UAV to Spray Pesticide

UAVs to Spray Pesticide on Crops

UAV spraying is effective tool for applying pesticides on crops. UAVs especially shine when fields are flooded with water, making entry of motorized vehicle to the field impractical or when treating crops that grow in steep hills.

UAV pesticide spraying is becoming increasingly available for specialty crops and row-crop production. Recently, UAV manufacturers such as DJI have started offering high payload rotor UAVs that include sprayers.

Spraying with UAVs is a unique practice since it is conducted autonomously. UAV sprayers are equipped with almost all the parts of any other sprayer: a tank, a pump to push liquid through the hoses to the nozzles, filters and a pressure gauge. But there are limitations, mostly on the size of these components because of the power required to keep the UAV sprayer in flight mode for a reasonable time.

UAVs carry unique characteristics when applying liquid products. First, the application is different from ground-based machines but not the same as typical aerial applications completed with helicopters or crop dusters. These small UAVs are typically flown 3 to 10 feet above the crop or target area with their rotors creating turbulence or what we call vortices. While the turbulence created by the rotors can help spray droplets penetrate into a crop canopy and provide good coverage on the top and bottom of leaves, these vortices cause drift concerns. Research is being conducted to determine spray deposition, coverage and drift from UAV sprayers in comparison to other methods used for pesticide application. Unique features for UAV sprayers include vertical or altitude adjustments for topography or height, autonomous swath control, and safety.

UAV Drone

In general, spray UAVs for applying products to row-crops will have 4 to 5-gallon tanks with a spray width between ranging 10 and 15 feet. The application rate will be 1 to 2 gallons per acre or set in accordance with product labels. Today, multi-rotor UAVs have a flight time of around 15 – 20 minutes allowing a tank to be dispersed before needing to land to refill plus change out batteries for the next flight. Most manufacturers provide estimates on application rates in minutes per acre with most UAVs spraying an acre within 3 to 4 minutes.

UAVs can be used to clean up fields, spray drowned out spots, control resistant weed escapes, or other small areas within a field versus using a high-clearance sprayer.

Today, the mapping process is more accurate and efficient given the development of AI representing an essential step forward in technology.

Companies developing and testing these systems have been successful in applying to the FAA for an exemption under Section 333 resulting in the FAA potentially issuing a Certificate of Waiver or Authorization (COA for Certificate of Authorization) to facilitate testing in the United States.

Farmers and ranchers can purchase spray UAVs today but, at a minimum, you will need following three licenses to operate:

  1. Private Pesticide Applicator License in Ohio
  2. Part 107 Certificate through the FAA
  3. Part 137 Certificate through the FAA

Further, owners are required to register their UAVs (any UAV between 0.55 and 55 pounds) with the FAA:

However, if the UAV weighs over 55 pounds it must be registered with the FAA under Rule 47.

Yamaha RMAX and FAZER

  • 2- or 4-stroke gas engine depending upon model
  • 6.3, 4.2, or 8.5 on-board storage (2 tanks) depending upon model
  • 0.3 to 0.5 gpm discharge rate
  • Granular material application option
  • Legal in CA to apply crop protection products. Purchase service from Yamaha.

DJI AGRASMG

  • Electric with 8 rotors
  • 2.6 gallon tank
  • Spray Width = 4 – 6 m spray width
  • 4 nozzle boom

Hylio AgroUAV

  • Electric with 8 rotors
  • 4.5- gallon tank
  • Typically 1 gpm
  • 15-foot spray width
  • 6-nozzle boom

While there is still work on application quality, spray UAVs provide unique capabilities over manned aircraft and ground spraying equipment. To learn how we can help you register your UAV then contact the Dunaway Law Group at 480-389-6529 or click HERE.

Part 47 Registration

UAV Registration under 14 CFR Part 47

Registration with the FAA is required for all unmanned aircraft flown in the United States. The vast majority of UAVs are registered online with the FAA are small and the application process is quick, easy, and costs just $5.

