Learning guide
FAA Part 137 for agricultural drones
6 of 6 sections complete
1. Determine whether Part 137 applies
The FAA says Part 137 governs aircraft—including drones—used to dispense or spray covered substances. Its agricultural-operation categories include dispensing an economic poison; dispensing another substance intended for plant nourishment, soil treatment, propagation of plant life, or pest control; and dispensing that directly affects agriculture, horticulture, or forest preservation.
Start with the definitions in 14 CFR 137.3 and the facts of the proposed operation. Do not assume every payload is covered, or that calling a material seed, fertilizer, disinfectant, or biological product settles the question.
2. Identify the aircraft pathway
The FAA's current UAS instructions distinguish aircraft below 55 pounds—including the dispensed substance—from aircraft weighing 55 pounds or more. The lighter pathway may operate under Part 107 with required exemption relief. The heavier pathway operates under a different set of rules and requires relief from different provisions.
Use actual operating weight and the FAA's current instructions. Registration category, pilot requirements, requested relief, aircraft documentation, and operating conditions can differ. Do not copy another operator's petition without confirming that its aircraft and operation match yours.
3. Build the operating foundation
Before seeking agricultural authority, identify the legal applicant, chief supervisor of operations, pilots, aircraft, registration identifiers, proposed substances, and operating concept. The FAA currently calls for a registered UAS and identifies a Remote Pilot Certificate among the basic requirements for applicable operations.
Document crew roles, maintenance, loading, containment, emergency response, drift and exposure controls, communications, recordkeeping, and how the operation will remain inside applicable flight and exemption limits. These are operational controls, not application paperwork alone.
4. Obtain the required exemption relief
UAS operators commonly cannot comply literally with every rule written for conventional agricultural aircraft. The FAA's published pathway therefore requires petitioning for exemption from the specific provisions that need relief. A petition must satisfy 14 CFR 11.81 and explain the requested relief, public interest, and how safety will not be adversely affected or will remain equivalent.
The FAA page says petitions should be submitted at least 120 days before the exemption is needed or an existing exemption expires. Treat that as a minimum filing rule, not a promised decision time. Respond completely to any FAA request for information and retain the docket record and decision letter.
5. Apply for the Agricultural Aircraft Operator Certificate
The FAA states that the exemption process must be completed and an exemption number received before applying for the AAOC in its streamlined UAS process. The applicant then uses the current FAA Form 8710-3 process described on the official dispensing page. The applicant name must match the exemption holder.
An exemption and an AAOC are separate pieces of authority. Do not begin covered operations because one step is complete while the other remains pending. Use the current FAA page for submission instructions rather than relying on a saved email address or old form workflow.
6. Operate within every condition and limitation
Approval is not a blanket permission. The FAA specifically warns operators to comply with their exemption's conditions and limitations, required Part 137 certificate, applicable certificate of authorization, and all pertinent regulations. Build a mission-release checklist that tests the proposed field, aircraft, pilot, substance, airspace, weather, and operating plan against those documents.
Federal aviation authority also does not replace pesticide applicator certification, product-label compliance, state or local requirements, or permission to use the property. Keep those requirements in a separate compliance matrix and stop the mission when any required authority or condition cannot be verified.
See the field information Wisconsin Aerial collects before reviewing an agriculture request.
Glossary
- AAOC
- Agricultural Aircraft Operator Certificate, the FAA certificate required for covered agricultural aircraft operations unless specific relief applies.
- Economic poison
- A defined Part 137 term. Consult 14 CFR 137.3 for the controlling definition.
- Exemption
- FAA-granted relief from identified regulations, subject to its own conditions and limitations.
- Part 137
- 14 CFR Part 137, Agricultural Aircraft Operations.
- VLOS
- Visual line of sight. The FAA identifies a streamlined UAS Part 137 process for specified VLOS operations within the applicable exemption limits.
Official links
- FAA: Dispensing chemicals and agricultural products with UAS
Current FAA UAS Part 137 overview and application sequence.
- eCFR: 14 CFR Part 137
Current regulatory text, including definitions and certification rules.
- eCFR: 14 CFR 11.81
Required content for a petition for exemption.
- FAA: Part 107 waivers
Separate FAA waiver information; a waiver and an exemption are not interchangeable.
- FAA: Register your drone
