Ultimate Guide to Large Drones/Heavy Lift Drones (55lbs.+)

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Curious about flying large drones legally—and avoiding costly mistakes? You’ve come to the right place.  Whether you’re a filmmaker, surveyor, agricultural operator, or innovator pushing the limits of drone tech, heavy-lift drones open the door to powerful capabilities—but they also come with serious legal and regulatory challenges.

In this article, I’ll walk you through what it really takes to operate large drones lawfully in the U.S., including the hidden legal traps that can cost you thousands, the most common problems operators face, and practical answers to questions I hear all the time.

I’m not just offering theory—I’m a commercial pilot, FAA-certified flight instructor, aviation attorney, and former Embry-Riddle professor. I’ve helped clients across the country secure complex FAA approvals and avoid compliance pitfalls, and I’ve distilled those lessons into this guide to help you do the same.

If you need help with FAA exemptions or legal strategy, I’ve included details about my services and pricing at the end.

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Uses for Large Heavy Lift Drones

Large drones are really focusing on one thing….moving material.

Spraying Crops

I have a massive article just on drone spraying. Hundreds of people are using large drones now to spray pesticides, herbicides, pollen, fertilizer, etc. on crops and animals around the United States.

Firefighting

Ship to Shore and Vice-Versa

Deer Removal After the Hunt

Removing Stuff from Power Lines

Construction in Difficult Terrain

Powerline Stringing

Carrying Large Camera/ Sensor Equipment

A large camera for cinematography, LIDAR for terrain, a chemical sensor for monitoring the air, etc.  Some sensors are just large and very heavy. When you need high-quality data, you are sometimes forced to fly large drones that can carry the payloads.

Bird Diverters Installed on Powerlines

Carrying Stuff for the Utility Industry (Wirecuttings, Nest Remover, etc.)

Linebird has stuff to help those in the utility industry such as ohmmeters, wire cutters, grapple, etc. https://linebird.net/products/ 

Vegetation

Large drones can be used to remove chopped-up logs from difficult-to-reach areas and transport plants to workers operating in remote areas doing reforestation/rehabilitation work on the environment.

Closed-Set TV and Movie Filming

For TV/movie productions, large, high-quality cameras and lenses are needed to capture all of the action. Drones are perfect for this. These types of operations have a special exemption associated with them so the pilot can fly closer to the film crew. I have done many exemptions for closed-set TV/movie filming.

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Certifications You Need to Obtain to Fly a 55 and Heavier Drone

• Each drone must obtain a certificate of registration under Part 47. This is the “N Number” registration. IMPORTANT! You cannot do the FAA Drone Zone method of registration under Part 48 and you obtain an “FA Number” which is only for under 55-pound and heavier drone operations. 55 pound and heavier drones can only use Part 47 N number registrations. This costs $5 per drone. We can help you with this.
• Each pilot must have a remote pilot certificate. $175 test per pilot.
• Regarding medical certificates, some exemptions require them and some do not. It’s a case-by-case basis.  We have obtained exemptions without them.  If needed, each pilot must have a 3rd class medical certificate. Varying costs.  You’ll have to go to a medical doctor.
• The operator must obtain an exemption. This could be ONE exemption that ALL of the employee pilots get to use. The FAA does not charge to approve these. The only thing is that this would cost you time, or you’ll need to hire someone to help you.
• Each aircraft must have an airworthiness certificate or the make and model must have a Section 44807 determination.

Other:

• If you are spraying substances (pesticides, fertilizers, pollen, herbicides, etc.), you’ll need a Part 137 operating certificate.  See 14 CFR 137.3 for the full definition of what is triggered.
• If you are transporting other people’s property for compensation or hire, you’ll need a Part 135 operating certificate.

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Laws for Large Drones

Public Aircraft v. Civil Aircraft

Before we dive into everything, I’m gonna help you make sense of a lot of things by explaining public aircraft versus civil aircraft.  ALL of the Federal Aviation statutes and Federal Aviation regulations apply to civil aircraft while only SOME of the federal statutes and some of the Federal Aviation regulations apply to public aircraft which are aircraft that are owned and operated in one of six ways according to federal statute and there is no compensation or reimbursement for the flight. 49 USC Sections 40102(a)(41) and 40125 explain further.

Everyone is a civil aircraft by default but certain types of government entities can qualify for a public aircraft status. There are big benefits to public aircraft status, in that the FAA does not exercise control over the certification of their pilots, the building of their aircraft, or the maintenance of the aircraft, but only over the operation of the aircraft. It’s not that there isn’t a standard; it’s just that the FAA does not create the standard.

The government entity creates its standards for this. You can understand that when you look at the military. They designed their own fighter jets using their own aircraft standards while using their own maintenance standards and having their own fighter jet mechanics with their own fighter jet pilots. The rules of the road in the Federal Aviation Regulations apply to those fighter jets and also to civil aircraft because we don’t want people crashing into each other. There is a common set of regulations governing the operation of aircraft.

How do you figure out which regulation applies to a government operator? You’ll need to review the regulations. If it says “aircraft,” then it applies to ALL aircraft. If it says “civil aircraft,” then it applies ONLY to civil aircraft and not public aircraft. There is a handy list in the regulations for public aircraft operations. I do have one of these if you want to purchase it from me.  You end up having to read through the 1,000+ regulations to figure out which ones apply and which do not.

Federal Statutes

The statutes we look to are in Title 49 of the United States Code (USC).  These statutes tell the FAA what to do and give the FAA certain powers. There is ALOT that could be said here but for purposes of this article, let’s focus on 49 USC Section 44807.

In the manned aviation world, manufacturers spend a great deal of time getting type certifications from the FAA. Each of the aircraft manufactured ends up with it’s own airworthiness certificate. With drones, the vast majority of manufacturers do not do this. How do we get them legal? They don’t have airworthiness certificates. Section 44807 gives the FAA the power to determine that certain aircraft do not need an airworthiness certificate. That’s how we get an aircraft legal to fly.

Back in the day, this was called Section 333 but was later moved into Section 44807. Here is an important point. The 44807 determination only applies to the aircraft. A 44807 determination is 99% of the time always used with an exemption. The reason for this is that 44807 fixes the airworthiness problem, but doesn’t fix the problems with the rest of the regulations. You need the exemption to fix the remaining problems. This is why people refer to them as 44807 exemptions. They are almost always used together.

Federal Aviation Regulations (FAR’s)

The Federal Aviation Regulations are located in Parts 1-198.

You will be flying under Part 91, NOT Part 107, as Part 107 is only for aircraft under 55 pounds. These regulations explain the requirements for ALL aircraft in how they operate. The regulations prescribe some regulations only towards civil aircraft, such as it being airworthy, etc.

For most, we deal with the airworthiness requirement in Section 91.7 by getting the aircraft determined under 44807. However, there is another option. The aircraft can obtain an airworthiness certificate. This is valuable for rapid research and development type of aircraft. If you are interested in this, let me know.

Additionally, if you are doing special things in that operation, you will have an additional layer of regulations that apply to your operation.

