Special Drone Operations Permissions for Agricultural Work

“Special permission” is a route, not one FAA document

For agricultural pilots, “special drone operations permission” is not the name of a single federal approval. The right route depends on what the aircraft carries, what it dispenses and how the pilot plans to fly.

The FAA’s Unmanned Aircraft System or Drone Operations guidance sets out the main federal paths. Its scope includes the Small UAS Rule, air-carrier work and agricultural aircraft operations.

For most non-recreational small UAS work, Part 107 is the baseline. Agricultural spraying can bring Part 137 into play as well. Transporting dangerous goods is a separate issue again and may lead to the Part 135 authorisation track.

That distinction matters when an operator describes the job. Mapping a field, dispensing a substance and carrying another party’s property are not the same task under FAA rules.

The FAA’s recreational guidance also warns pilots not to treat unpaid work as recreational by default. Almost all non-recreational flying is regulated by Part 107, though complex agricultural flights may use other rules or waivers.

Before filing anything, write down the proposed operation in plain terms:

• What will the drone carry?
• Will it dispense or spray a substance?
• Does that substance fall within Part 137?
• Will the flight stay within visual line of sight?
• Is the UAS below or at least 55 pounds when loaded?
• Is the operator carrying another party’s property for payment?

Those answers point towards the right FAA process. They also stop operators from filing for a broad “special permission” that does not match the work.

Start with the mission, then match the federal path

The FAA guidance separates routine small UAS work from dispensing and dangerous-goods transport. Operators should make that split before preparing forms, manuals or exemption requests.

Proposed work	Main federal path identified in FAA guidance	First point to check
Non-recreational small UAS work	Part 107	Pilot status, operating limits and any needed authorisation
Dispensing or spraying a regulated substance	Part 137, with other rules based on aircraft weight	Whether the substance meets the definition in Section 137.3
Carrying another party’s property for payment beyond visual line of sight	Part 135	Certification and dangerous-goods programme needs
Work outside standard operating limits	Waiver or exemption route may apply	Which rule blocks the planned flight

Part 107 allows many kinds of UAS operation. It does not, however, provide a waiver for carrying or transporting dangerous goods. The FAA states that Part 107 prohibits that carriage at all times.

That rule should not be read as meaning all agricultural dispensing is barred. The FAA has a distinct page for dispensing chemicals and agricultural products, which directs regulated work into Part 137.

The difference between carriage and dispensing must remain clear in the application. An operator should describe the payload, its owner, its purpose and what happens to it during flight.

Pilots still choosing the type of work they plan to offer can review How to choose an agricultural drone. That choice should follow the intended regulatory path, not come before it.

Spray work must first pass the Part 137 test

Part 137 governs aircraft, including drones, used to dispense or spray substances. The FAA says this can include disinfectants, but not every substance falls under the rule.

The first Part 137 task is therefore classification. Check whether the proposed substance and operation fit the definitions in Section 137.3. If they do, use the FAA’s certification guidance before dispensing it.

This is broader than a simple check on whether a payload is called a pesticide. The filing should state what the substance is and why the aircraft will release it. Vague terms such as “farm product” do not settle which rule applies.

Operators should also separate the aircraft certificate from the rest of the spray business. The FAA process covers aviation approval. The supplied licensing resources also identify state pesticide licensing as a separate part of legal spray work.

Our detailed FAA Part 137 for agricultural drones guide covers that rule set. Operators who need the mechanics of pumps, tanks and flow control can also read How agricultural drone spraying systems work.

The FAA describes Part 137 certification as a process in which it reviews the applicant’s programmes, systems and intended ways to comply. The process includes document review, demonstration and inspection before certification.

The general Part 137 certification page describes five phases:

• preapplication;
• formal application;
• document compliance;
• demonstration and inspection;
• certification.

Preapplication and formal application are combined through the Applicant Readiness Checklist. During demonstration and inspection, the certification team checks facilities and equipment. It also watches personnel carry out their duties.

The UAS spray route now starts with a central submission

The FAA’s UAS dispensing page describes a streamlined application process for a Part 137 UAS certificate. It covers Part 137 certification and the drone exemption process for visual-line-of-sight operations within the exemption’s altitude and airspeed limits.