Registering a UAV over 55 pounds is not quick and not easy and cannot be completed online. So you may want help to complete the Part 47 Application.

UAV Registration under 14 CFR Part 47

Part 47 Registration is required for Unmanned Aircraft that weigh 55 pounds or more.

UAV Drone

Who Must Register their Large UAV:

Excluding unmanned aircraft owned by the U.S. Armed Forces; all people, companies, and government entities that own a UAV over 55 pounds must be registered in accordance with 14 C.F.R. Part 47 or Part 48.

Registering a New- Aircraft Under Part 47

What is considered a “new” UAV? A new UAV is defined as one that came to the owner essentially new in-the-box from the manufacturer or retailer and has never been registered.  

The UAV owner must provide the following:

  1. A completed Aircraft Registration Application: For an original Aircraft Registration Application, AC Form 8050-1 must be used.

    Applicant is an LLC- When a Limited Liability Corporation (LLC) is the applicant to register a UAV it must provide pertinent information regarding the organization.
  2. A Notarized Affidavit:
    a) Establishes the required description of the UAV providing the following:
    • Full Legal Name of UAV Manufacturer or Builder,
    • UAV Model Designation,
    • UAV Serial Number,
    • Class (Airplane, Airship, Rotorcraft, Glider, Hybrid Lift, Ornithopter),
    • UAV Maximum Takeoff Weight (including all items on board or attached),
    • Number of Engines; Engine Types- Electric, Turbo – Fan/Prop/Shaft/Jet.
  3. Proof of Ownership: The applicant must show ownership of the UAV by providing an aircraft bill of sale, or an equal transfer of ownership document for each change of ownership from the UAV manufacturer, builder, or retail vendor to the owner making application for registration.

    a) Registration in a Foreign Country: The rule 47 applicant must establish that the UAV is not already registered in another country. If the UAV was purchased from a seller located in another, country is considered an import. If the UAV has not been registered anywhere and was purchased new off-the-shelf from the manufacturer or a retail vendor, include a statement that you bought it. If the UAV was registered or operated in another country, then additional steps must be taken to verify that the UAV is eligible for a Part 47 Registration.

    b) Affirmed and Notarized: The Part 47 application must be avowed and signed by the UAS owner.

4. An N-number to be assigned to the registered aircraft.

a) Special N-number– Can be reserved in advance by the UAV owner for this registration, this number will be assigned if it is entered on the forms in the indicated blanks. A special N-number may be requested when filing the application and other documents. Include a letter that lists several N-number choices, and the $10.00 special number fee. The first listed number verified as available will be assigned to the aircraft.

b) Random N-number– A random N-number will be assigned at no cost if the indicated blanks on the registration forms are left empty, or a random number is requested.

5. Registration Fee– The registration fee by check or money order made payable to the Federal Aviation Administration. This fee is waived when the applicant is a Federal, State or local government office, agency or institution.

6. Mail Your Part 47 Application: Mail your completed Part 47 application to the FAA, Aircraft Registration Branch.

As you can see, registering a UAV under Part 47 is extremely complicated and time-consuming. If you would like help registering a drone that weighs more than 55 pounds (lbs) then contact drone attorney Clint Dunaway at office@dunawaylg.com or by phone at 480-389-6529.


Registering a Used or Previously Registered UAV Under Part 47:

What is the definition of “used”? A used or previously registered UAV is defined as having been registered or operated as a civil, public, or military aircraft under the laws of the U.S. or another country.

When applying for the new application of a used UAV the application must provide the following information:

  1. A completed Aircraft Registration Application: A completed Part 47 application will include; an original Aircraft Registration Application, AC Form 8050-1.