• Package Delivery of Another’s Property For Hire or Compensation. If you are transporting another person’s property for compensation or hire, then Part 135 applies to your operation also. This requires a Part 135 operating certificate.
• Agricultural aircraft operations. “means the operation of an aircraft for the purpose of (1) dispensing any economic poison, (2) dispensing any other substance intended for plant nourishment, soil treatment, propagation of plant life, or pest control, or (3) engaging in dispensing activities directly affecting agriculture, horticulture, or forest preservation, but not including the dispensing of live insects.” “Economic poison means (1) any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any insects, rodents, nematodes, fungi, weeds, and other forms of plant or animal life or viruses, except viruses on or in living man or other animals, which the Secretary of Agriculture shall declare to be a pest, and (2) any substance or mixture of substances intended for use as a plant regulator, defoliant or desiccant.”  If you are doing these types of operations.

Exemptions from the Federal Aviation Regulations

If you read Parts 91, 133, 135, and 137 above, you’ll notice that some of the regulations are not easy to comply with. Some are impossible or highly financially burdensome.  To address this, we obtain an exemption from multiple regulations in these areas.

Blanket Certificate of Authorization (COA) that Comes with the Exemption

The exemptions almost always come with a COA. There is a standard “blanket” COA that everyone gets. See my article here for further explanation.  This explains where you can fly with it. If you need to fly in an area near airports, you’ll need another COA. It’s not that it is prohibited to fly near airports, just that you need another COA.

Export Laws

The reason I mention this is that ECCN 9A012 applies to drones that fly for certain lengths of time. With these large drones, you can put a bunch of batteries on them and get pretty good flight times.  There might be a possibility that the large drone is under export control just due to the sheer amount of batteries it can carry and have really long flight times.  Additionally, if the drone can carry a certain amount of pounds and fly at least 300 kilometers, the ITAR regs would apply. The reason I’m flagging this for you is that there are certain regulations in the Export Administration Regulations (EAR) and the International Trafficking in Arms Regulations (ITAR) that require you to protect the equipment and technical data from exporting. Exports can happen within the United States. You don’t have to export the drone outside the country to have an export violation. It could be something as simple as allowing someone with a work visa or student visa to have access to the controlled technology. I have a huge article on drone export laws here.

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Airworthiness Determinations

FAA does not have jurisdiction over public aircraft airworthiness determinations.  FAA does control determinations on the airworthiness of civil aircraft.

You have two ways of getting civil aircraft determined: you can have either EACH aircraft have an airworthiness certificate or the make and model (thus is applicable to ALL of the aircraft everywhere) is determined by the FAA, under Section 44807, to not need an airworthiness certificate.

Here is how it works. For an early beta version of an aircraft, you might want to obtain a quick experimental certificate for the aircraft to get data while you are going for a 44807 determination.  You eventually want to obtain a 44807 determination so ALL of your customers can fly it. (They will still need an exemption, registration, etc. but the airworthiness issue has been resolved for all of the customers). This is why the 44807 determination is very valuable.

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Section 44807 Determinations

FAA puts out a list of all of the 44807ed aircraft. Here is the list. FAA-2023-1271.  It’s constantly being updated.  Just view the latest one.

How do you apply for a section 44807 determination?

Step 1. Prep all of your supporting documents. You apply on regulations.gov for a petition for exemption. You’ll have to put the 44807 determination request in the petition for exemption.

Step 2. Submit all of the supporting documentation to the FAA. Note that if your material is export-controlled, you must submit it in a way compliant with the export regulations. You should be submitting at a minimum the following: (a) user manual and (b) maintenance manual.  If it is difficult to find the information, it will take longer for the FAA to process the request. Your manuals should answer questions such as, but not limited to, aircraft performance capabilities, aircraft flight limitations, lost link programming, and emergency procedures for all sorts of various emergencies and equipment failures.

Step 3. Answer any FAA questions they have.

At some point, the FAA will deny it or add it to the docket. They might add it to the docket before the underlying petition is granted so check the FAA-2023-1271 list regularly.

If you want help with getting your aircraft on the list, we can help you with getting an aircraft added.

How long does it take?

To get an aircraft determined under 44807, it can take around 37 days to  to 15 months.

The fastest one that can be tracked on regulations.gov, that I know of, is 37 calendar days. This was the one we did. :)  The 44807s can be determined somewhat quickly if the package (1) has everything in it and (2) it’s organized well.

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Problems with the 55 Pound and Heavier Exemptions for Civil Aircraft

Blanket COA

The blanket certificate of authorization (COA) being given out with the exemptions for 55-pound and heavier drone spraying operations say the following:

Beyond the following distances from the airport reference point (ARP) of a public use airport, heliport, gliderport, or seaport listed in the Digital – Chart Supplement (d-CS), Alaska Supplement, or Pacific Chart Supplement of the U.S. Government Flight Information Publications:
(1) 5 nautical miles (NM) from an airport having an operational control tower; or
(2) 3 NM from an airport having a published instrument flight procedure, but not having an operational control tower; or (3) 2 NM from an airport not having a published instrument flight procedure or an operational control tower; or
(4) 2 NM from a heliport.

This is what it looks like on a sectional chart for the airspace around Austin, Texas.

You can obtain approvals to fly in SOME of those red areas. The blanket COA says, “For all UAS requests not covered by the conditions listed above, the exemption holder may apply for a new Air Traffic Organization (ATO) COA at https://caps.faa.gov/coaportal.”  It just means another hoop you have to jump through if you need to fly there.

Also, drones cannot even operate in Bravo and Charlie airspace without having ADS-B out or without authorization. If you get a COA, you have to make it also a 91.225 COA and not just some general airspace COA. This is a point many will miss.

In heavily congested airspace environments, this is a deal breaker for 55-pound and heavier operations which means you have to do your operations under 55 pounds under Part 107 which does not have the 500ft buffer zone. This is the same area under Part 107 regulations. Those 3 red areas are where a COA is required under Part 107.

When it comes to getting COA approvals. Part 107 wins. The CAPs portal above for 55+ operations is a super pain to connect to and takes longer than LAANC which is the FAA’s new way of granting COAs electronically within seconds in certain locations. The FAA is transitioning from the CAPs portal to the FAA Drone Zone portal for future COAs for operators so that will speed things up and make things much easier. :)

500ft Buffer Zones

Most of the exemptions have a buffer zone restriction of some sort.

To operate a drone 55 pounds and heavier, you’ll need an exemption from some of the regulations in Part 91. One of them is 91.119(c). The exemptions being given out which grant regulatory relief from 91.119(c) require under restriction you to stay a certain distance away from people.

“27. All flight operations must be conducted at least 500 feet from all persons who are not directly participating in the operation, and from vessels, vehicles, and structures, unless when operating[.]”

Every road, person, house, car, etc. is a problem.

Restriction for Aerial Data Collection Exemptions

a. Over or near people directly participating in the operation of the UAS. People directly participating in the operation of the XXXXXX include the PIC, crewmembers, and other consenting personnel whose presence is necessary to ensure the safety of the operation.

b. Near nonparticipating persons. The XXXXXX may be operated closer than 500 ft. to a person who is not directly participating in the operation only when barriers or structures are present. Such barriers must sufficiently protect the person from the aircraft and from debris or hazardous materials from the aircraft. Under these conditions, the Operator must ensure the person remains under such protection for the duration of the operation. If a situation arises in which the person leaves such protection and is within 500 ft. of the XXXX, flight operations must cease immediately in a manner that does not cause undue hazard to any person.

c. Near vessels, vehicles, and structures. Prior to conducting operations within 500 ft. of any vessels, vehicles, or structures, the Operator must obtain permission to proceed within 500 ft. from a person with authority over such vessels, vehicles, or structures. The PIC must first assess the risk of operating closer to those objects and determine that it does not present an undue hazard.

