Package Delivery by Drone (Part 135)

As drones are introduced into everyday life in the U.S. from recreational flying to commercial uses, the FAA's number one priority remains safety. Whether manned or unmanned aircraft, FAA requires that all operators follow specific guidelines for the operations they request.

The FAA is encouraging innovation and working with industry, state, local, and tribal governments to realize the benefits of drones and inform future rules and regulations. From 2017 through 2020, the Unmanned Aircraft Systems (UAS) Integration Pilot Program (IPP) focused on testing and evaluating the integration of civil and public drone operations into our national airspace system. This work continues under the UAS BEYOND program, which focuses on the remaining challenges of UAS integration, including beyond visual line of sight (BVLOS) operations, societal and economic benefits of UAS operations, and community engagement.

Participants in these programs are among the first to prove their concepts, including package delivery by drone through part 135 air carrier certification. Part 135 certification is the only path for small drones to carry the property of another for compensation beyond visual line of sight.

As participants in these programs move to prove their concepts, they must use FAA's existing part 135 certification process, some of which FAA has adapted for drone operations by granting exemptions for rules that don't apply to drones, such as the requirement to carry the flight manuals on board the aircraft.

There are four types of Part 135 operations:

  • A part 135 Single-Pilot operator is limited to using one pilot for all part 135 operations.
  • A Single Pilot in Command is limited to using one pilot in command and up to three second-in-command pilots. There are also limitations on the size of the aircraft and the scope of the operations.
  • A Basic operator is limited in the size and scope of their operations: A maximum of five pilots, including second-in-command, and a maximum of five aircraft can be used.
  • A Standard operator has no limits on the size or scope of operations; however, the operator must be granted authorization for each type of operation they want to conduct.

All part 135 applicants must go through the five phases of the certification process.

The FAA issues air carrier certificates to U.S. applicants based on the type of services they plan to provide and where they want to conduct their operations. Operators must obtain airspace authorizations and air carrier or operating certificates before they begin operations.

Focus Items Specific to UAS Certifications 

  1. The certification team will request an operator provide a concept of operations (CONOPS) during the preapplication phase. This allows the certification team to become familiar with the proposed operation. CONOPS should include the purpose and scope of the operation as well as the geographical areas of operation. Additionally, the type of unmanned aircraft should be identified, to include airworthiness, performance and capabilities.
  2. During phase 1, an operator is required to present evidence of an aircraft with an airworthiness certificate. Alternately, an operator may petition for an exemption to this requirement per 49 U.S.C. Section 44807: Special Authority for Certain UAS.
  3. During the document compliance phase, an operator will be required to show compliance with the Code of Federal Regulations. If an operator is unable to comply with certain regulations, the operator may petition for exemption from those regulations. This is necessary, as many of the traditional regulations don’t support UAS operations. 
  4. Prior to receiving an air carrier or operating certificate, an environmental assessment is required for compliance with the National Environmental Policy Act (NEPA) and the implementation of regulations issued by the Council on Environmental Quality (CEQ). The following website contains more information related to NEPA and UAS: Public Involvement and Environmental Review for Drone Operations
  5. Deviation requests may be submitted for proposed management personnel who do not meet the traditional 14 CFR part 119.69 (a) management personnel requirements. Operators may also apply for FAA approval for management personnel under part 119.69 (b). 
  6. Validation testing may require additional regulatory relief because an exemption issued for use with an air carrier certificate may not be valid until the certificate is issued.
    • sUAS that meet the requirements to operate under Title 14 CFR Part 107, may require a Title 14 CFR Part 107 waiver for operations such as BVLOS prior to validation testing. 
    • UAS that do not meet the requirements to operate under Title 14 CFR Part 107 (over 55 pounds), may require a type certificate, or 49 U.S.C. 44807 Grant of exemption or Special Airworthiness Certificate. Airworthiness Certification of Aircraft
  7. Prior to certification an operator will be required to show compliance with the reporting requirements located in the conditions and limitations of their exemption. (e.g. Area of Operations Plan (AOO), Ground Risk Assessment, Communication Services Assessment, and Collision Avoidance Strategy.) Exemptions that have been issued to air carriers can be found on regulations.gov.
  8. During phase 4, the certification team will conduct an on-site facility inspection and validation testing of the operator’s flight and maintenance procedures.  The certification team will also conduct practical tests for pilots in command (PICs) and check pilots. 

The following links provide additional information

Operators Approved for Part 135 UAS Package Delivery Operations

The FAA issued the first 14 CFR Part 119 air carrier certificate with authority to operate unmanned aircraft systems (UAS) under 14 CFR Part 135 as a single-pilot operator to Wing Aviation, LLC in April 2019. In October 2019 the FAA amended this authority to operate as a standard 14 CFR part 135 operator. Wing Aviation, LLC was a part of the Integration Pilot Program (IPP) and delivered food and over-the-counter pharmaceuticals directly to homes in Christiansburg, VA. Wing Aviation, LLC continues with BEYOND and is expanding their operations.

UPS Flight Forward, Inc., another IPP participant that continued on with BEYOND, was the first company to receive a 14 CFR part 119 air carrier certificate to operate UAS as a standard 14 CFR part 135 operator. In September 2019, UPS Flight Forward, Inc. conducted its first commercial package delivery by drone operations with the Matternet UAS, flying medical supplies at WakeMed hospital campus in Raleigh, NC.

Amazon Prime Air was the first company to operate a drone larger than 55 pounds under a 14 CFR part 119 air carrier certificate as a standard part 135 operator. Amazon Prime Air began commercial operations in August 2020, in Pendelton, OR.   

In June 2022, Zipline International Inc. became the fourth drone operator to receive a 14 CFR part 119 air carrier certificate as a standard part 135 operator. Zipline was the first company to complete air carrier certification as part of the BEYOND program and the first fixed-wing 14 CFR part 135 UAS operator. Zipline began operations in Charlotte, NC

In January 2023, Causey Aviation Unmanned, Inc. was granted a 14 CFR part 119 air carrier certificate, with authority to operate as a standard part 135 operator. They began on-demand commercial drone deliveries in Holly Springs and Raeford, NC with the Flytrex UAS.

In November 2024, DroneUp, LLC became the sixth U.S. drone operator to receive a 14 CFR part 119 air carrier certificate with authority to operate as a standard part 135 operator. Drone Up, LLC began operations in the Murphy, TX area as an on-demand package delivery service provider.

The seventh U.S. drone operator to receive a 14 CFR part 119 air carrier certificate with authority to conduct operations under 14 CFR part 135 was Drone Express, Inc. (DEXA). They received their air carrier certificate in April 2025 and will conduct on-demand, small package delivery in Winston-Salem, NC.
 

Last updated: Tuesday, June 17, 2025