If you want to spray next spring with a drone, the paperwork clock starts now. The FAA's own rule for exemption petitions is simple: send it at least 120 days before you need the exemption to take effect. That is the only official timeline number you should plan around. Everything else depends on how complete your package is and how busy the FAA is.

What Part 137 is

14 CFR Part 137 is the FAA rule for agricultural aircraft operations — dispensing an economic poison (pesticide or similar), plant nourishment, soil treatment, pest control, or related work that directly affects agriculture, horticulture, or forest preservation. The FAA's dispensing chemicals page confirms that includes drones.

To do that work legally you generally need the right pilot credentials, an exemption for the Part 137 and related rules a drone cannot meet as written, an Agricultural Aircraft Operator Certificate (AAOC, the Part 137 operating certificate), aircraft registration, and — for many heavy spray drones — a 44807 path (FAA permission to fly certain drones over 55 lb) plus airspace authorization (COA). Your state pesticide applicator license is separate from the FAA.

For the bigger picture, see FAA compliance for drone custom applicators and state license department contacts.

The only timeline the FAA publishes: 120 days

Under 14 CFR 11.63(d), you must submit a petition for exemption 120 days before you need it to take effect (or 120 days before your current exemption expires). The FAA repeats that on its Part 137 UAS page and petition for exemption page.

Want a mid-March start? Count back at least 120 days — mid-November. Want room for a Request for Information (RFI, the FAA asking for missing details)? Start earlier. The 120-day rule is a filing deadline, not a guaranteed approval date. The FAA does not publish a fixed number of days for finishing a Part 137 UAS exemption or issuing the AAOC after Form 8710-3. Incomplete petitions can be delayed or closed.

The current UAS path

The FAA streamlines routine visual-line-of-sight (VLOS, keeping the drone in sight) agricultural UAS work within the altitude and airspeed limits in the exemption.

1. Register the aircraft. Under 55 lb including the load: FAADroneZone and Part 107 with the needed exemptions. 55 lb or more: an N-number under Part 47. A loaded DJI Agras T100 is over 55 lb — see our N-number guide.

2. Petition for exemption (and 44807 when needed). File on regulations.gov via the shell docket the FAA points to (currently FAA-2007-0001-0001), or by paper to Docket Operations. Cover 14 CFR 11.81: who you are, which rules need relief, public interest, and equivalent level of safety. For drones over 55 lb, follow the 44807 guidance and include, as relevant, concept of operations, manuals, checklists, training, flight history, and a safety risk analysis. Keep the docket confirmation. Decision email comes from 9-ASE-ARM320-Exemptions@faa.gov.

3. Include basic operational information up front. Leave it out and expect an RFI. From the FAA page (updated October 28, 2026): legal name and street address (no P.O. Box); Chief Supervisor of Operations contact; pilot in command (PIC) name and certificate number; each aircraft's make, model, FA- or N-number, and owner; and for extension/amendment requests only, your AAOC number.

4. Get the exemption number, then apply for the AAOC. Finish the exemption first. Then email FAA Form 8710-3 with your exemption number to UAS137Certificates@faa.gov. The name on the form must match the exemption holder. You no longer send this UAS package to a local Flight Standards District Office (FSDO). AFS-760 handles UAS-only Part 137 certificates under Notice N 8900.741 and successor Notice N 8900.773. Under that policy, the 14 CFR 137.19(e) knowledge and skill tests may be self-administered for UAS ag operations — document them and be ready to show the FAA. That does not replace the PIC rules in 137.41(c).

5. Airspace authorization (COA). For 44807 operations, apply through CAPS. The FAA may issue a "blanket" COA for flights at or below 400 feet in Class G for qualifying operators. Petition name, exemption number, and registration have to match.

Why winter is the time

Spring does not wait for a slow inbox. Between the 120-day filing rule, possible RFIs, AAOC issuance, state exams, insurance, and getting the drone ready, winter is when the timeline still works.

1. Confirm pilot certificate status (and a third-class medical when your exemption requires it).
2. Register the aircraft the right way for its weight.
3. Build the exemption package with the operational info above. Do not wait for the FAA to chase you.
4. File early enough that 120 days lands before your first spray week, with margin.
5. After the exemption grant, send Form 8710-3 promptly.
6. Schedule state licensing in parallel.
7. Watch your email. Missed RFIs stall packages. Already filed? See getting a status update on your FAA 137 and heavy-drone exemption.

Docs checklist

Before you file: legal name and physical address; Chief Supervisor contact; PIC name and certificate number; aircraft make/model, registration, owner; 14 CFR sections needing relief; public-interest and equivalent-level-of-safety narrative; Federal Register summary; supporting manuals/checklists as needed; flight history and safety risk analysis for 44807 or complex ops.

After the grant: Form 8710-3 matching the exemption holder; email to UAS137Certificates@faa.gov; 137.19(e) documentation on file; COA in CAPS when required; state applicator license; insurance and spray records ready before the first paid acre.

What we will not guess

The FAA does not publish a guaranteed number of weeks for exemption review or AAOC issuance. Third-party blogs quote ranges; those are not official. Plan from the 120-day filing rule, assume RFIs can add time, and file a complete package the first time. Requests outside routine VLOS ag work, or aircraft without prior 44807 approval, can take longer — the FAA says so on the dispensing page.

Ready to start the paperwork?

If you would rather not build the petition yourself, our FAA Part 137 Package covers the Part 137 and exemption paperwork. For questions about a T100 or setting up for spring, call 1-877-992-8279 (M–F 9–5 MT) or email sales@avarydrone.com. More in Start your own spray drone business.

This article is general information, not legal advice. Always check current FAA rules, your exemption conditions, and state pesticide requirements.