Restriction for Agricultural Aircraft Operation Exemptions

The only exceptions to the buffer zone are to the following four:

a. Over or near people directly participating in the operation of the UAS. No person may operate the UAS directly over a human being unless that human being is directly participating in the operation of the UAS, to include the PIC, VO, and other personnel who are directly participating in the safe operation of the UA.

b. Near nonparticipating persons. Except as provided in subsection (a) of this section, a UA may only be operated closer than 500 feet to a person when barriers or structures are present that sufficiently protect that person from the UA and/or debris or hazardous materials such as fuel or chemicals in the event of an accident. Under these conditions, the operator must ensure that the person remains under such protection for the duration of the operation. If a situation arises, in which the person leaves such protection and is within 500 feet of the UA, flight operations must cease immediately in a manner that does not cause undue hazard to persons.

c. Closer than 500 feet from vessels, vehicles and structures. The UA may be operated closer than 500 feet, but not less than 100 feet, from vessels, vehicles, and structures under the following conditions:
(1) The UAS is equipped with an active geo-fence boundary, set no closer than 100 feet from applicable waterways, roadways, or structures;
(2) The PIC must have a minimum of 7 hours experience operating the specific make and model UAS authorized under this exemption, at least 3 hours of which must be acquired within the preceding 12 calendar months;
(3) The PIC must have a minimum of 25 hours experience as a PIC in dispensing agricultural materials or chemicals from a UA;
(4) The UA may not be operated at a groundspeed exceeding 15 miles per hour;
(5) The UA altitude may not exceed 20 feet AGL; and
(6) The PIC must make a safety assessment of the risk of operating closer than 500 feet from those objects and determine that it does not present an undue hazard.

d. Closer than 100 feet from vessels, vehicles and structures. The UA may operate closer than 100 feet from vessels, vehicles, and structures in accordance with the conditions listed in 27.c. (2) through (6) and the following additional conditions:
(1) The UAS is equipped with an active geo-fence boundary, set to avoid the applicable waterways, roadways, or structures; and
(2) The operator must obtain permission from a person with the legal authority over any vessels, vehicles or structures prior to conducting operations closer than 100 feet from those objects.

To fly close to the property, ya need to get permission. Now you’re knocking on doors like you’re a girl scout selling cookies. What if they are in the shower, out of town, in the barn, just don’t care, etc.? Bummer. You have to stay more than 100ft away.

One exception to this is for closed-set TV movie filming exemptions. They allow you to get close to the actors. If you want one of those, contact me. These require a special manual.

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Money Saving Tips & Things to Consider Before Purchasing a Large Drone

Tip 1. If your exemption is going to need a medical certificate, try to obtain a 3rd Class Medical Certificate BEFORE you buy.

People have medical conditions, PTSD, or medications that will disqualify them or make it really hard for them to obtain a 3rd class medical. It would be a big mistake to buy a drone to learn you have a medical condition that wouldn’t allow you to fly. We are trying to change the restrictions down to a minimum of a driver’s license, so it’s something we are working on fixing, but it isn’t something happening soon. If this is you, contact me.

Tip 2. Make sure the aircraft has been 44807ed. 

You can check if the aircraft has been determined.  Here is the list. FAA-2023-1271.   To get an aircraft determined under 44807, it can take around 37 days to -15 months.  The wait is dependent on the quality of what was put into the application. It does not make sense to pay for a drone for it to be a paperweight while you wait to get it on the list.  If that is the case, ask for a discount.  Note that the 44807s can be determined somewhat quickly if the package is put together well. We recently obtained a 44807 for a client in 37 calendar days.

Tip 3. Find out if your aircraft has remote identification.

The remote identification laws for operators require the operator to have a drone capable of broadcasting remote ID.  See 14 CFR Part 89. The issue here is some of the drone manufacturers may have some difficulty in creating a drone capable of doing this or finding a broadcast module to retrofit their aircraft.  Before purchasing a drone, find out what the manufacturer’s game plan is on remote ID.  You can see if any manufacturers have declarations of compliance for their aircraft by looking here. https://uasdoc.faa.gov/listDocs  Manufacturers may choose to not support older models. You can purchase a broadcast module (see the previous link) and retrofit your aircraft for like $100-300. The downside to retrofitting your aircraft is Part 89 limits it to visual line of sight only. If you need to fly beyond line of sight with a broadcast module, contact me. There is a way around that.

If you are flying beyond line of sight, 14 CFR 89.115 requires the drone to be standard remote ID.  That’s a big issue. Alot of drone sellers are going to hide this issue. If you are planning on flying beyond line of sight, such as under an exemption that allows this (email me if you want to do this) or under the future Part 108 regulations for beyond line of sight flying, you’ll need a standard remote ID drone.

I made a huge table here of aircraft on the FAA-2023-1271 list that have remote ID. I did my best to try and find them all.  This table is current as of 6/23/2025.