Under that UAS-specific route, applicants no longer submit their documents to the local Flight Standards District Office. They complete FAA Form 8710-3 and send their exemption number to UAS137Certificates@faa.gov so the FAA can begin certification.

That instruction is more specific than the broader FAA pages that direct Part 137 questions to a Flight Standards District Office. An agricultural UAS applicant should use the current dispensing page for the filing route that matches this work.

The generic Part 137 page remains useful for understanding how certification is assessed. It says applicants must prepare themselves and become familiar with the rule’s certification and operating needs.

The aircraft’s loaded weight then determines the next branch.

Loaded UAS weight	FAA route stated for Part 137 dispensing
Less than 55 pounds, including the dispensed substance	Part 107; exemptions are needed from Section 107.36 and several Part 137 rules
55 pounds or more	Part 91 and Part 137; exemptions are needed from several rules in Parts 61, 91 and 137

For the lighter route, petitioners apply for an FA-number through FAADroneZone.

Hazardous-material transport is not a spray shortcut

The FAA and the Pipeline and Hazardous Materials Safety Administration have issued guidance for assessing the distinct risks of moving hazardous materials by UAS. Its stated audience is Part 135 applicants and certificate holders seeking authority to transport those materials.

This track may matter to an agricultural firm, but it should not be treated as a substitute for Part 137. The key question is whether the planned flight transports dangerous goods or dispenses a substance as an agricultural aircraft operation.

Part 135 is the only regulatory path identified by the FAA for carrying another party’s property for payment beyond visual line of sight. Its certification process calls for a dangerous-goods training programme and manual.

The FAA says it works with applicants during that process to check regulatory and safety needs. It applies the same dangerous-goods expectations used for traditional crewed Part 135 on-demand certificate holders.

By contrast, Part 137 applies to agricultural and other special aircraft operations in which dangerous goods are dispensed during flight. The operator’s mission description must make this difference plain.

Questions about dangerous goods involving a UAS can go to the FAA Office of Hazardous Materials Safety at hazmatinfo@faa.gov. The FAA also gives 405-954-0088 for voice messages and asks callers to allow 1–2 business days for a reply.

A clean file starts with certificates, limits and records

A Remote Pilot Certificate is the starting point for commercial small UAS work under Part 107. The University of Florida’s regulatory overview says pilots obtain it by passing an aeronautical knowledge test.

Part 107 also sets operating limits. Its standard framework includes visual-line-of-sight flight and controlled-airspace authorisation. Flights outside standard limits may need a waiver backed by a case for safe operation.

For Part 137 spraying, an industry overview also identifies a Remote Pilot Certificate and an Agricultural Aircraft Operator Certificate as core credentials. The exact mix still depends on aircraft weight, the substance and the exemption terms.

Before filing, build a compliance pack around the actual mission:

• Remote pilot and operator certificate details;
• aircraft registration details;
• loaded aircraft weight;
• substance name and its Part 137 status;
• proposed flight area and airspace;
• visual-line-of-sight plan;
• exemption number and relevant conditions;
• operating, training and safety documents;
• the matching FAA form and submission route.

Do not copy a previous operator’s description without checking it. A change in weight, payload, ownership or flight method can change the applicable path.

Operators planning a commercial service should also read Running a drone spraying business. The aircraft permission is only one part of the job; the business must also manage chemical rules, records and client scope.

The latest FAA pages should control the filing plan

The key news for applicants is that FAA material now combines a broad certification framework with a UAS-specific submission route. The general Part 137 page explains how the agency reviews an applicant. The dispensing page tells UAS spray operators where to start the streamlined filing.

The FAA’s broader UAS and dangerous-goods page remains the baseline for deciding whether Part 107, Part 135 or Part 137 is the relevant federal path.

Applicants should watch for changes in three places: the UAS operations guidance, the dispensing page and the Part 137 certification page. Exemption terms also matter because they set the bounds of the approved operation.

The practical rule is simple: define the work before seeking permission. A mapping flight, a spray pass and dangerous-goods transport may all use a drone, but the FAA does not treat them as one operation.