# Drone for pesticide spraying: FAA permissions and the farm handover

URL: https://leafwrit.com/us/agricultural-spray-drone-requirements/
Reviewed: 2026-10-29

A drone for pesticide spraying needs the applicable FAA exemptions and a Part 137 Agricultural Aircraft Operator Certificate. Basic requirements include a Remote Pilot Certificate and a registered aircraft. The application route is on the [FAA agricultural dispensing page](https://www.faa.gov/uas/advanced_operations/dispensing_chemicals).

## What counts as an agricultural operation under Part 137

Part 137 governs the use of aircraft, including drones, to dispense or spray substances, disinfectants included. Not all substances fall under Part 137, so first check whether the proposed operation is regulated by it.

Three kinds of dispensing are agricultural by nature: dispensing any economic poison as defined in section 137.3, dispensing any other substance intended for plant nourishment, soil treatment, propagation of plant life or pest control, and dispensing activities directly affecting agriculture, horticulture or forest preservation. The FAA places chemicals used as disinfectants for viruses in the economic-poison category.

## The FAA sequence: registration, petition, information, certificate

The route has four steps: register the aircraft, petition for an exemption, supply basic operational information, and apply for the Agricultural Aircraft Operator Certificate (AAOC).

The exemption process must be complete, with the exemption number received, before the AAOC application. The requirement that every operator conducting agricultural operations hold an AAOC remains in place. Questions about dispensing chemicals and agricultural products under Part 137 go to the UAS Support Center (uashelp@faa.gov).

## Basic operational information

The FAA requires this information before an exemption is issued, and it should be attached to the petition:

- the applicant's full legal name and address;
- the Chief Supervisor of Operations, with phone number, email address and address if different from the applicant's;
- the pilot in command, by name and pilot certificate number, or proof of a Temporary Airman Certificate;
- each aircraft's make, model and FA or N-number, such as FA3###### for a UAS below 55 lbs. or N123UA for one above 55 lbs., and the owner of each aircraft;
- for extension or amendment requests only, the AAOC number: send the number, not the application.

A P.O. Box is not an acceptable address, for the applicant or for the Chief Supervisor of Operations. The Chief Supervisor of Operations is the petitioner's contact who can answer FAA questions about the applicant's operations in a timely manner.

If the information is not attached to the petition, the FAA sends a Request for Information (RFI) by email. The answer goes in as a comment to the docket, or by email to 9-AVS-320-Exemptions@FAA.gov with the docket number. Files and file names are marked confidential or proprietary when that handling is wanted. If the FAA does not receive all the requested information in sufficient detail, it may close the petition. Inaccurate or incomplete information delays processing.

## The exemption petition

A petition includes the applicant's name and mailing address, the sections of Title 14 CFR from which relief is sought, the extent of relief and the reason for it, and why granting it would be in the public interest. It also states why the exemption would not adversely affect safety or how it provides a level of safety at least equal to that of the rule, and a summary the FAA can publish in the Federal Register.

Electronic submission is a comment on shell docket FAA-2007-0001-0001 at regulations.gov. After submission, the docket confirmation receipt is retained and a docket number such as FAA-2025-0000 is created for the petition. Paper petitions go to the Department of Transportation, Docket Operations, West Building Ground Floor, Room W12-140, 1200 New Jersey Avenue, SE., Washington, DC 20590. The decision arrives by email from 9-ASE-ARM320-Exemptions@faa.gov, and a copy goes in the public docket.

Send the petition at least 120 days before the exemption must take effect. The same lead time applies to an extension before the current exemption expires.

## Aircraft weight: below or above 55 pounds

Weight includes the substance being dispensed. A drone below 55 pounds operates under Part 107 and needs exemption from section 107.36 (carriage of hazardous material) and from several Part 137 provisions; the FA-number is applied for through FAADroneZone. A drone of 55 pounds or more operates under Parts 91 and 137 and needs exemption from several provisions of Parts 61, 91 and 137; the N-number is applied for through Civil Aviation Registry Electronic Services (CARES) or by mail.

## Which operations the streamlined process covers

The streamlined process combines Part 137 agricultural UAS certification with the drone exemption process for visual line of sight (VLOS) operations within the altitude and airspeed limitations stipulated by the exemption. Requests outside routine agricultural operations, or to use aircraft without prior section 44807 approval, may take longer to review.

## Form 8710-3 and the AAOC application

Applicants no longer submit documents to the local Flight Standards District Office. The applicant completes active Form 8710-3 and sends it with the exemption number to UAS137Certificates@faa.gov. The form is active in its December 1, 2016 edition, printed “12/16”; the instruction printed on it to submit it to the local Flight Standards District Office no longer applies to this route. The applicant name on the form must match the name of the Part 137 exemption holder.