Make	Model	Remote ID?	Type?
AgrowDrone	UAS-e-M5	NO	137
AgrowDrone	UAS-e-M10	NO	137
AgTS	FireEye	NO
AiRanger	UAS	NO
Amazon	MK27	RID000000378
Amazon	MK30	RID000001843
Anduril Industries Inc	Ghost UAS	No
ASW	Heavy Lift Quadcopter	NO
ASW	Heavy Lift Hexacopter	NO
ASW	Heavy Lift Octocopter	NO
BFD Systems	GD40	NO
BROUAV	U30L-6	NO	137
BROUAV	52L-8	NO	137
BROUAV	U60	No	137
BROUAV	D-72L-8	NO	137
Chengdu JOUAV Drone	CW-30	NO
DJI	Agras T16	NO	137
DJI	Agras T20P	RID000001181	137
DJI	Agras T20	NO	137
DJI	Agras T25	RID000001594	137
DJI	Agras T30	RID000000038-1	137
DJI	Agras T40	RID000000039-1	137
DJI	Agras T50	RID000001594	137
DJI	Heavy Lift	NO	137
DJI	Storm UAS	NO	137
DMR Technologies Inc	Field Ranger X-50	Yes https://uasdoc.faa.gov/listDocs/RID000002272	137
EAVision	EA-J100	NO	137
EAVision	EA-J70 (J100 EVO)	No	137
EAVision	EA-J150	No	137
EFT	Z50	NO	137
Equinox	Falcon Heavy	NO
Event38	E500	NO
FLARES	2	NO
Flytrex	FTX-M600P*	RID000000491
Flytrex	Sky2	RID000001411
Freefly Systems	Alta X	RID000001225
Freespace	Callisto 50	NO
FulcrumAir	E7500	NO
Gaia	160-AG	NO	137
Galaxy Unmanned Systems LLC	GC35-E2	NO
Galaxy Unmanned Systems LLC	GC35-E4	NO
Galaxy Unmanned Systems LLC	GC50-E4	NO
Guardian Agriculture	MOE	NO	137
Guardian Agriculture	SC1 UAS	NO	137
Harris Aerial	Carrier H6 HL	Carrier H6 is approved.
Hermeus	Quarterhorse Mark 1	No
HSE/TTA	M6A Pro G200	NO	137
HSE/TTA	M8A Pro	NO	137
Huida Tech	HD540 Pro	? Remote ID is for “3WWDZ-U70A” https://uasdoc.faa.gov/listDocs/RID000002412	137
Hylio Inc.	AG-116/AG-216	RID000000119	137
Hylio Inc.	AG-122	NO	137
Hylio Inc.	AG-130/AG-230	RID000000120	137
Hylio Inc.	AG-172/AG-272	RID000000121	137
Hylio Inc.	AG-152/AG-252	NO	137
Hylio Inc.	H-450	NO	137
Hylio Inc.	H-600	NO	137
Hylio Inc.	HYL-150	RID000002231	137
Hylio Inc.	HYL-150 HYBRID	NO	137
Hylio Inc.	HYL-300	NO	137
Joyance	JT20L-606	NO	137
Joyance	JT30L-606	NO	137
JTI	M60Q	NO	137
L3 Harris Technologies	FVR-55	NO
L3 Harris Technologies	HQ-90/FVR-90 UAS	NO
Latitude	HQ-60	NO
Leigh Aerosystems	Athena A200	NO
Malloy Aeronautics	TRV-80	NO
Malloy Aeronautics	TRV-150	NO
Matternet	M2-sUAS	RID000000337
MFD	5000	NO
Neany	Arrow	No
Precision Vision	30 (PV-30), Model SiCX-25	NO	137
Precision Vision	35 (PV-35)	NO	137
Precision Vision	35X	NO	137
Precision Vision	40X	RID000000525	137
Precision Vision	100X	No	137
PRISM	V2*	NO
PteroDynamics	X-P4	No
Pulse Aerospace	Vapor 55	NO
Pyka Inc.	Pelican (3 Engine)	? There are 3 remote IDs for the Pelican	137
Pyka Inc.	Pelican (4 Engine)	? There are 3 remote IDs for the Pelican	137
Rigitech	Eiger	RID000001218
Rigitech	Eiger-03	? Is that the same as the Eiger?
Schiebel	CAMCOPTER S-100	NO
Shotover	S1/U1	NO
Shotover	U1 Series III	NO
Skyways	V2.50 UAS	NO
Skyways	V2.7	NO
SwissDrones	SDO 50 V2	NO
SwissDrones	SDO 50 V3	NO
Talos	T60	NO	137
Telegrid	DE2020	NO
TYI Model Technology Co.	3WTYI6-30C	NO
USI	Sandstorm	NO
V.4CS		NO
Velary	Lift 10	NO
Velary	LIFT 10 Hexa	No
Velary	LIFT 10 Quad	No
Watts Innovations	AERO Sky UA	RID000001735
Wing Aviation	Hummingbird	RID000002169 – RID000001459
Wing Aviation	Hummingbird 7000W-A	? There are 3 RIDs for the Hummingbird.
Wing Aviation	Hummingbird 7000W-B	? There are 3 RIDs for the Hummingbird.
Wing Aviation	Hummingbird 8000-A	? There are 3 RIDs for the Hummingbird.
XAG	P40	NO	137
XAG	V40	RID000000525	137
XAG	P60	NO	137
XAG	P100	RID000000162	137
XAG	P100 PRO	RID000000163	137
XAG	P100 PRO 50L	P100 has it.	137
XAG	P100 PRO 60L	P100 has it.	137
XAG	P150	RID000002240	137
Yamaha	FAZER	NO	137
Yamaha	FAZER R	NO	137
Yamaha / Drone America Inc.	FAZER SAR	NO	137
ZenaDrone	1000	NO
Zephyr	ARK-350	RID000000055

Tip 4. Consider the company.

DJI is the big gorilla in the room but it has all sorts of problems. Read this Washington Post article. Using a DJI product could be a deal breaker for certain clients who are either legally precluded from contracting with a contractor using a DJI product or the customer chooses to do it for PR or “what will my boss think?” reasons. You need to know if your end customers care about this or not.

Tip 5. Battery Compatibility.

Some of the drone sprayer batteries can be used on different platforms. This is really important as batteries can get very expensive and you want to fully utilize your batteries. You want, for the least amount of capital expenditure, the greatest amount of batteries. A lack of intercompatibility means greater overall capital costs.

Tip 6. Consider sales and use tax! Some sellers do NOT include sales tax.

This messes up the comparison of costs. You should call your state department of revenue and find out if the aircraft are taxed and to what percent. Do NOT think you can just skip this. If you register your drone with an N Number (all drones 55 pounds and heavier have to do this), you might be receiving a letter in the mail from your state department of revenue which regularly checks the publicly available database of N Numbers for new entries. Oklahoma! You’ll get a letter saying, “Hey! We noticed you have a new aircraft. Did you pay sales or use tax on it?” If you didn’t pay sales tax, you might end up having to pay state taxes then. This comes months later and is an unexpected surprise of a potentially 4 figure tax bill. If the seller doesn’t put sales tax in the quote, ask why. At this point, you should call over to your state department of revenue and ask them what they think about the seller’s statement.

Tip 7. Consider State Aircraft Taxes

Some states have taxes on aircraft. This is a seperate tax from sales and use tax. You buy the drone and then you’ll get a bill in the mail from your state asking for you to pay tax on the aircraft.

Tip 8. Shop around.

Some of the people selling drones are heavily marking up in costs. It is not uncommon to save thousands by shopping around. If a person recommends you to purchase from a specific dealer, ask them why. A lot of sellers and some consultants pay referral fees so you as a customer end up paying higher prices (as referral fees). If you are wondering about me, as an attorney, I am not permitted to receive referral fees.

Tip 9. Consider Used Aircraft.

Facebook marketplace and Facebook groups.  There are people unloading old drones. You could obtain one cheaply. Note that switching a drone over from one person to another with DJI may be a pain. The drone will be associated with the previous owner in DJI’s system so you have to deal with those extra headaches.

Some dealers also purchase used drones. You can also ask some dealers if they are willing to sell their demo drones.

Ask the dealer if they have any open box drones. Some dealers have open box drones and can sell them at a lower price because of this.

Tip 10. Only purchase one drone.

You only need one drone to get through the operating certification process. Do NOT purchase any more until you get operating. Prices come down over time.

Tip 11. Consider leasing a drone instead of purchasing one.

Some people have extra drones around. Lease one. Guys up north don’t fly in the winter. A southern operator can lease for the late fall and winter a northern drone to use.

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FAQs Surrounding 55 Pound and Heavier Drones

How long does it take to obtain an exemption from the FAA for a large drone?

This is constantly changing.  As a good rule of thumb, plan for 60-180 calendar days.

How long do the exemptions last?

24 months.

Can an exemption get more than one aircraft for it?

Yes.

For exemptions doing aerial data collection, you MUST ask for the aircraft at the beginning. If you change your mind later on, we can add more aircraft. I typically just ask for all aircraft on the FAA-2023-1271 list.

For exemption for drone spraying, you’re approved for everything on docket FAA-2023-1271. The FAA constantly keeps adding aircraft to this list. Once it is added, you are then allowed to fly it. It’s all done for you.

Am I limited to specific aircraft or just make and model?

The exemptions are for make and model. You can fly 100 aircraft of the same make and model.

Can you add aircraft to an exemption later on?

Yes.

For exemptions doing aerial data collection, you normally ask for all aircraft on the docket FAA-2023-1271. The FAA constantly keeps adding aircraft to this list. Once it is added, you are then allowed to fly it. It’s all done for you.

For exemption for drone spraying, you’re approved for everything on docket FAA-2023-1271. We can try and add an aircraft to that list. Others can add it.

