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⚖ Operations · Part 137; FAA Advisory Circular 137-1BOPS-049 · 218 of 261

A farmer hires a remote pilot to spray a 40-acre soybean field with pesticide using an agricultural drone. The pilot holds a current Part 107 certificate. What is the correct regulatory pathway for this operation?

APart 107 alone is sufficient because the operation is commercial drone work under 55 pounds
BA Part 137 certificate is required in addition to the Part 107 certificate
CA one-time § 107.200 waiver covers the spraying operation

Why →Agricultural aircraft operations that dispense chemicals, fertilizers, or seed are governed by 14 CFR Part 137. Part 107 does not authorize dispensing operations. A Part 137 operating certificate is required, issued by the local FSDO, and comes with its own knowledge test, operating rules, and recordkeeping. A § 107.200 waiver cannot substitute for Part 137 certification because spraying is outside Part 107's scope entirely.

The trap →Part 107 is broad enough for most commercial drone work, which leads pilots to assume it covers everything commercial. Spraying and dispensing sit in a separate regulatory category that pre-dates Part 107 and was not absorbed by it.

Field note →Part 137 drone operations also commonly require an exemption under 14 CFR § 11.81 because many ag drones exceed 55 pounds. Plan on a multi-month certification path before accepting ag spray work.

SOURCE → 14 CFR Part 137; FAA Advisory Circular 137-1BCHECKED JUL 16ACS I.A.K1MED