SEO title FAA Part 137 Requirements for Agricultural Drone Operations

Part 107 is not the complete approval path for an agricultural spray drone. When an aircraft releases pesticides, fertilizer, seed-treatment material, plant nutrients, or another substance covered by 14 CFR Part 137, the operator generally needs an FAA agricultural aircraft operator certificate, an exemption that fits the aircraft and operation, and any additional approvals stated in that exemption.

When Part 137 Applies

Part 137 applies to aircraft operations conducted to dispense an “economic poison,” to release another substance intended for plant nourishment, soil treatment, propagation of plant life, or pest control, or to perform dispensing work that directly affects agriculture, horticulture, or forest preservation. The regulatory definition excludes the dispensing of live insects.

The rule is broader than pesticide spraying. A drone used to release herbicide, fungicide, insecticide, fertilizer, nutrient products, granular material, or seed-related material may fall within Part 137 depending on the substance and the purpose of the release. The correct first question is not whether the aircraft looks like a crop sprayer. The question is what the aircraft will release and why.

Mapping is different | A drone used only to collect RGB, thermal, or multispectral imagery does not become a Part 137 operation merely because the work supports a farm. Part 137 is triggered by covered dispensing activity, not by agricultural data collection alone.

Part 107, Part 91, and Part 137 Work Together

Loaded takeoff weight	Primary flight framework	Agricultural approval path
Less than 55 lb, including the material being dispensed	Part 107 remains the underlying small-UAS operating rule.	Part 137 AAOC plus an FAA exemption from applicable Part 107 and Part 137 provisions. The aircraft receives an FA registration number through FAADroneZone.
55 lb or more	The operation is outside Part 107 and generally proceeds under Part 91.	Part 137 AAOC plus relief from applicable Parts 61, 91, and 137 requirements. The aircraft receives an N-number through CARES or the Aircraft Registry, and a COA may be required.

The 55-pound line is based on the actual takeoff configuration, including batteries, tank, liquid or granular product, pumps, booms, nozzles, mounts, and everything else carried or attached. A platform that weighs less than 55 pounds empty can still be a large UAS when launched with a working load.

The Operator Certificate Is Separate From the Pilot Certificate

A Remote Pilot Certificate belongs to an individual. An Agricultural Aircraft Operator Certificate, commonly called an AAOC, authorizes the operator identified on the certificate to conduct approved agricultural aircraft operations. One does not replace the other.

The FAA currently asks Part 137 UAS applicants to identify the chief supervisor of operations, the pilot in command, the aircraft make and model, the aircraft registration number, and the aircraft owner. The pilot and crew must meet the conditions in the exemption and the operator’s approved operating framework. Do not assume that a standard Part 107 certificate by itself authorizes spraying.

Private and Commercial Part 137 Certificates

Certificate type	Practical use	Key limitation
Private agricultural aircraft operator	Operations involving property the operator owns or leases, or crops in which the operator has an ownership or other property interest.	May not be used for compensation or hire, over a congested area, or over unrelated property.
Commercial agricultural aircraft operator	Spraying or dispensing services performed for customers or other compensated operations.	The operator must use the business name shown on the certificate and maintain the commercial records required by Part 137.

A farm owner applying only to the owner’s acreage may qualify for a private certificate, but ownership structure matters. A contractor, dealer, service company, or operator applying material for another party normally needs the commercial path. Resolve the operator identity before filing because the name on FAA Form 8710-3 must match the exemption holder.

The Current FAA Application Sequence

The FAA uses a streamlined process for routine visual-line-of-sight agricultural UAS operations that remain within the altitude and airspeed limits stated in the exemption. The process still contains separate approval steps.