What if the FAA has not approved my drone under Section 44807? How can we get it approved?

Here is the list of aircraft that have been approved under 44807. Docket FAA-2023-1271. The FAA is constantly updating it.  If you want to add another aircraft, contact me.  The process to get an aircraft determined under 44807 takes around 37 days to 15 months.

Do I have to own the aircraft to petition for exemption?

No, we can petition for the exemption without you owning the drone. For drone spraying, the FAA will require you to have at least one registered drone. You do not have to own it but could lease it or barrow it.

How much does it cost to obtain an exemption?

The FAA does not charge to process an exemption. If you choose to hire someone, then that is the only fee.

How do I register the drone? Can you help me with this?

55-pound and heavier drones are registered under Part 47. You cannot register a 55 pound and heavier drone under the Part 48 method on the FAA’s Drone Zone. 

I have helped hundreds of clients obtain N-number registrations. The process takes around 2-3 months but we recently, as of 6/23/25, obtained one in 20 calendar days.

I read the restrictions on the exemptions below. How can we change them?

The ones below are called summary grants.  This means the FAA has looked at and has already approved these conditions and limitations. The FAA can approve these petitions for exemption much faster.  If you want to change any restriction, the FAA will send it through an entire process all over again. That can take around 8-15 months to get approved.

Are there different exemptions for different operations?

Yes.

• Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.
• Closed-set TV Movie Filming.
• Evaluating, testing and demonstrating, surveying and mapping, industrial-site inspection and monitoring, cargo delivery, and other commercial services using such products.
• Agricultural Aircraft Operations
• Part 135 Package Delivery of Another’s Property for Compensation or Hire.
• Providing flight experience (AKA the flight instruction exemption).

What is the difference between aerial data collection, closed set, and the evaluating, R&D, mapping, cargo delivery exemptions?

The main difference would be that some of them allow for day and night while some are daylight ONLY.

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My Services

The services below are only for aerial data collection. Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography,
video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.

If you want an exemption for drone spraying, go to my dedicated page just on drone spraying for prices and services.

If you want any of the following,  contact me.

• Closed-set TV Movie Filming (allows you to fly close to the actors).
• Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.
• Evaluating, testing and demonstrating, surveying and mapping, industrial-site inspection and monitoring, cargo delivery, and other commercial services using such products.
• Providing flight experience.

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Exact Language of the 55 Pound and Heavier Exemption for Aerial Data Collection

General:

1. Operations authorized by this exemption are limited to XXXXX (hereafter referred to collectively as “the aircraft”) by the Operator and are limited to the operations described in the petition for exemption and the operating documents. The maximum takeoff weight (MTOW) of the XXXXX must not exceed XXXXpounds (lbs.). Proposed operations of any other unmanned aircraft system (UAS) requires a new petition or a petition to amend this decision.
2. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The Operator must follow the procedures as outlined in its operating documents. The documents listed in this grant, the applicable Federal Communications Commission (FCC) license, and a copy of this exemption must be accessible to the PIC at the ground control station during all UAS operations that occur under this exemption. They must be made available to the Administrator upon request. Where a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in any of the aforementioned documents, the most restrictive provision must be followed.
3. The Operator may update or revise its operating documents. It is the Operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The Operator must also present the most current documents if petitioning for extension of or amendment to this grant of exemption. If the Operator determines that any update or revision would affect the Operator’s ability to comply with any requirement of this exemption, then the Operator must petition for an amendment to its grant of exemption. If questions arise regarding updates or revisions to the operating documents, the Operator may contact the Flight Standards Service, Emerging Technologies Division, General Aviation & Commercial Branch (AFS-750), 800 Independence Ave. SW, Washington, DC 20591. Telephone: 202-267-1100, Email: 9-avs-fs-afs-700- [email protected]
4. All operations that occur pursuant to this exemption must be conducted in accordance with an Air Traffic Organization (ATO)-issued Certificate of Waiver or Authorization (COA). A copy of the blanket 49 U.S.C. § 44807 COA is enclosed with this exemption. The Operator must apply for a new or amended COA if it intends to conduct operations that the terms of the COA do not permit. If a conflict between the COA and this condition exists, the more restrictive provision will apply. In the absence of any express altitude restrictions in a COA or any other document the FAA provides that applies to operations under this exemption, the maximum altitude shall be 400 feet (ft.) above ground level (AGL). Altitude must be reported in feet AGL. UAS maintenance:
5. The Operator must follow the original equipment manufacturers (OEM) operating limitations, maintenance, service bulletins, overhaul, replacement, inspection, and life limit requirements for the UAS and its components as well as operator supplemental manuals. Each UAS operated under this exemption must comply with all OEM service bulletins.
6. Maintenance must be performed by qualified individuals who have been trained by the manufacturer in proper techniques and procedures for these UAS and all maintenance must be recorded in the aircraft records including a brief description of the work performed, date of completion and the name of the person performing the work.
7. Any maintenance or alterations that affect the UAS operation or flight characteristics, such as replacement of a flight critical component, must undergo a functional operational check test flight prior to conducting further operations under this exemption. Functional operational check flights must be conducted in visual line of sight (VLOS) by a pilot-in-command (PIC) and other personnel required to conduct the functional operational check test (such as a mechanic or technician) and must remain at least 500 feet from all other people. The functional operational check flight must be conducted in such a manner to not pose an undue hazard to persons and property. The Operator must permit the FAA Administrator and his representative to observe functional test flights upon the request.

Crew Qualifications:

8. The PIC must hold a valid remote pilot certificate with a small UAS rating issued under Part 107 and be in compliance with 14 CFR § 107.65, Aeronautical knowledge recency.
9. Knowledge Test Requirements. Each PIC operating under the provisions of this exemption must have passed within the previous 24 calendar months either a sport, recreational, or private pilot FAA airman knowledge test before acting as PIC. This requirement does not apply to a PIC who holds any Part 61 pilot certificate (other than a student pilot certificate) and meets the flight review requirements of 14 CFR § 61.56.
10. The PIC must hold at least a current FAA third-class airman medical certificate. The PIC may not conduct the operation if the PIC knows or has reason to know of any medical condition that would make the pilot unable to meet the requirements for at least a third-class medical certificate or is taking medicine or receiving treatment for a medical condition that results in the pilot being unable to meet the requirements for at least a third-class medical certificate.
11. The PIC and visual observers (VO) must be qualified in accordance with the Operator’s training program. The PIC and VO must remain current and qualified before conducting operations under this exemption.
12. All training operations must be conducted only during dedicated training sessions for the petitioner’s employees and must be conducted in accordance with the operating training program described in operator’s training program.
13. The Operator must ensure that the PIC can satisfactorily make evasive and emergency maneuvers and maintain appropriate distances from persons, vessels, vehicles and structures before operating non-training, proficiency, or experience-building flights under this exemption.
14. The VO or any other direct participant may not participate in the operation if they know or has reason to know of any physical or mental condition that would interfere with the safe operation of the aircraft.
15. VOs must have adequate visual abilities to be able to see the unmanned aircraft (UA) clearly, recognize terrain, obstructions, see and avoid aerial or ground hazards and other aircraft without undue hesitation. The VOs must be able to establish and maintain by unaided vision, except vision that is corrected by the use of corrective lenses to maintain a normal field of vision allowing them to see all potential hazards without hesitation.

