but became part of the Department when it was established in 1966. Despite being an essential part of USDOT, there are organizational divides between the FAA and the other modal administrations. As USDOT works to modernize internal systems and processes and as there is greater policy overlap across modes, stronger internal integration of the FAA with USDOT would potentially improve agency effectiveness.

The Air Commerce Act of 1926 initially placed regulation of civil aviation under the Department of Commerce. The Civil Aeronautics Act created the Civil Aeronautics Authority to conduct safety investigations and regulate travel routes in 1938. In 1940, the CAA was split into the Civil Aeronautics Administration, with responsibilities around air traffic control, certification, and safety, and the Civil Aeronautics Board with responsibilities around airfares and routes.  Under the Federal Aviation Act of 1958, the CAA became an independent agency, the Federal Aviation Agency, which then became a modal administration within the US Department of Transportation in 1967 when the agency was created. The CAB, along with the federal role in airfares and routes, were dissolved in the Airline Deregulation Act of 1978.

While the FAA has been a part of USDOT since, the FAA maintains a higher level of organizational separation from the agency in comparison to other modal administrations. There may be several explanations for this separation, including the different nature of aviation from surface transportation and the operational role of the federal government in the airspace. This direct federal role in operating the airspace through the air traffic control system also contributes to the significant size and structural difference between FAA and the rest of USDOT: of the approximately 55 thousand USDOT employees, roughly 45 thousand work at FAA. My own experience of the organizational divide occurred when, from June to October 2023, Deputy Secretary of Transportation Polly Trottenberg served as the acting FAA administrator. During this time, I was an intern with the Deputy Secretary’s office. Given the organizational divides between USDOT and the FAA, staff members needed additional sets of emails, phones, badges, and computers in order to support the Deputy Secretary in her dual role within the same organization.

Past reorganizational proposals, including the first Trump Administration’s “Delivering Government Solutions in the 21st Century” and the Clinton Administration’s 1995 “REGO” plan, called for air traffic control to be managed by a separate entity (non-governmental for the former and governmental for the latter). The FY 1996 Budget proposed integrating the Highway Trust Fund and Airport and Airway Trust Fund into a Transportation Trust Fund. In the present day, the management of the air traffic control system remains under the purview of the FAA.

The updating and strengthening of the air traffic control system has become a top priority for Secretary Duffy and the Trump Administration and for members Congress on both sides of the aisle. Past proposals for better integration of the FAA into USDOT should still be examined even without removal of the ATC from the FAA. In August 2025, USDOT Secretary Duffy announced intentions to relocate FAA staff from the FAA DC headquarters building to USDOT’s headquarters, also in DC, citing the FAA building’s declining physical state and the organizational challenges of physical separation of the modal administration. This followed Secretary Duffy’s July 2025 announcement of “1DOT,” a reorganizational effort to better integrate the agency’s software systems. The memo from the Secretary expressed intentions to replace legacy systems and streamline internal processes and administrative functions. In particular, this includes consolidation of IT and HR systems within the agency.

It is essential that integration efforts complement rather than strain existing aviation safety and staff capacity, especially during a period of heightened attention to U.S. airspace safety and ongoing implementation of the 2024 FAA Reauthorization objectives. Internal documents from the FAA raised concerns about the potential $250 million cost of transfer of DC staff to the USDOT building and concerns about the impact to safety on the U.S. national airspace system. Since the start of the year, the FAA has already seen a net reduction of 2.6 percent of its workforce, with 3,774 reductions and 2,574 additions from a baseline of 46,595 employees. Efficiencies gained from systems integration should be utilized as a tool to help mitigate existing capacity concerns, and the transitional period itself will likely require higher staff capacity and resources.

Greater organizational IT integration should come alongside enhancement of the agency’s cyber security, including enhanced enterprise cloud system security. According to the USDOT OIG November 2024 report, “DOT’s Fiscal Year 2025 Top Management Challenges,” USDOT faces longstanding challenges to its cybersecurity program including weaknesses related to unsupported software, configuration management, and missing software updates. The report calls for a multiyear strategy to commit resources to overall improvement of the security program. A multiyear strategy for IT improvements could come in tandem with a multiyear strategy for FAA integration, both of which will require dedicated resources for planning and implementation efforts.

In addition to organizational efficiency, there are also significant potential benefits from stronger integration of FAA into USDOT for policy reasons. This is particularly the case in the contemporary moment of reflection on efficient infrastructure implementation and new safety challenges and opportunities presented by emerging technologies.

As advanced air mobility (AAM) continues to reshape the airspace, there will likely be greater overlap between the regulatory terrain of the FAA and other DOT modal administrations. Advanced air mobility—highly automated and typically electric aircraft with vertical take-off and landing capacity—has the potential to create more efficient transportation systems for both passengers and cargo and could support first responders. The FAA has an integral role in aircraft and operator certification and in ensuring safety in the airspace for all users. However, according to the FAA, multiple entities will play an important role in this changing transportation landscape. The AAM Working Group established in 2023 included representatives across various agencies including the Department of Transportation, Defense, Commerce, Labor, and Energy. As AAM becomes more integrated into transportation networks and potentially replaces shorter distance surface travel, there will be a stronger imperative for collaboration across modal administrations. Technological innovations, a priority of Secretary Duffy’s Innovation Agenda, such as autonomous and connected technologies, have overlaps in the surface and aviation spaces. According to USDOT’s OIG, DOT faces challenges across modes in the testing and implementation of technological transformations, in both physical and digital transportation infrastructure.

Additionally, as the Department works to better deliver infrastructure project funding, there are opportunities for Department-wide enhancements and sharing of best practices to improve grant delivery mechanisms. The USDOT OIG has reviewed and raised concerns about both the FAA’s approach to project reviews and risk ratings, which are similar to findings about USDOT as a whole from the Government Accountability Office (GAO) in their report entitled, “DOT Should Better Communicate Funding Status and Assess Risks.” The dual reports reveal a need for greater agency-wide risk management for the administration of federal grants. Additionally, there should be an effort for modal administrations to share lessons learned during IIJA implementation and for subsequent process improvements to be implemented across the agency.

Data and transportation statistical integration is another important area of potential improvement. For instance, USDOT OIG’s 2024 report “DOT’s Top Management Challenges” for FY 2025 called for enhanced data sharing and analysis by the FAA, which could help improve management of runway incursions and aviation close calls. The report also calls for enhanced data collection on consumer protection and experience. The Bureau of Transportation Statistics (BTS) also collects certain aviation statistics, but this data is not always consistent with the FAA’s air traffic control data. Greater collaboration in data analysis and sharing could help to leverage existing resources to enhance progress towards FAA’s goals.

The FAA faces a number of significant challenges and objectives at the contemporary moment including enhancing aviation safety, ATC modernization, regulation of emerging technologies, and effective infrastructure funding implementation. Greater integration into USDOT can enhance existing staff capacity and therefore prioritize FAA workforce needs and responsibilities. Achieving long-term efficiencies may require dedication of additional resources for a smooth and successful transition period. However, the long-term benefits would be significant, particularly if this transition can occur alongside existing efforts to enhance the agency’s cybersecurity and can help the FAA address policy challenges such as multimodal integration, technological transition, and effective infrastructure funding management.

The views expressed above are those of the author and do not necessarily reflect the views of the Eno Center for Transportation.