FAA Part 137 Agricultural Drone Requirements
Learn what Part 137 covers for agricultural drone spraying, including certification, exemptions, COAs, and FAA application steps.
What Part 137 Covers for UAS Agriculture
FAA Part 137 governs aircraft operations that dispense or spray certain substances. The rule covers drones as well as crewed agricultural aircraft.
- DJI Agras T100 100 L
- DJI Agras T70P 70 L
- XAG P150 70 L
- DJI Agras T55 50 L
- DJI Agras T50 40 L
- Yamaha FAZER R 32 L
| Model | Value |
|---|---|
| DJI Agras T100 | 100 L |
| DJI Agras T70P | 70 L |
| XAG P150 | 70 L |
| DJI Agras T55 | 50 L |
| DJI Agras T50 | 40 L |
| Yamaha FAZER R | 32 L |
Sources: ag.dji.com, ag.dji.com, xa.com, ag.dji.com, ag.dji.com, global.yamaha-motor.com
The key test is the operation being performed, not whether the aircraft has a spray tank. FAA guidance identifies agricultural operations as:
- Dispensing an economic poison as defined in Section 137.3.
- Dispensing substances for plant nourishment, soil treatment, plant propagation or pest control.
- Dispensing material that directly affects agriculture, horticulture or forest preservation.
The FAA also places disinfectants for viruses within the economic-poison category. However, not every substance dispensed from a drone falls under Part 137. Operators should therefore check the proposed substance and purpose against Section 137.3 before applying.
This distinction matters for mixed fleets. A drone used only for mapping does not become a Part 137 operation merely because the business also sprays crops. The dispensing activity is what brings the agricultural flight into the framework described by the FAA.
Why the FAA created a streamlined UAS process
FAA notices have described UAS agricultural aircraft operations as lower risk than other certificated operations. The agency said revising the UAS certification process would not adversely affect safety.
The FAA reached that position after seeing a significant increase in UAS certificate applications. It had approved hundreds of requests with few incidents. Its resulting policy sought to standardise decisions across Flight Standards Safety Assurance offices while reducing unnecessary documentation.
That approach did not remove the underlying operating duties. It changed how certain applications were processed and where documents were sent.
Operators should also note the status of the supporting notices. Notice 8900.659 is marked cancelled, and the FAA identifies Notice 8900.704 as cancelled as well. The agency’s dedicated page for dispensing chemicals and agricultural products should therefore be checked against any older notice used for background.
Core FAA Requirements Operators Must Have in Place
A Part 137 certificate is one part of the regulatory package. The FAA says an exemption holder must operate in accordance with:
- The conditions and limitations of the exemption.
- The required Part 137 certificate.
- The operator’s ATO-issued COA.
- All pertinent sections of 14 CFR.
Basic requirements also include a Remote Pilot Certificate and registration of the UAS. An operator should not treat an exemption, certificate or aircraft registration as a substitute for the others.
Start by classifying the aircraft correctly
The FAA’s UAS application guidance separates aircraft according to a 55-pound threshold. Payload is included when applying that threshold.
A drone weighing less than 55 pounds, including the substance being dispensed, may operate under Part 107. The operation requires relief from Section 107.36 concerning hazardous material, along with applicable Part 137 provisions.
A drone weighing 55 pounds or more operates under Part 91 and Part 137. The operation requires exemptions from relevant provisions in Parts 61, 91 and 137.
These routes affect registration and exemption work. They do not change the initial question of whether the dispensing activity falls within Part 137.
Keep the approval set aligned
The FAA’s operational-validation policy reflects a practical problem: some exemption holders were conducting commercial agricultural work outside their exemption conditions.
A sound compliance check should therefore compare the intended operation with every controlling document. Aircraft, substance, airspace, crew arrangements and operating method should all match the permissions being relied upon.
This is broader than checking whether a pilot holds a certificate. The operation itself must remain inside the exemption, Part 137 certificate, COA and pertinent regulations.
Operators building a wider compliance file can use our guides index to organise related operating material. FAA documents remain the controlling source for federal requirements.
How the FAA Is Handling Part 137 Certification
The FAA’s general Part 137 certification page describes a process that tests the applicant’s programmes, systems and intended compliance methods. It combines preapplication and formal application through an Applicant Readiness Checklist.
The remaining stages cover document compliance, demonstration and inspection, and certification. During demonstration and inspection, the certification team examines facilities and equipment. It also observes personnel carrying out their duties, with emphasis on regulatory compliance and safe practice.
Certification follows after the applicable requirements and preceding phases have been completed. The FAA may then issue the Agricultural Aircraft Operating certificate.
The streamlined UAS application route
The dedicated UAS guidance describes a more direct submission route. Applicants are no longer required to send their initial documents to the local Flight Standards District Office.
Instead, the applicant completes FAA Form 8710-3 and submits it with the issued exemption number to UAS137Certificates@faa.gov. The FAA then begins the Part 137 UAS certification process.
