Agricultural Drones Over 55 Pounds: FAA Requirements

A loaded agricultural drone that weighs 55 pounds or more is not a Part 107 aircraft. The operator moves into a Part 91 and Part 137 framework that normally requires an FAA exemption, N-number registration, an Agricultural Aircraft Operator Certificate, and an Air Traffic Organization Certificate of Waiver or Authorization when required. The aircraft cannot be treated as a standard Part 107 spray drone simply because it flies at low altitude over a field.

The Loaded Takeoff Weight Controls the Regulatory Path

Part 107 applies only when the unmanned aircraft weighs less than 55 pounds at takeoff, including everything onboard or attached. For an agricultural platform, that calculation includes the aircraft, batteries, tank or hopper, liquid or granular material, pump, hoses, boom, nozzles, radar, cameras, mounting hardware, and any other carried equipment.

Exactly 55 pounds is outside Part 107 | The Part 107 definition is less than 55 pounds, not 55 pounds or less. Build a documented weighing procedure around the real working configuration, not the manufacturer’s empty weight or an estimated tank load.

Under-55 and Over-55 Agricultural UAS Compared

Issue	Less than 55 lb at takeoff	55 lb or more at takeoff
Underlying flight rule	Part 107	Part 91
Agricultural operating rule	Part 137	Part 137
Aircraft registration	FA number through FAADroneZone	N-number through CARES or the Aircraft Registry
Regulatory relief	Exemption from applicable Part 107 and Part 137 provisions	Exemption from applicable Parts 61, 91, and 137 provisions under the FAA’s statutory authority
Air traffic approval	As required by airspace and the exemption	Large-UAS operations generally require an ATO-issued COA in addition to the exemption
Pilot and crew	Remote Pilot Certificate and other conditions stated in the grant	Pilot, medical, training, crew, and supervision requirements stated in the grant and COA

What a Section 44807 Exemption Does

Section 44807 gives the FAA authority to use a risk-based, case-by-case process for certain UAS that cannot operate under Part 107 or cannot comply with rules written for conventional aircraft. The operator petitions under Part 11 and identifies the specific regulations from which relief is requested, why the relief is needed, why it serves the public interest, and how the proposed operation will provide an equivalent level of safety.

The exemption is not a general license for the drone model. It is a decision issued to the named petitioner and controlled by its conditions and limitations. Those conditions can identify approved aircraft, registration, pilot qualifications, medical certification, visual observers, operational area, maximum altitude and speed, distance from people and structures, weather, daylight or night restrictions, maintenance, manuals, training, records, notification, and emergency procedures.

Do not rely on another company’s exemption number, a manufacturer’s approval, or a dealer’s statement that a model is “FAA approved.” A manufacturer may have supporting aircraft documentation or a model may have prior Section 44807 acceptance, but the operating company still needs authority that covers its own legal entity and intended operation.

N-Number Registration for a Large Agricultural UAS

FAA guidance directs operators of agricultural drones weighing 55 pounds or more to obtain an N-number through Civil Aviation Registry Electronic Services, commonly called CARES, or through the Aircraft Registry by mail. This is different from the FA-number registration used for small UAS in FAADroneZone.

The registered owner, aircraft identity, serial number, legal name, and supporting ownership documents must be consistent across the registration, exemption petition, AAOC application, insurance, maintenance file, and operating records. Resolve ownership before filing. A mismatch between the exemption holder, aircraft owner, and AAOC applicant can create delay or require additional documentation.

Part 137 Agricultural Aircraft Operator Certificate

Large agricultural UAS still require the Part 137 operator certificate when the mission falls within the agricultural dispensing definition. The FAA’s current UAS process requires the operator to complete the exemption process first, then submit FAA Form 8710-3 with the exemption number. The name on the application must match the exemption holder.

The AAOC does not replace the exemption, and the exemption does not replace the AAOC. The operator must hold both unless the FAA has expressly granted relief from a specific requirement. Commercial service work also brings the Part 137 business-name and recordkeeping provisions into the compliance file.

Certificate of Waiver or Authorization

FAA air traffic guidance states that large UAS operators conducting agricultural operations must obtain an ATO Certificate of Waiver or Authorization. The COA defines where and how the operation may access the National Airspace System and can impose operating areas, altitudes, communications, observers, transponder or surveillance requirements, NOTAM procedures, and other air traffic conditions.