    When a Limited Liability Corporation (LLC) is an applicant to register a used UAV, it must provide specific information regarding its organization, how management authority is held, and how it meets the definition of U.S. citizen for aircraft registration.
  2. Notarized Affidavit:
    a) Establishes the required description of the UAV providing the following:
    • Full Legal Name of the UAV Manufacturer or Builder
    • UAV Model Designation,
    • UAV Serial Number,
    • Class (Airplane, Airship, Rotorcraft, Glider, Hybrid Lift, Ornithopter),
    • UAV Maximum Takeoff Weight (including all items on board or attached),
    • Number of Engines,
    • Engine Type (Electric, Turbo – Fan/Prop/Shaft/Jet).

b) Establishes the ownership of the UAV by the applicant:

4.    Proof of Ownership: Ownership may be established by filing, with the affidavit, an aircraft bill of sale, or an equal transfer of ownership document for each change in ownership from the last U.S. registered, foreign, or military owner through any intervening owners to the owner making application for registration.

If a bill of sale or other transfer document is unobtainable, there are other options for showing the transfer of ownership.

a) Establishes that the UAV isn’t registered in another country.

When a used UAV is purchased from a seller located in another country, it is considered an import. This requires a statement from the Civil Aviation Authority of the exporting country confirming their registration for this UAV or UAV has ended or that a registration was never issued in that country.

b) Includes the following statement above the signatures,

“I affirm the information and statements provided herein are correct, the aircraft is not registered under the laws of any foreign country, and I am the owner.”

5.   Obtain an N-number– An N-number to be assigned to the used UAV being registered.

When a U.S. used or registered UAV or UAV is sold to another U.S. owner, it already has an assigned N-number. The new owner should show the assigned N-number in the indicated blanks on the application and bill of sale forms. The aircraft will then be registered and a registration certificate issued using this N-number.

If a special N-number was reserved or is desired for use on this UAV or UAV, include a letter requesting the assignment of the desired N-number. Use the special N-number link above for more information about requesting or changing N-numbers.

A random N-number will be assigned at no cost to an unregistered import or former military aircraft if the indicated blanks on the registration forms are left empty, or a random number is requested.

6.    Registration Fee– The Part 47 registration fee must be paid check or money order to the Federal Aviation Administration. Multiple fees may be consolidated into a single payment. Registration and N-number fees are waived when the applicant is a Federal, State or local government office, agency or institution.

7.    Mail Your Application– Send your Registration documents to the FAA, Aircraft Registration Branch.

As you can see, registering a UAV under Part 47 is extremely complicated and time-consuming. If you would like help registering a drone that weighs more than 55 pounds (lbs) then contact drone attorney Clint Dunaway at office@dunawaylg.com or by phone at 480-389-6529.

Selling/Purchasing a Used or Previously Registered UAV:

  • Selling a Used or previously registered UAV: The seller should execute a bill of sale transferring all or a specific portion of their right, title and interest in the UAV to the purchaser. Provide the original signed bill of sale to the purchaser. Use the aircraft description shown on the registration certificate or the Search Aircraft Registration Information website to correctly describe the UAV on the bill of sale.
  • Retaining Important Documents– When selling a UAV under Part 47, the seller should retain their Certificate of Aircraft Registration, AC Form 8050-3, complete the applicable items on the reverse side, and return it to the FAA.
  • Submitting Part 47 Documents– The purchaser should forward the bill of sale with the seller’s original signature, a completed Aircraft Registration Application, AC Form 8050-1, and registration fee to the FAA.

As you can see, registering a UAV under Part 47 is extremely complicated and time-consuming. If you would like help registering a drone that weighs more than 55 pounds (lbs) then contact drone attorney Clint Dunaway at office@dunawaylg.com or by phone at 480-389-6529.