The form's applicant fields:

| Field | What the form asks |
| --- | --- |
| 1. Application for | Original, amendment or reissuance; private or commercial; dispensing of economic poisons or of substances other than economic poisons |
| 2. Name and address of applicant | Name, address and telephone number |
| 3. Principal operations base | Airport, city, state and telephone number |
| 4. Operating as | Individual, corporation, partnership or other (specify) |
| 5. Name of chief supervisor of operations | Marked “Commercial Operations Only” |
| 6. Airman certificate held | Certificate number; grade (private, commercial, airline transport); ratings (helicopter, gyroplane, AMES, AMEL, ASES, ASEL); type rating(s) |
| 7A and 7B. Waiver | Whether a currently effective certificate of waiver for agricultural aircraft operations is held; if yes, date issued, expiration date and FAA district office where issued |
| 8. Agricultural aircraft to be operated | Registration mark (minimum one), make, model, equipped for liquid or solid, total number of each aircraft operated |
| 9. Agricultural pilots | Names and airman certificate numbers of the pilots working for the applicant; extra pilots go on a separate attached sheet |
| 10. Remarks | Remarks, if applicable |
| 11. Certification | Date, title and signature under the statement that the information on the form is true and correct |

The inspection-report page is marked “For FAA Use Only.”

## What the FAA checks after the exemption is issued

Exemption holders must follow their exemption, the required Part 137 certificate, the ATO-issued Certificate of Waiver or Authorization (COA) and all pertinent sections of 14 CFR. The FAA is implementing operational validations to check this.

## Pesticide applicator certification is separate from the FAA certificate

Federal law requires any person who applies or supervises the use of restricted use pesticides (RUPs) to be certified under EPA regulations and state, territorial and tribal laws. State, territorial and tribal authorities certify applicators, and certification is required in each state, territory and area of Indian country where RUPs are applied. Their requirements can be stricter than the federal ones: many states require all commercial applicators, not only those using RUPs, to be certified. Most states have a Pesticide Safety Education Program that provides training and study materials.

## Part 137 knowledge subjects and private-operator limits

The knowledge test for an agricultural aircraft operator certificate covers the steps before starting operations, including a survey of the area to be worked; safe handling of economic poisons and disposal of used containers; the effects of economic poisons and agricultural chemicals on plants, animals and persons; the symptoms of poisoning, emergency measures and the location of poison control centers; the aircraft's performance and operating limitations; and safe flight and application procedures.

A private agricultural aircraft operator certificate prohibits operations for compensation or hire and over a congested area. It also prohibits operations over any property unless the operator owns or leases it or has an ownership or other property interest in the crop on it.

## Dispensing limits in Part 137

No one may dispense material from an aircraft in a manner that creates a hazard to persons or property on the surface. A registered economic poison may not be dispensed for a use other than the one for which it is registered, contrary to any safety instructions or use limitations on its label, or in violation of any law or regulation of the United States.

## Records and certificate duties of a commercial operator

The holder of a commercial agricultural aircraft operator certificate keeps current records at the designated home base: each customer's name and address, the service date, and the name and quantity of the material dispensed for each operation. The records also include each pilot's name, address and certificate number and the date the pilot met the knowledge and skill requirements. They are kept at least **12 months** and made available for inspection by the Administrator on request.

No one may operate under a business name that is not shown on the commercial agricultural aircraft operator certificate. The FAA must be notified in writing in advance of any change in the address of the home base. A holder that ceases operations under Part 137 surrenders the certificate to the responsible Flight Standards office last having jurisdiction. A facsimile of the certificate is carried on the aircraft and presented for inspection on request of the Administrator or a law enforcement officer.

## Practical checks before you file and before the first flight

Before you file, check the paperwork:

- Compare the applicant name on Form 8710-3 with the name of the exemption holder. If the legal entity differs, fix that first; a similar trading name will not explain the difference.
- Write the Chief Supervisor of Operations, the pilot in command and the aircraft owner as three separate entries, even when one person fills all three roles.
- Identify each aircraft by make, model and FA or N-number, not by a commercial nickname or the wording on an invoice. If a Temporary Airman Certificate is the proof, attach that document instead of copying a permanent number you assume will follow.
- Keep the docket confirmation receipt, the docket number assigned to the petition and the decision together, and quote the docket number in every later message to the FAA. Note which version of an answer went to the docket or mailbox and which later one replaced it.
- Count back 120 days from the start of your field season to get the latest filing date, and do not assign flights until you hold the decision.

Before the first customer flight:

- Collect the real documents: the exemption conditions, the AAOC and the COA. Check which aircraft and which activities each one covers.
- Decide whether you work under a private or a commercial certificate before you accept customer work, because a private certificate rules out work for hire.
- Ask the contractor where the treatment will take place and who holds the pesticide applicator credential for that location. Check that credential in addition to the aviation approvals.
- Ask for an itemized quotation: aircraft service, mobilization, treatment area and the documents you will receive.
- Go through the product label and the field layout with the ground crew, and agree in advance how loading stops if a person walks into the planned work area.

## Next step

The application sequence is on the [FAA agricultural UAS page](https://www.faa.gov/uas/advanced_operations/dispensing_chemicals); pesticide applicator certification comes from your [state authority](/us/state-pesticide-regulatory-agencies/).

### What permissions does a drone for pesticide spraying need?

Obtain the applicable FAA exemption and Part 137 agricultural operator certificate. Check pesticide applicator certification for the treatment jurisdiction.

### Is a remote pilot certificate enough for a drone chemical sprayer?

No. A Remote Pilot Certificate is one of the basic requirements; dispensing also requires the exemption and the Part 137 operator certificate.

### Which form is used for an agricultural spray drone operator certificate?

Use active Form 8710-3, edition 12/16. For agricultural UAS certification, send it with the exemption number to UAS137Certificates@faa.gov.

### How long before the start date must the exemption petition be sent?

At least 120 days before the exemption must take effect, or 120 days before the current exemption expires if you want to extend it.