Step	Required action	Operational point
1. Register the aircraft	Obtain an FA number for an aircraft under 55 pounds or an N-number for an aircraft weighing 55 pounds or more.	Use the registration path that matches the planned loaded aircraft and legal owner.
2. Petition for exemption	File through Regulations.gov and request relief from the specific regulations the UAS cannot meet.	FAA instructs applicants to file at least 120 days before the exemption is needed or before an existing exemption expires.
3. Provide operational information	Identify the legal applicant, chief supervisor, pilot, aircraft, registration, and aircraft owner.	Incomplete or inaccurate responses can delay the petition or cause the FAA to close it.
4. Apply for the AAOC	After receiving the exemption number, submit FAA Form 8710-3 and the exemption number to the FAA’s Part 137 UAS office.	The AAOC applicant name must match the exemption holder.
5. Satisfy airspace and exemption conditions	Obtain any required COA or controlled-airspace approval and complete the manuals, training, medical, aircraft, or crew items stated in the grant.	The exemption’s conditions and limitations are legally controlling for the operation.

Operations Manual, Training Program, and Demonstrated Knowledge

FAA policy for streamlined Part 137 UAS certification requires an operations manual and a training program even though the text of Part 137 does not generally require those documents for every traditional operator. The operator normally keeps the documents rather than submitting them for routine preapproval, but must provide them to the FAA on request.

The operations manual should cover the actual system and mission: safety risk management, weather, NOTAM review, site planning, aircraft inspection, preflight and postflight duties, normal and emergency procedures, lost-link response, crew communication, accident reporting, hazardous-material handling and stowage, and maintenance. The training program should address initial and recurrent training, site surveying, flight training, emergency procedures, exemption conditions, any COA, and safe material handling.

Part 137 also requires knowledge and skill appropriate to agricultural operations. Current FAA UAS policy allows the required Part 137 knowledge and skill evaluations to be self-administered for many routine UAS applicants, but completion must be documented and available for inspection. Special operations can require additional FAA involvement.

Operating Rules That Still Matter After Certification

An exemption and AAOC are not blanket permission to release material anywhere. Part 137 prohibits dispensing in a manner that creates a hazard to people or property on the surface. Pesticide application must follow the registered use, safety directions, and limitations of the product label, together with federal and state pesticide law.

Commercial operators must keep current service records at the designated home base, make the certificate available for inspection, and allow FAA inspections, including on-the-job inspections. The exact recordkeeping, maintenance, medical, crew, standoff, altitude, speed, and airspace conditions can also appear in the exemption or COA. Build the operating checklist from the actual decision letter, not from a generic online summary.

Pre-Launch Part 137 Checklist

Confirm that the substance and dispensing purpose fall within Part 137.
Determine the fully loaded takeoff weight and select the correct registration and operating path.
Identify the legal operator and whether the operation is private or commercial.
Confirm that the aircraft make, model, registration number, and configuration are covered by the exemption.
Obtain the exemption before submitting FAA Form 8710-3 for the AAOC.
Complete the operations manual, training program, knowledge documentation, and crew qualification records required by the grant.
Obtain any required COA or controlled-airspace authorization.
Verify pesticide licensing, product registration, label directions, worker-protection, and state requirements.
Run a documented site survey covering people, roads, structures, sensitive areas, wind, drift, emergency landing areas, and lost-link behavior.
Carry or maintain all documents exactly as required by the exemption, AAOC, registration path, and applicable regulation.

Frequently Asked Questions

Is a Part 107 certificate enough to spray crops with a drone?

No. A Remote Pilot Certificate may be one pilot qualification within the approval stack, but covered dispensing operations generally require an FAA exemption and a Part 137 Agricultural Aircraft Operator Certificate in addition to the underlying flight rules.

Does Part 137 apply only to pesticides?

No. The definition also reaches substances intended for plant nourishment, soil treatment, propagation of plant life, or pest control, plus other covered agricultural dispensing activity. Evaluate the released material and its intended purpose.

Can a farmer use a private certificate to spray neighboring farms?

Not for compensation or hire under the private certificate. Private operations are limited to the property and crop interests described in Part 137.35. Customer work normally requires a commercial agricultural aircraft operator certificate.

How early should the exemption petition be filed?

FAA instructs applicants to file at least 120 days before the exemption is needed or before an existing exemption expires. That is a filing requirement, not a guaranteed processing time. Do not schedule paid application work before all required approvals are active.

Related Guides

Compliance notice | This page provides general federal compliance information and does not replace legal advice, an FAA decision letter, a pesticide label, or state-specific guidance. Verify the current rules and approvals before operating.