Operational:

16. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the aircraft is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, such as inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed, and the aircraft is found to be in a condition for safe flight.
17. The PIC is prohibited from beginning a flight unless, considering wind and forecast weather conditions, there is enough available power for the UA to conduct the intended operation with sufficient reserves such that the PIC can land the UA without posing an undue risk to aircraft or people and property on the ground, or the reserve power recommended by the manufacturer, if greater, is satisfied.
18. The UA must remain within the VLOS of the PIC. VLOS means the PIC must be able to, with natural unaided vision except for corrective lenses, see the UA and determine its orientation, height above the surface, and direction of flight. The UA must be conspicuous so as to be obvious within the VLOS area. The PIC may use VOs as an operational mitigation; however, the PIC must be able to see the UA throughout the flight. The PIC retains the overall responsibility to see-and-avoid other aircraft.
19. All operations must utilize the services of at least one or more VOs. The UA must be operated within the VLOS of the PIC and VO at all times. If either the PIC or a VO is unable to maintain VLOS with the UA during flight, the entire flight operation must be terminated as soon as practicable. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability.
20. The VO and PIC must be able to communicate verbally at all times. The PIC must ensure that the VO can perform the duties required of the VO. For purposes of this condition, a VO is someone: (1) who maintains effective communication with the PIC at all times; (2) who the PIC ensures is able to see the UA with human vision unaided by any device other than corrective lenses; and (3) coordinates with the PIC to scan the airspace where the UA is operating for any potential collision hazard and maintain awareness of the position of the UA through direct visual observation. The operation must be conducted with a dedicated VO who has no collateral duties and is not the PIC during the flight.
21. The PIC must be designated before the flight and cannot transfer their designation for the duration of the flight. In all situations, the PIC is responsible for the safety of the operation. The PIC is also responsible for meeting all applicable conditions and limitations as prescribed in this exemption and ATO-issued COA, when conducting operations, and operating in accordance with the operating documents.
22. All crew, including the PIC and VOs, must maintain two-way voice communications with each other during operations. If unable to maintain two-way voice communication, the PIC will land the UA in a safe location as soon as the PIC determines it is practicable to do so. If communication occurs by electronic device: the device must be continuous full-duplex; the PIC must be able to use the device hands-free; and the PIC must ensure that there is a reliable back-up communication method. Electronic messaging or texting is not permitted during flight operations. During operations, no person on whom the PIC relies for safe conduct of the operation may engage in communications not relevant to the operation.
23. Each UA must be controlled by only a single ground control station and one PIC at a time. A PIC may not operate multiple UA at the same time.
24. All operations must be conducted under visual meteorological conditions (VMC).
25. The PIC must obtain and use real-time weather information as described in the operating documents.
26. Each operation may only occur when weather in the area of the operation is reported and forecast to be at least 1,000-foot ceiling and 3 statute mile visibility within 1 hour before and 1 hour after takeoff and landing.
27. The UA must remain 500 ft. below and more than 2,000 ft. horizontally from a cloud.
28. The PIC must land the aircraft as soon as possible if the PIC is unable to comply with the required visibility and cloud clearance requirements.
29. Operations under this exemption may not be conducted during night, as defined in 14 CFR § 1.1.
30. All flight operations must be conducted at least 500 ft. from all persons who are not directly participating in the operation, and from vessels, vehicles, and structures, unless when operating:
31. Over or near people directly participating in the operation of the UAS. People directly participating in the operation of the XXXXXX include the PIC, crewmembers, and other consenting personnel whose presence is necessary to ensure the safety of the operation.
32. Near nonparticipating persons. The XXXXXXX may be operated closer than 500 ft. to a person who is not directly participating in the operation only when barriers or structures are present. Such barriers must sufficiently protect the person from the aircraft and from debris or hazardous materials from the aircraft. Under these conditions, the Operator must ensure the person remains under such protection for the duration of the operation. If a situation arises in which the person leaves such protection and is within 500 ft. of the XXXXXX, flight operations must cease immediately in a manner that does not cause undue hazard to any person.
33. Near vessels, vehicles and structures. Prior to conducting operations within 500 ft. of any vessels, vehicles, or structures, the Operator must obtain permission to proceed within 500 ft. from a person with authority over such vessels, vehicles or structures. The PIC must first assess the risk of operating closer to those objects and determine that it does not present an undue hazard.
34. The UA must remain clear and give way to all manned aviation operations and activities at all times.
35. Operations under this exemption may not occur from any moving vehicle or aircraft.
36. The PIC may not begin or continue a flight if any global positioning system (GPS) outage, signal fault, integrity issue, Notice to Air Mission (NOTAM) in effect for any part of the planned operational area, or any other condition affects the functionality or validity of the GPS signal.
37. The PIC must abort the flight operation if circumstances or emergencies arise that could degrade the safety of persons or property. In such cases, the PIC’s termination of flight operations must not cause undue hazard to persons or property.
38. Accidents or other reportable incidents described in 49 CFR Part 830 must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.
39. The carriage of property for compensation or hire is strictly prohibited.
40. This exemption is not valid for operations outside of the United States.

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Exact Language of the 55 Pound and Heavier Exemption for Drone Spraying

1. This exemption is non-transferrable. Only XXXXX may conduct operations in accordance with this exemption.

2. The Operator must obtain an agricultural aircraft operator certificate under Part 137 by submitting FAA Form 8710-3 (copy enclosed) and the Operator’s exemption number to [email protected]. Please note, the name of person or entity on the 8710-3 application must match the Exemption Holder’s name.

3. Prior to operations under 14 CFR Part 137, the Operator may conduct training flights, proficiency flights, experience-building flights, and maintenance functional test flights under this exemption with the understanding that the Operator is conducting these flights for the purpose of obtaining a Part 137 agricultural aircraft operator certificate.

4. Operations authorized by this grant of exemption include any unmanned aircraft system (UAS), along with the approved maximum take-off weight (MTOW) weight, which includes payload, for the respective UAS identified on the List of Approved Agricultural UAS under Section 44807 at regulatory docket FAA-2023-1271 at www.regulations.gov, when weighing 55 pounds (lbs.) or greater including payload. Proposed operations of any aircraft not on the list, or at different weights than currently approved, will require a new petition or a petition to amend this exemption.

5. This exemption does not excuse the Operator from complying with 14 CFR Part 375. If operations under this exemption involve the use of foreign civil aircraft, the Operator must obtain a Foreign Aircraft Permit pursuant to 14 CFR § 375.41 before conducting any operations under this exemption. Application instructions are specified in 14 CFR § 375.43.

6. The unmanned aircraft (UA) may not be operated at a groundspeed exceeding 30 miles per hour or at a speed greater than the maximum operating speed recommended by the aircraft manufacturer, whichever is lower.

7. All operations must be conducted in accordance with an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA). A copy of the blanket 49 U.S.C. § 44807 COA is enclosed with this exemption. The Exemption Holder must apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the enclosed COA. If a conflict exists between the COA and this condition, the more restrictive provision will apply. The COA will also require the Operator to request a Notice to Air Missions (NOTAM) not more than 72 hours in advance, but not less than 24 hours prior to each operation. Unless the COA or other subsequently issued FAA authorization specifies an altitude restriction lower than 200 feet above ground level (AGL), operations under this exemption may not exceed 200 feet AGL. Altitude must be reported in feet AGL.

