FAA Part 137: Agricultural Aircraft Operator Certificate for Drones

What Part 137 is

14 CFR Part 137 is the agricultural aircraft operator certificate, originally written for manned aircraft (crop dusters and helicopters) and later interpreted by FAA to cover small unmanned aircraft systems (sUAS). Any person or business conducting aerial application of economic poison, seed, or other agricultural substance for hire or for their own agricultural operation must hold a Part 137 certificate. The certificate is issued by the local FAA Flight Standards District Office (FSDO) after review of the operations manual, training records, and any applicable exemption petitions.

Part 137 commercial vs. private

FAA distinguishes commercial operators (spraying for hire or custom application work) from private operators (a farmer spraying only their own crops on land they own, lease, or rent). Private operators are eligible for a simplified Part 137 with reduced recordkeeping and no commercial-fleet airworthiness requirements. Commercial operators have the full Part 137 obligations including operations manual, crew training documentation, and maintenance records. The commercial certificate is the correct path for any operator who charges customers or sprays for neighbors.

The Section 44807 exemption

Section 44807 of the FAA Reauthorization Act allows FAA to grant exemptions for unmanned aircraft that fall outside standard Part 107 rules. Drones over 55 lbs and commercial spray operations with sUAS require a 44807 exemption as part of the Part 137 package. The exemption petition documents the specific aircraft, operations manual compliance, pilot training, and maintenance program. Most ag drones (DJI Agras T50 at 90+ lbs loaded, Hylio AG-272 at 140 lbs loaded, DJI T100 at 220 lbs loaded) cross the 55 lb threshold and therefore require 44807.

How to get Part 137

The application process: (1) complete Part 107 first; (2) draft an operations manual covering the items listed below; (3) prepare training records for each pilot and crew member; (4) submit a Section 44807 petition if applicable; (5) file the Part 137 application package with your local FSDO; (6) complete FSDO review and interview. The FAA target is 90 to 180 days but delays caused by manual revisions and petition corrections often push this to 6 to 9 months for DIY applicants. Consultants (Thrush Aircraft, PrecisionHawk, UAV Coach, RobinAero) charge $2,500 to $4,500 for a complete package and typically cut approval time by 60 to 120 days by submitting a clean package on the first pass.

What the operations manual must include

FAA requires the operations manual to cover: (1) crew training program and recurrent training schedule; (2) aircraft maintenance program with inspection intervals and service bulletins; (3) chemical handling and personal protective equipment procedures; (4) emergency procedures including lost-link, fly-away, and medical emergencies; (5) recordkeeping for flights, maintenance, chemical applications, and incident reports; (6) congested area operations plan if applicable; (7) weather minimums specific to sUAS; (8) crew fitness and duty time limits. Manuals typically run 60 to 120 pages. Templates are available from consultants and from FAA Advisory Circular AC 137-1 (manned operations, adapted for sUAS).

Common mistakes that delay approval

The four most common delays: (1) operations manual missing one or more required sections, particularly emergency procedures and maintenance intervals; (2) Section 44807 petition filed in the wrong format (FAA has a specific template); (3) missing or incomplete pilot training documentation, including initial and recurrent records; (4) attempting to file Part 137 before holding Part 107 (FAA requires Part 107 for the responsible remote pilot before issuing Part 137). A consultant who has shepherded 20+ applications through FSDO typically avoids all four.