Earlier FAA policy transferred these applications within the Safety Assurance System to the 137 UAS Operations Office. It required the applicant to provide FAA Form 8710-3 and the issued exemption number. The operator still had to petition for relief from regulations applicable to the proposed operation and intended aircraft.
The same policy allowed the knowledge and skill tests under Section 137.19(e) to be self-administered for qualifying UAS agricultural operations. Satisfactory completion had to be documented and shown to the FAA on request. This did not remove the pilot-in-command requirements under Section 137.41(c).
Special circumstances could still require Flight Standards District Office involvement. FAA guidance used an unmanned aircraft fitted with an aerial ignition system as an example.
Because the relevant notices are now marked cancelled, operators should not assume an older workflow remains unchanged. Application instructions should be checked directly with the FAA before documents are submitted.
Operational Validation Is More Than an Application Check
The FAA has implemented operational validations for exemption holders. Their purpose is to confirm that operators understand the duties attached to agricultural UAS work.
The agency has also sent requests for information seeking basic operational details. It says it will not move forward with a decision letter without that information. A petition may be closed if the applicant does not respond.
This makes document control an operating issue rather than an administrative afterthought. The person preparing the petition should be able to connect its statements to the planned field operation.
A useful internal review should confirm that the team understands:
- Which substance brings the flight within Part 137.
- Which aircraft registration route applies.
- Which exemption conditions control the work.
- What the Part 137 certificate authorises.
- What the ATO-issued COA requires.
- Which pilot and aircraft records must be available.
This checklist does not replace FAA instructions. It helps expose mismatches before an operational validation or field deployment.
What the FAA Says About UAS Agricultural Operations
Advisory Circular 137-1B describes an acceptable means of applying for an Agricultural Aircraft Operator Certificate. It is not the only possible means, and the circular is not itself a regulation.
An applicant choosing that method must follow it in all important respects. Applicable regulations still control where the circular and a regulatory requirement differ.
The circular expressly applies to agricultural aircraft operations using UAS. It also directs UAS operators towards related drone rules, the exemption process and FAA procedures.
The circular explains why exemptions are central to the process. Some Part 137 provisions cannot be met by a UAS, while others do not apply to unmanned operations. The operator therefore needs relief from the appropriate provisions before reaching the demonstration and inspection stage described there.
That exemption principle applies on both sides of the 55-pound threshold. The exact regulatory route differs, but a Part 137 application cannot be treated in isolation.
Where Agricultural Drone Operators Fit in the FAA Framework
The FAA lists dispensing chemicals and agricultural products within its Advanced Operations guidance. That section sits beside aircraft certification, package delivery, emergency approvals and UAS traffic management.
The placement signals that agricultural dispensing can require more than the standard small-UAS framework. Additional certification or approval may be needed, depending on the aircraft and operation.
Beyond visual line of sight is another separate consideration. The FAA’s NPRM proposes performance-based rules for low-altitude BVLOS operations and supporting services. Agriculture is specifically listed among the intended use cases.
The proposal is intended to provide a predictable route for routine and scalable UAS work. It also names package delivery, aerial surveying, training, demonstrations, recreation and flight testing. As an NPRM, however, it is a proposal rather than a substitute for an operator’s existing approvals.
Operators comparing operational categories can consult our drone specifications alongside the FAA framework. Specifications help classify equipment, but they do not establish regulatory permission.
Relevant Agricultural Drone Platforms
Part 137 applies to the dispensing operation, not to a model merely appearing in a product list. None of the examples below should be read as a claim of model-specific FAA approval.
The DJI Agras T25 has a 20 L spray tank and a maximum take-off weight of 52 kg when spraying at sea level. The DJI Agras T50 carries 40 L for spraying and has a maximum spraying take-off weight of 92 kg at sea level.
At the larger end of the supplied range, the DJI Agras T100 has a 100 L spray tank. Its maximum take-off weight is 175 kg in the standard spraying configuration.
The Hylio Ares has a 13 gal (50 L) spray tank and a maximum take-off weight of 220 lb (100 kg).
The Yamaha FAZER R is a petrol-powered unmanned helicopter with a 32 L spray tank. These different airframes can all illustrate why operators must check weight, registration and exemptions before certification.
Mapping hardware presents a useful contrast. The DJI Mavic 3M carries multispectral and RGB cameras, while the Wingtra WingtraOne GEN II is specified for mapping. The supplied data does not identify either platform as a dispensing aircraft.
Hardware capability therefore answers only part of the planning question. The operator must separately establish whether the work is regulated by Part 137 and whether every required approval is in place.
Practical Reading of the FAA Process
The safest interpretation is to treat Part 137 as an operating system, not a single form. Certification, exemptions, registration, pilot credentials and the COA must support the same planned operation.
Begin with the substance and purpose. Then classify the aircraft by its operating weight, including payload. After that, identify the registration and exemption route before submitting FAA Form 8710-3.
Finally, prepare for operational validation. The FAA wants evidence that the certificate holder understands the actual limits of the operation, not merely the names of the documents involved.