Dictionary UAS

Certificate of Waiver or Authorization (COA)- is an authorization issued by the Air Traffic Organization to a public operator for a specific UAS activity. A Blanket COA is a granted authorization that includes the following:

  • The drone must operate within the visual line of sight of the pilot
  • Visual observers must be used at all times
  • Operations must occur during the day
  • The drone must remain below 200 feet above ground level (AGL)
  • The drone must stay 2-5 nautical miles away from all public-use airports or heliports
  • The drone must be registered and display its aircraft registration number
  • A Notice to Airmen must typically be issued for each operation

If a government entity wants to fly outside of their granted Blanket COA, they must apply for a separate COA for that specific operational change.

Drone

REG-AR-94– Provides helpful information about registration eligibility, types of registration, the form of: names, signatures, titles, addresses plus other related issues. Click HERE to obtain a copy of REG-AR-94.

FAA Form 8050– Click HERE to obtain a copy of Form 8050.

FAA Form 8050-2 – Click HERE to obtain a copy of form 8050-2.

Federal Aviation Administration (FAA)– The FAA’s mission is to provide the safest, most efficient aerospace system in the world.

Flight Training Guide– Every company flying UAVs should have a flight training guide that puts into writing certain things like; minimum requirements for pilots, and minimum requirements for drones.

Flight Operations Manual

Flight Maintenance Log

LiDAR– LiDAR is a land surveying method that measures the distance to a target by illuminating that target with a pulsed laser light, and measuring the reflected pulses with a sensor. LiDAR is often used to assist mapping in where objects are below a tree canopy, mine site conveyors, and other obstructions. LiDAR is currently being used to research; archaeology, agriculture, industrial surveying or mapping, water and forest conservation.

Person in Charge (PIC)

Special Government Interests (SGI)

Pilot in Command– The operator or pilot in command (PIC) is responsible for halting or canceling activity in the COA area if, at any time, the safety of persons or property on the ground or in the air is in jeopardy, or if there is a failure to comply with the terms or conditions of this authorization.

Part 47

Section 107 Exemption

Section 137 Operations– These regulations govern agriculture aircraft in the United States and encompass the dispensing of an economic poison designed to treat the soil or crops. Special certification rules for these pilots include knowledge and skill tests for the safe handling of poisons, agricultural chemicals, and basic medical knowledge of the symptoms of poisoning. There is also a special skill test (flight) and some rules that differ from part 91 that allow for low altitude aerial application among others.

Certification Process Part 137 (FSIMS Volume 2, Chapter 8, Section 1)

  • 2-968 – General
  • 2-969 – Pre-application
  • 2-970 – Formal Application
  • 2-971 – Document Compliance
  • 2-972 – Demonstration and Inspection
  • 2-938 – Certification

Section 44807 Exemption

Unmanned Aerial Systems

Unmanned Aerial Vehicles– means an aircraft operated without the possibility of direct human intervention from within or on the aircraft.

Small Unmanned Aircraft (sUA)-
means an unmanned aircraft weighing less than 55 pounds on takeoff, including everything that is onboard or attached to the aircraft.

Small Unmanned Aircraft System (sUAS) –
means a small unmanned aircraft and its associated elements (including communication links and the components that control the small unmanned aircraft) that are required for the safe and efficient operation of the small unmanned aircraft in the national airspace system.

Visual Observer– Required during all 333 flights.

Section 333 Exemption

So You Want to Fly a Drone that Weighs over 55 lbs?

When it comes to large drones weighing more than 55 pounds, things are not so simple. Large drones are used for applications like crop spraying, drone deliveries, and LiDAR.

Anyone wanting to fly a UAS over 55 pounds will have to seek exemption under Special Authority for Certain Unmanned Systems (49 U.S.C. §44807). Section 44807 of the 2018 FAA Reauthorization Act replaces FAA 333 exemption of the FAA Modernization and Reform Act of 2012.

How to File for a Section 44807 (Previously Section 333) Exemption?

Section 44807 of the 2018 FAA Reauthorization Act states:

“Notwithstanding any other requirement of this chapter, the Secretary of Transportation shall use a risk-based approach to determine if certain unmanned aircraft systems may operate safely in the national airspace system”.