A COA is not a substitute for the exemption or AAOC. Controlled-airspace approval is also not automatically included simply because the aircraft is operating from a farm. Read the exemption and COA together and apply the more restrictive condition when they overlap.

Pilot, Medical, Training, and Crew Requirements

The regulations in Parts 61, 91, and 137 were largely written for manned aircraft. A UAS cannot comply with every cockpit, airworthiness, manual-carriage, or pilot provision as written, so the exemption replaces specific rules with UAS conditions. Current streamlined agricultural UAS policy uses a Remote Pilot Certificate as a baseline pilot credential for UAS-only Part 137 operators and may impose medical, training, chief-supervisor, visual-observer, and operator-specific qualification requirements.

Use the actual decision letter. Do not assume the pilot qualifications for a small Part 107 mapping drone apply to a heavy spray platform. The operator should maintain a qualification matrix showing which pilot, observer, loader, mixer, and ground crewmember has completed each required course, check, medical item, and recurrent event.

Manuals, Maintenance, and Configuration Control

FAA policy for Part 137 UAS operators requires an operations manual and training program, and the exemption normally adds maintenance conditions. A heavy agricultural system needs a controlled configuration record covering aircraft serial number, firmware, flight-control settings, batteries, motors, propellers, pump, tank, hoses, nozzles, radar, remote controller, payload limits, and any modifications.

Maintenance records should identify the work performed, date, aircraft or component time where applicable, parts replaced, person performing the work, inspections, damage, software updates, and return-to-service decision. Chemical exposure, corrosion, clogged nozzles, pump wear, seals, hose condition, propeller damage, and battery degradation directly affect flight and application safety.

Do Not Buy Capacity Before Confirming the Approval Path

A larger tank can reduce refill frequency, but it also moves the aircraft outside Part 107 and can lengthen the regulatory, training, logistics, and insurance setup. Compare usable field productivity, not advertised tank volume. A heavy platform may carry more per sortie while requiring more people, larger transport equipment, higher charging or generator capacity, more restrictive site control, and a longer approval process.

Before placing a nonrefundable order, obtain the aircraft make, model, serial-number format, empty and maximum takeoff weight, approved payload configurations, manufacturer operating limitations, maintenance program, safety documentation, prior Section 44807 status, and evidence that the seller can support the exemption package. Prior approval of a model can help, but it does not guarantee approval of the buyer or every proposed configuration.

Heavy Agricultural UAS Approval Checklist

Weigh the complete working configuration and document that it is 55 pounds or more at takeoff.
Confirm that the mission is an agricultural aircraft operation under Part 137.
Establish the legal operator, aircraft owner, chief supervisor, pilots, and home base.
Obtain the N-number and ensure the aircraft identity matches every application and record.
Prepare the Section 44807 petition with the exact aircraft, operation, requested relief, and safety case.
Provide the FAA’s requested basic operational information and respond completely to any RFI.
Receive the exemption before applying for the Part 137 AAOC.
Obtain the ATO COA and any separate controlled-airspace authorization required for the site.
Complete the operations manual, training program, maintenance system, medical items, and crew qualification records required by the grant.
Verify pesticide labels, applicator licenses, product registration, WPS, state rules, insurance, transport, loading, and spill procedures.
Validate each field operation against the current exemption, COA, AAOC, aircraft configuration, and site plan.

Frequently Asked Questions

Can I operate a 55-pound agricultural drone under Part 107?

No. Part 107 applies to an aircraft weighing less than 55 pounds at takeoff. An aircraft at exactly 55 pounds or above requires another FAA path.

Can I launch with a partial tank and use Part 107?

Do not make that assumption from weight alone. The aircraft registration, approved configuration, exemption, and operating authority must support the chosen path. A large-UAS platform approved and registered under one framework should not be switched between frameworks without confirming the legal basis with the FAA.

Does the manufacturer’s exemption cover the buyer?

Generally no. An exemption is issued to the named petitioner and controlled by its terms. Manufacturer documentation or prior model approval may support the buyer’s petition, but the operating company needs its own applicable authority.

Does an AAOC authorize BVLOS?

No. The agricultural operator certificate addresses Part 137 authority. BVLOS, one-to-many operation, controlled airspace, and other advanced privileges require separate authority when they are outside the exemption and COA.

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.