8. The pilot in command (PIC) must be designated before the flight and cannot transfer their designation for the duration of the flight. In all situations, the Operator and the PIC are responsible for the safety of the operation. The Operator must ensure the PIC follows all applicable conditions and limitations as prescribed in this exemption and ATO-issued COA and operating in accordance with the operating documents as defined in the conditions and limitations in this exemption. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. If the PIC is unable to maintain VLOS with the UA during flight, (including if caused by the inadvertent loss of night vision) the entire flight operation must be terminated as soon as practicable. The PIC must be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

9. The PIC may manipulate flight controls in the operation of no more than three UA at the same time. Proposed operation of more than three UA at the same time (by one PIC) requires a new petition or a petition to amend this exemption.

10. Unless otherwise authorized by the Administrator, the Ground Control Station (GCS) and software must be designed for, and compatible with, the UAS to be operated. The GCS must clearly display and identify each UAS being operated by the PIC.

11. Operations of multiple UAS by a single PIC must be automated and have a back-up remote control for each UAS being operated. The autopilot system must maintain UAS separation without input from the PIC.

12. All operations may optionally utilize the services of at least one or more visual observers (VO). If utilized, the VO must be trained in accordance with the Operator’s training program. For purposes of this condition, a VO is someone: (1) who maintains effective communication with the PIC at all times; (2) who the PIC ensures is able to see the UA with human vision as described in Condition and Limitation No. 8; and (3) coordinates with the PIC to scan the airspace where the UA is operating for any potential collision hazard and maintain awareness of the position of the UA through direct visual observation. The UA must be operated within VLOS of both the PIC and VO (if used) at all times. The VO (if used) must have no collateral duties and is not the PIC during the flight. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO (if used) and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The VO (if used) must maintain visual sight of the aircraft at all times during flight operations without distraction. The PIC must ensure that the VO can perform the duties required of the VO. If either the PIC or a VO (if used) is unable to maintain VLOS with the UA during flight, (including if caused by the inadvertent loss of night vision) the entire flight operation must be terminated as soon as practicable.

13. If a VO is not utilized, the PIC must maintain VLOS with the UA during the entire flight operation. Additional support personnel may be used to conduct UA inspections, and servicing, such as changing batteries and refilling or exchanging hoppers. Additional support personnel are not considered to be performing the function of a VO; however, their use is encouraged to ensure the PIC is not distracted with non-essential duties during flight.

14. All documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. At a minimum, the operating documents must include:
a. The Operator’s operations manual;
b. The Operator’s training program;
c. The manufacturer’s provided flight manual;
d. All other manufacturer UAS provided documents;
e. This exemption; and
f. Any ATO-issued COA that applies to operations under this exemption.
These operating documents must be accessible during all UAS operations that occur under
this exemption and made available to the Administrator or any law enforcement official
upon request. If a discrepancy exists between the conditions and limitations in this
exemption and the procedures outlined in the operating documents, the conditions and
limitations herein take precedence and must be followed. Otherwise, the Operator must
follow the procedures as outlined in its operating documents.

15. The Operator must have and keep current a comprehensive operations Manual that is tailored for their proposed operation and contain, at a minimum:
a. Operations policies, methods, and procedures that address Safety Risk Management (SRM);
b. Adverse weather;
c. Flight planning;
d. NOTAM;
e. Aircraft inspection;
f. Preflight duties and post-flight duties;
g. Normal and emergency flight procedures;
h. Crew Resource Management (CRM) and communications,
i. Crewmember responsibilities;
j. Accident reporting;
k. Hazardous material (HAZMAT) handling and stowage;
l. UAS maintenance;
m. Operation at Night (if operating at night);
n. Multi-UAS Operation (if operating multi-UAS);
o. Multi-UAS Operation at Night (if operating multi-UAS at Night); and
p. Operation without a VO (if operating without a VO).

16. The Operator must have and keep current a comprehensive crewmember training program that is tailored for their proposed operation and contain, at a minimum:
a. Knowledge requirements of 14 CFR § 137.19(e)(1),
b. Initial and recurrent training;
c. Testing;
d. Completion standards;
e. Ground training;
f. Site surveying;
g. Flight training;
h. Normal and emergency procedures;
i. UAS operating limitations;
j. Lost-link procedures;
k. Multi-UAS;
l. Any ATO-issued COA that applies to operations under this exemption;
m. HAZMAT handling and stowage;
n. Operation at Night (if operating at night), the Training Program must include:
o Elements to ensure crewmembers are personally prepared for night operation, with a focus on eyesight preparation and fatigue;
o Emphasis on the preparation of the ground station and landing location, ensuring it is as well-lit as possible, without hindering the PIC’s night vision; and
o Satisfactory functional checks of the aircraft lights.
o. Multi-UAS Operation (if operating Multi-UAS), the Training Program must include:
o Satisfactory pre-flight inspection of the GCS and operating area to ensure that three UAS can operate and land safely.
p. Multi-UAS Operation at Night (if operating multi-UAS at night), the Training Program must include:
o Satisfactory pre-flight inspection of the GCS and operating area to ensure that three UAS can operate and land safely; and
o Satisfactory pre-flight checks to ensure the aircraft identification lights distinguish each UAS individually.
q. Operation without a VO (if operating without a VO), the Training Program must include:
o All roles and responsibilities of the VO to be assumed and conducted by the PIC.

17. Any aircraft that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g., replacement of a flight-critical component) must undergo a
functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO (if used) and other
personnel required to conduct the functional flight test (such as a mechanic or technician) and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

18. The Operator is responsible for maintaining and inspecting all aircraft to be used in the operation and ensuring that they are all in a condition for safe operation.

19. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the aircraft is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, such as inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed, and the aircraft is found to be in a condition for safe flight.

20. The Operator must follow the UAS manufacturer’s operating limitations, maintenance instructions, service bulletins, overhaul, replacement, inspection, and life-limit requirements for the UAS and UAS components. Each UAS operated under this exemption must comply with all manufacturers’ safety bulletins. Maintenance must be performed by individuals who have been trained by the Operator in proper techniques and procedures for these UAS. All maintenance must be recorded in the UAS records including a brief description of the work performed, date of completion, and the name of the person performing the work.

21. A PIC must hold a current remote pilot certificate with a small UAS rating issued under Part 107. The PIC must meet the requirements of Section 107.65, Aeronautical knowledge recency.

22. For night operations, the PIC must not have any night operating limitations on their FAAissued airman medical certificate, nor any medical condition which interferes with night vision and must be able to perceive those colors necessary to correctly distinguish the UA’s position and orientation at night.

23. The PIC must also hold at least a current FAA third-class airman medical certificate. The PIC may not conduct the operation if the PIC knows or has reason to know of any medical condition that would make the PIC unable to meet the requirements for at least a thirdclass medical airman medical certificate or is taking medication or receiving treatment for
a medical condition that results in the PIC being unable to meet the requirements for at least a third-class medical certificate. A VO (if used) or any other direct participant may not participate in the operation if they know or have reason to know of any physical or mental condition that would interfere with the safe operation of the UAS.

24. The PIC must satisfactorily complete the Operator’s training program requirements, as described in the training manual; and satisfactorily complete the applicable knowledge and skills requirements for agricultural aircraft operations outlined in Part 137, with the exception of Sections 137.19(e)(2)(ii), 137.19(e)(2)(iii), and 137.19(e)(2)(v), which are not required for the purposes of meeting this condition. The operator or chief supervisor’s knowledge and skill tests of 14 CFR § 137.19(e) may be self-administered. Documentation of satisfactory completion of both the training program and the knowledge and skill tests of Section 137.19(e) must include the date of the test, as well as the PIC’s name, FAA pilot certificate number, and legal signature. This documentation must be provided to the FAA upon request.

