So You Want to Fly a Drone

As unmanned aerial vehicle (UAV) or RPAS (Remotely Piloted Aircraft Systems) capabilities improve and costs come down, having a drone on the farm is becoming more appealing. In addition to useful imaging and remote sensing capabilities that can help with crop management, drones can allow mid or late season pesticide applications or cover crop broadcasting without wheel track damage. They are also more maneuverable than airplane or even helicopters, especially for small, irregularly shaped fields.

Before you make the leap and buy a drone, make sure you consider current Federal and Pennsylvania regulations around UAV flight and pesticide applications.

Federal Aviation Administration Rules

Drones weighing under 55lbs at takeoff are regulated under 14 CFR part 107. Each drone pilot must have a current part 107 remote pilot certificate. First-time pilots must be at least 16 years old, be able to read, speak, write, and understand English, be in physical and mental condition to safely fly a drone, and pass an aeronautical knowledge exam. The required steps for prospective pilots to register with the FAA, register for the knowledge exam, and complete the application for the certificate are outlined in detail in the FAA website. Existing part 61 certificate holders can also get the part 107 certificate following the completion of an online training course. Once the certificate is obtained, it must be easily accessible by the remote pilot during all drone operations. Maintaining the certificate involves continued training courses to keep their aviation knowledge up to date. At the time of publication, an online course is required to be completed by all pilots within 24 calendar months to maintain their remote pilot certificate.

Next, each drone must be registered with the FAA. Register your drone under part 107. Registration costs $5 and is valid for three years. You will need to provide basic contact information, the make and model of your drone, and starting in September 2023, the specific remote ID serial number provided by the manufacturer. Make sure your drone is labeled according to FAA guidelines.

In addition to the pilot licensing and drone registration requirements, waivers and certifications may be required to complete specific drone operations. These waivers and permissions vary widely, including operations that take place in certain regulated airspaces, operations taking place at night, and many others. One of the most significant exemptions required for agricultural drone operators is dispensing chemicals and agricultural products with UAS, regulated under 14 CFR part 137.

Drone spraying a breakout of foxtail in soybeans late in the growing season to control the weeds without wheel track damage. Credit: Leon Ressler, Penn State Extension

Part 137 – Agricultural aircraft operations

14 CFR Part 137 importantly defines agricultural aircraft operation as the operation of an aircraft for the purpose of dispensing substances that act as a pesticide, plant regulator, or defoliant, or those intended for plant nourishment, soil treatment, propagation of plant life, or pest control, or otherwise engaging in other dispensing activities affecting agriculture, horticulture, or forest preservation, except the dispensing of live insects.

Agricultural aircraft operations require that exemptions be requested depending on the specific nature of the operation. The FAA supplies the following guidance for part 107 drone pilots based on the weight of the drone:

• Drones weighing less than 55 pounds at takeoff, including the weight of the substance being dispensed, are operated under 14 CFR part 107 and require exemption from §107.36 Carriage of hazardous material as well as several part 137 regulations.
• Drones weighing 55 pounds or more are operated under 14 CFR part 91 rather than the aforementioned part 107, and require exemption from several 14 CFR part 61, 91, and 137 regulations.

For information on how to petition for exemption, see part 11.63 and Part 11.71.

View examples of exemptions for drones conducting agricultural operations.

Pennsylvania Department of Agriculture Rules

In addition to the FAA, the Pennsylvania Department of Agriculture also requires licensing of pesticide applicators. Drone applications are considered aerial applications according to PDA; there is not a separate licensing category. If you plan to apply pesticides by drone, you need category 25 in addition to your core license. Beyond this licensing requirement, applicators must check each pesticide label for application restrictions or guidance and must follow the label—the label is the law. Study materials for the category 25 license can be found on the Penn State Extension's website.

Environmental Protection Agency Rules

EPA has yet to address drone applications specifically and have mostly left regulation up to states to individually address it. As drone pesticide applications become more popular, EPA will likely offer standardized guidance, but this is not yet the case. Currently, products permitted for aerial application under the "Directions for Use" heading, are also permitted for drone applications. This allowance is subject to change at any time.  

Notes on spraying

Remote pesticide application system (drone for spraying) calibration differs from ground application, as there is not a consistent swath width set by the boom width and nozzle spacing. Therefore, special attention must be paid to measuring the swath width, to make sure that overlap is correct and there are no skips or over-application. One method for determining swath width is provided on the Farming for Tomorrow website.

Limitations

The main limitation with drones for ag product applications is the small payload compared to manned aircraft or ground vehicles. Keep in mind, since drone payloads are rather small (i.e., <5 gallons), the minimum spray volume dictated on the label may still be too large for practical utility of some units, even though that pesticide may be allowed to be aerially applied. For example, the Roundup PowerMax3 label allows aerial applications, but the minimum spray volume is 3 gallons/acre. Make sure to follow product label guidelines when making drone applications.

Finally, the economics of drone ownership and applications are still up in the air, and we advise careful consideration of the licensing requirements and maintenance and insurance cost of the UAV before purchasing a unit.