Package Delivery by Drone (Part 135)
As drones are introduced into everyday life in the United States, from recreational flying to commercial operations such as Package Delivery by Drone, the FAA's number one priority remains safety. The Agency is at the forefront encouraging innovation and working with industry, state, local, and tribal governments to realize the benefits of drones and inform future rules and regulations.
The FAA is developing a draft Programmatic Environmental Assessment (PEA) that evaluates the potential environmental impacts of UAS package delivery operations in the United States. The proposed action analyzed in the draft PEA is drone operators conducting commercial drone package deliveries under 14 Code of Federal Regulations (CFR) Part 135.
The FAA plays an important role with Package Delivery by Drone operations by ensuring safety in the National Airspace System (NAS), operator certification under FAA Part 135 and compliance with National Environmental Policy Act (NEPA) regulations.
How Does Package Delivery by Drone Work?
Drone Operator Certification
FAA is responsible for the certification, production approval, and continued airworthiness of aircraft which includes drones conducting package deliveries. The agency issues certificates, exemptions, waivers, and operations specifications for drone operations.
Safety in the NAS
Eventually most drone package deliveries will be part of the Unmanned Aircraft System Traffic Management (UTM) once it is fully developed and implemented. There may be some who operate in areas where they are the only operator or in rural areas where they will not use or do not need UTM. UTM will enable multiple drones operating under Beyond Visual Line-of-Sight (BVLOS) regulations at low altitude airspace (under 400 feet above ground level (AGL). BVLOS refers to any drone operation that is flown outside of the pilot’s direct line of sight. Direct FAA air traffic services are not provided to these operations. UTM will consist of a cooperative interaction between drone operators and the FAA to determine and communicate real-time airspace status. The FAA will provide real-time constraints to the UAS operators, who are responsible for managing their operations safely within these constraints without receiving positive air traffic control services from the FAA.
Environmental Review
The FAA ensures the appropriate level of NEPA review for the Package Delivery by Drone operators and leads the preparation of individual NEPA documents to ensure compliance and smooth integration of UAS operations into the NAS.
The FAA has completed more than 20 environmental assessments (EAs) for individual drone package delivery proposals and one PEA for drone package delivery. Each EA resulted in a Finding of No Significant Impact (FONSI). States represented in previous environmental reviews for Part 135 drone package delivery include Arizona, Arkansas, California, Florida, Missouri, North Carolina, Ohio, Oregon, Texas, Utah, and Virginia.
For more information see:
Drone operators are required to comply with state and local requirements, inform the local community of their operations, obtain an FAA Part 135 Certificate and Airspace Authorization, establish a hub and delivery infrastructure, comply with NEPA, and respond to public inquiries concerning their operations.
Environmental Responsibilities
Drone operators are responsible for mitigating adverse environmental impacts by implementing mitigation measures and/or best management practices identified in the NEPA document. Environmental resource categories requiring mitigation may include noise, wildlife, historic resources, and others.
Mitigation examples may include reducing the number of operations per day to reduce noise impacts. Or locate a hub a specified distance from a noise sensitive area which include residential, educational, health, and religious structures and sites, and parks, recreational areas, areas with wilderness characteristics, wildlife refuges, and cultural and historical sites. In a case of wildlife mitigation an operator may create a buffer zone around bald eagle nests; or for an historic resource they may site a hub a sufficient distance away from historic resource.
Operators should recognize that some noise from drone operations may not reach what is considered a “significant impact” according to NEPA but may still impact the public and therefore should respond to their concerns.
Community Engagement
Drone companies that want to establish a hub must abide by any state and local requirements. In addition to the FAA involving the public as part of the NEPA process, it is important for drone operators and local governments to inform the local community about the proposed drone operations.
The FAA does not select the locations for commercial drone operators to conduct operations. The operators select the locations. Operators are expected to site their distribution hubs in accordance with all local land use ordinances and zoning requirements in addition to setback distances from noise sensitive areas. In addition to coordinating with the FAA, drone operators may have to work with local government to obtain approvals. An applicant’s community engagement may be a parallel process to the FAA’s public involvement as part of the NEPA review.
Operator Certification
Drone operators that want to conduct small package delivery must use the FAA’s existing Part 135 certification process and obtain an exemption or waiver to provide drone package deliveries using BVLOS. All part 135 applicants must go through the full 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 air operator certificate before they can begin operations.
Certificates are available for four types of Part 135 operations:
- A Part 135 Single-Pilot operator is a certificate holder that is limited to using only one pilot for all Part 135 operations.
- A Single Pilot in Command certificate is a limited part 135 certificate. It includes one pilot in command certificate holder and three second pilots in command. There are also limitations on the size of the aircraft and the scope of the operations.
- A Basic operator certificate 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 in their operation.
- A Standard operator holds a certificate with 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.
Focus Items Specific to UAS Certifications
- 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.
- 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.
- 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.
- 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 webpage contains more information related to NEPA and UAS: Public Involvement and Environmental Review for Drone Operations
- 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).
- 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.
a. 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.
b. 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 - 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.
- 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.
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 up to three 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.
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, utilizing the Prism V2 aircraft.
In April 2025, Drone Express, Inc. (DEXA) was the seventh drone operator to receive a 14 CFR part 119 air carrier certificate, with authority to conduct operations under 14 CFR part 135 was. They received their air carrier certificate in April 2025 and will conduct on-demand, small package delivery in Dayton, OH, utilizing the Telegrid aircraft.
In Sept. 2025, MAA, Inc., dba Direct2, became the first manned part 135 air carrier to add UAS operations to their certificate. They currently utilize the Matternet UAS aircraft and will conduct on-demand, small package delivery, in Mountain View, CA.