Section 44807

So, how does the FAA plan on implementing this risk-based approach to ensure the safety of the national airspace system? These are some essential pointers for filing your Section 44807 Exemption:

  • Describe the design and operational characteristics for the type(s) of UAS in as much detail as possible
  • Training of PIC and flight experience matters a lot
  • Describe your plan for ensuring safety
  • Specify the proposed maximum operating speed and altitude, minimum flight visibility and distance from clouds
  • You will need to obtain a COA too. The FAA issues a Blanket COA to everyone with a Section 44807 exemption. If you wish to operate outside the purview of a blanket COA, you can also apply for a full COA. To learn more about the different kinds of COA’s and how they compare to Part 107, check out our show, “Should public safety offices get a Part 107 or a COA?”

You can also check out FAA’s document, “How to File a Section 333 Exemption” for more details on this. Once you have reviewed this document, you can file your petition on the public docket.

Section 333 Exemption vs. Part 107 – Comparison

  1. Requirements for getting a Section 44807 exemption are far more stringent

For starters, only Part 61 manned aircraft license holders can apply for a Section 44807 exemption.

  1. You can get your Part 107 in just 15 days

Drone registration requirements for Section 333 exemption holders mandate that they must use the traditional Part 47 process. Part 47 is a cumbersome and paper-based process.

Getting your Section 44807 exemption can take as long as 120 days.

  1. Medical Requirements– When applying for a Section 333 exemption, you MUST furnish a medical certificate.
  2. Visual Observers Section 333 exemption holders must use Visual Observers at all times.

Section 333 Exemption- Important Highlights

  • Valid for two years
  • Must always maintain Visual Line of Sight
  • You need permission to fly in controlled airspace
  • Cannot fly higher than 400 feet above the ground.

You can check out all the requirements in this FAA’s application for a Blanket COA

Conclusion

If you wish to fly a large UAS over 55 pounds, applying for a Section 333 exemption is your ONLY resort.

Fee free to contact one of our drone attorney for assistance in obtaining your section 333 exemptions. Contact attorney Clint Dunaway at clint@dunawaylg.com or 480-389-6529.

FAQ FAA Waivers

FAA Drone Waivers: Frequently Asked Questions

How Long Does it take to Receive FAA Approval?
The FAA tries to have responses to FAA Waivers within 90 days.

Are There Certain Types of Waivers that are Required for the Movie Studios?
See California Film commission.

  • Should I Hire Someone to Help Apply for a FAA Drone Waiver?
  • Why use the help of a Waiver preparation company?
  • How do you know when you need a waiver?
  • How do you know if you properly completed the waiver?
  • Do you need a Drone Waiver to Fly at Night?
  • Do you need a Waiver to Fly over People? Yes, do you want to fly over crowds of people?
  • Does it help if I attached a parachute to my drone?

Can I Fly My Drone Over Rail Road Tracks?

Yes, you may fly your drone over rail road tracks. However, you may not fly over trains! It does not matter if the train is in motion or just sitting in a train yard you cannot fly over them.

Can I Fly My Drone Over Another Person’s House?

Yes, you can fly your drone over another person’s house.

Is it a good Idea to Contact the FAA and Give them Notice?

Is there a Filing Fee for FAA Waivers?

No.

What if my FAA Waiver Application is Rejected?

You can try again.

Can I appeal the FAA Waiver Decision?

No. As of 2020 no.

How Long will it Take to get Approved?

Around 90 days.

Who Makes the FAA Decisions on Waivers?

They have a group of…

Why are FAA Waiver Requests Denied?

They did not demonstrate how it could be done safely.

Do You Need a Waiver?

  • How can I fly my Drone at Night?
  • How Can I fly Over People?
    • Drone Parachutes- What models of drones do they work with?
    • Do they ever help people get the waiver?
    • “Flying over people can give you some of the greatest footage, however, it is also dangerous and so obtaining a waiver from the FAA is somewhat hard.