Dispensing Chemicals and Agricultural Products (Part 137) with UAS
The FAA has begun to send requests for information (RFI) seeking basic operational information. Without this information, the FAA will not move forward with a decision letter and will close your petition request for failure to respond to the RFI. If you have any questions about the RFI, please contact 9-AVS-ARM320-Exemptions@faa.gov
14 CFR Part 137 governs the use of aircraft, including drones, to dispense or spray substances (including disinfectants).
Not all substances fall under this regulation, so you should first check to see if your proposed operation is regulated by Part 137. If the substance you plan to dispense does fall within the definitions in Section 137.3 refer to Certification Process for Agricultural Aircraft Operators for guidance on the requirements you must meet before dispensing it.
What's an Agricultural Operation?
Under Part 137, the following aircraft operations are considered 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.
- Engaging in dispensing activities directly affecting agriculture, horticulture, or forest preservation.
Note: The FAA considers chemicals used as disinfectants for viruses to fall in the category of economic poisons as defined in Section 137.3.
Applying for a Part 137 UAS Certificate
There’s a new streamlined process for those applying for a Part 137 UAS certificate. This allows the FAA to streamline both the Part 137 agricultural UAS certification and the drone exemption process for visual line of sight (VLOS) operations conducted within the altitude and airspeed limitations stipulated by the exemption.
Applicants are no longer required to submit documents to their local Flight Standards District Office. Instead, the applicant must complete FAA Form 8710-3 and submit their exemption number to UAS137Certificates@faa.gov for the FAA to begin the certification process.
How to Apply:
Have a registered UAS weighing below or above 55 pounds.
- Drones weighing less than 55 pounds (including the weight of the substance being dispensed) may operate under 14 CFR Part 107 and require exemption from Section 107.36 Carriage of hazardous material as well as several Part 137 regulations. Petitioners must apply for their FA-number through FAADroneZone.
- Drones weighing 55 pounds or more are operated under 14 CFR Part 91 and Part 137 and require exemption from several regulations in 14 CFR Parts 61, 91, and 137. Petitioners must apply for their N-number through Civil Aviation Registry Electronic Services (CARES) or by mail. For more information see Aircraft Registration.
Note: Requests to operate outside of these routine agricultural-related operations or requests to use aircraft without prior § 44807 approval may take longer to review.
You must send a petition for exemption at least 120 days before you need the exemption to take effect or 120 days before your current exemption expires, if you wish to extend it (14 CFR § 11.63(d)).
- Please find the information that you must include in your petition for an exemption.
- Your name and mailing address and, if you wish, other contact information such as a telephone number, or e-mail address;
- The specific section or sections of Title 14 of the Code of Federal Regulations (CFR) from which you seek an exemption;
- The extent of relief you seek, and the reason you seek the relief;
- The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a whole;
- The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which you seek the exemption;
- A summary we can publish in the Federal Register stating:
- The rule from which you seek the exemption;
- A brief description of the nature of the exemption you seek;
- Any additional information, views or arguments available to support your request; and
- If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do so.
- Submit a petition for an exemption by commenting on the shell docket number FAA-2007-0001-0001. After submission, retain the docket confirmation receipt provided. A docket number (for example “FAA-2025-0000”) will be created and applied to your petition.
- By electronic submission, submit your petition for exemption to the FAA online through the Federal Docket Management System website.
- By paper submission, send the original signed copy of your petition for exemption to this address:
U.S. Department of Transportation, Docket Operations, West Building Ground Floor, Room W12-140, 1200 New Jersey Avenue, SE., Washington, DC 20590.
*See also Instructions for Submitting Petition to FAA and Visual Aid for Submitting Petition to FAA.
- You will receive an email from 9-AVS-ARM320-Exemptions@FAA.gov about the FAA’s decision on your petition. A copy of this decision is also placed in the public docket. The FAA will include the docket number associated with your petition in our letter to you (14 CFR 11.91).
For more information on how to petition for an exemption, see the FAA's Office of Rulemaking website. View examples of exemptions for drones conducting agricultural operations.
The following information must be provided prior to issuance of an exemption and should be attached to your petition. If the information is not included with your petition, the FAA will send a Request for Information (RFI) by email. Please provide the below information as a comment to the docket or email 9-AVS-320-Exemptions@FAA.gov along with your docket number.
Note: Be sure to mark files and file names as confidential or proprietary if you wish for them to be handled as such.
- The applicant’s full legal name and address. Please note, a P.O. Box is NOT an acceptable address.
- The Chief Supervisor of Operations. The “Chief Supervisor of Operations” is the point of contact for the petitioner that will be able to answer any potential FAA questions regarding the applicant’s operations in a timely manner.
- What is the contact information for the Chief Supervisor of Operations to include a phone number and an email address? Please provide the Chief Supervisor of Operations’ address if different from the applicant’s address. Note, a P.O. Box is NOT an acceptable address.
- Who will be the pilot in command (PIC) for the proposed UAS operations? Please provide the name and pilot certificate number for your PIC (for example "1234567"). Alternatively, proof of a Temporary Airman Certificate would also be acceptable.
- What aircraft do you intend to operate under this exemption? Please provide each aircraft’s make, model, and FA or N-number (for example “FA3######” for UAS below 55 lbs. or "N123UA" for UAS above 55 lbs.). Please also provide the name of the owner of each aircraft you intend to operate under this exemption.
* For extension or amendment requests only: - What is your Agricultural Aircraft Operator Certificate (AAOC) number? (for example "123A456B") Do NOT send the application. Please only send the requested certificate numbers.
If the FAA does not receive all the requested information in sufficient detail necessary to process your petition, the FAA may close your petition.
You must complete the exemption process and receive your exemption number before applying for an Agricultural Aircraft Operator Certificate (AAOC). The requirement that all operators conducting agricultural operations hold an Agricultural Aircraft Operator Certificate (AAOC) remains in place. You can obtain an AAOC by completing and submitting the 8710-3 form to UAS137Certificates@faa.gov.
- The applicant must complete FAA Form 8710-3 (PDF) and submit their exemption number to UAS137Certificates@faa.gov for the FAA to begin the certification process.
- The applicant name on Form 8710-3 (PDF) must match the name of the Part 137 exemption holder.
For an amendment and extension requests to an exemption, if an operator previously failed to obtain their AAOC in a timely manner, the operator must now apply for and obtain an AAOC; upon receipt, the operator must provide the Office of Rulemaking with the AAOC number. Please email the AAOC number and Regulatory Docket number (for example “FAA-2025-0000”) to 9-avs-arm320-exemptions@faa.gov. Until the FAA receives the AAOC number the FAA will take no further action on the request.
If the operator wishes to obtain relief from the requirement to hold an AAOC to conduct agricultural operations, please submit a petition for exemption for that specific request and ensure that it meets all elements of part 11.81. Find more information on the Petition for Exemption or Rulemaking page.
Please note: Failure to submit accurate and complete information in a timely manner will result in delays in processing your request.
To learn more about dispensing chemicals and agricultural products (Part 137), contact the UAS Support Center.