25. PIC qualification flight hours and currency may be logged in a manner consistent with 14 CFR § 61.51(b). However, time logged for UAS operations may not be recorded in the same columns or categories as time accrued during manned flight, and UAS flight time does not count toward total flight time required for any Part 61 requirement.

26. When operating without a VO, the PIC will remain at the ground station at all times while any UAS is in the air. The PIC will not leave the ground station to load or service a UAS on the ground while any UAS is in the air. When operating without a VO, the PIC must land all three UAS before proceeding to load or service.

27. All training operations must be conducted during dedicated training sessions in accordance with the Operator’s training program. The Operator may conduct training operations only for the Operator’s employees. Furthermore, the PIC must operate the UA not closer than 500 feet to any nonparticipating person while conducting training operations. Training, individually and combined, is required for night, multiple UAS by a single PIC, and operations without a VO.

28. The VO (if used) must not have any medical condition which interferes with night vision and must be able to perceive those colors necessary to correctly distinguish the UA’s position and orientation at night.

29. For night operations, the VO (if used) must have completed the night training portion of the Operator’s training program requirements, the completion of which must be documented.

30. UAS operations may be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Operations may not be conducted under special visual flight rules (SVFR). Night operations require anti-collision lighting that is visible for 3 statute miles and has a flash rate sufficient to avoid a collision as is consistent with 14 CFR § 107.29(b). The aircraft must also be equipped with continuously illuminated identification lighting.
a. For multi-UAS operation at night, the UAS must incorporate position lights configured to match each UAS’s color displayed in the ground station software.

31. For night operations, the area of operation must be sufficiently illuminated to allow both the remote PIC and VO (if used) to identify people or obstacles on the ground, or the PIC must have inspected the operating area in person during daylight hours in order to assess all potential hazards and develop a plan to avoid these hazards.

32. For night operations, the PIC must verify all aircraft lights are fully functional prior to each operation. Should the lighting system become inoperative, the night operation must cease immediately.

33. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

34. For UAS operations where a global navigation satellite system (GNSS) signal is necessary to safely operate the aircraft, the PIC must immediately recover or land the UA upon loss of GNSS signal.

35. An individual system failure must not interfere with the operation of other UAS or cause incidents, accidents, or loss of control involving UAS that are the subject of this exemption.

36. If the PIC loses command or control link, the UA must follow a pre-determined route to either reestablish link or immediately recover or land.

37. The UAS must be equipped with a flight termination system. Prior to operations subject to this exemption, the flight termination system must be tested and verified to operate as described in the operating documents.

38. The PIC must abort the flight operation if unexpected circumstances or emergencies arise that could degrade the safety of persons or property. The PIC must terminate flight operations without causing undue hazard to persons or property in the air or on the surface.

39. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for each aircraft involved in the operation to conduct the intended operation with sufficient reserve such that in the event of an emergency, the PIC can land the aircraft in a known area without posing an undue risk to aircraft or people and property on the surface. In the alternative, if the manufacturer’s manual, specifications, or other documents that apply to the operation of the UAS recommend a specific volume of reserve power, the PIC must adhere to the manufacturer’s recommendation, as long as it allows the aircraft to conduct the operation with sufficient reserve and maintain power to land the aircraft in a known area without presenting undue risks, should an emergency arise.

40. Documents used by the Operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9, 91.203, and 137.33 must be available to the PIC at the GCS of the UAS any time any UA operates in accordance with this exemption. These documents must be made available to the Administrator or any law enforcement official upon request.

41. The UA must remain clear and give way to all manned aviation operations and activities at all times.

42. The UAS may not be operated by the PIC from any moving device or vehicle.

43. All flight operations must be conducted at least 500 feet from all persons who are not directly participating in the operation, and from vessels, vehicles, and structures, unless when operating:
a. Over or near people directly participating in the operation of the UAS. No person may operate the UAS directly over a human being unless that human being is directly participating in the operation of the UAS, to include the PIC, VO (if used) and other personnel who are directly participating in the safe operation of the UA.
b. Near nonparticipating persons. Except as provided in subsection (a) of this section, a UA may only be operated closer than 500 feet to a person when barriers or structures are present that sufficiently protect that person from the UA and/or debris or hazardous materials such as fuel or chemicals in the event of an accident. Under these conditions, the Operator must ensure that the person remains under such protection for the duration of the operation. If a situation arises, in which the person leaves such protection and is within 500 feet of the UA, flight operations must cease immediately in a manner that does not cause undue hazard to persons.
c. Closer than 500 feet to vessels, vehicles and structures. The UA may be operated closer than 500 feet, but not less than 100 feet, from vessels, vehicles, and structures under the following conditions:
(1) The UAS is equipped with an active geo-fence boundary, set no closer than 100 feet to applicable waterways, roadways, or structures;
(2) The PIC must have a minimum of 7 hours’ experience operating the specific make and model UAS authorized under this exemption, at least 3 hours of which must be acquired within the preceding 12 calendar months;
(3) The PIC must have a minimum of 25 hours’ experience as a PIC in dispensing agricultural materials or chemicals from a UA;
(4) The UA may not be operated at a groundspeed exceeding 15 miles per hour;
(5) The UA altitude may not exceed 20 feet AGL; and
(6) The PIC must make a safety assessment of the risk of operating closer than 500 feet from those objects and determine that it does not present an undue hazard.
d. Closer than 100 feet from vessels, vehicles and structures. The UA may operate closer than 100 feet from vessels, vehicles, and structures in accordance with the conditions listed in 43.c. (2) through (6) and the following additional conditions:
(1) The UAS is equipped with an active geo-fence boundary, set to avoid the applicable waterways, roadways, or structures; and
(2) The Operator must obtain permission from a person with the legal authority over any vessels, vehicles or structures prior to conducting operations closer than 100 feet from those objects.

44. The PIC or a VO must be able to determine the aircraft’s altitude, attitude, and direction of flight at all times at the GCS or have an attitude threshold limit alert that must be operable prior to night flight operations.

45. All operations shall be conducted from and over predetermined, uninhabited, segregated, private or controlled-access property as described in the Operator’s Flight Operations Procedures Manual. The PIC must ensure the entire operational area will be controlled38 to reduce risk to persons and property on the ground, as well as other users of the National Airspace System (NAS). This area of operation will include a defined lateral and vertical area where the aircraft will operate and must be geo-fenced to prevent any lateral and vertical excursions by the operating aircraft. Safety procedures must be established for persons, property and applicable airspace within the area of operation. A briefing must be conducted regarding the planned UAS operations prior to operation at each location of operation in which the Operator has not previously conducted agricultural aircraft operations. All personnel who will be performing duties within the boundaries of the area of operation must be present for this briefing. Additionally, all operations conducted under this exemption may only occur in areas of operation that have been physically examined by the Operator prior to conducting agricultural aircraft operations and in accordance with the associated COA.

46. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported within 24 hours as required by the applicable COA issued by the FAA ATO. Additionally, any incident or accident that occurs, or any flight operation that transgresses the lateral or vertical boundaries of the operational work area, must be reported to 137 UAS Operations Office at [email protected].