Legal and Regulatory Solutions for Emerging Airspace Technologies
Our team of experienced regulatory attorneys and advisors help drone operators, manufacturers, and service providers as they navigate complex FAA, DOT and state regulatory compliance. Jetlaw offers clients a distinct advantage: deep legal insight, industry relationships, and hands-on experience to help clients reduce operational delays, mitigate risk and stay compliant while advancing their goals in the National Airspace System (NAS).
Extensive Experience in FAA Exemptions and Drone Operations
Jetlaw has extensive experience in securing critical FAA exemptions and advising clients through legally complex matters affecting drone (UAS) operations. Our notable engagements include:
Securing FAA approval for UAS operations in Part 135 cargo operations.
Partnering with Department of Defense contractors on AAM and UAS operations under Part 91, 135, and PAO regulations.
Helping universities, corporations, and organizations navigate FAA regulations for legal drone flight operations.
Securing complex FAA exemptions to accommodate unique and evolving drone operations.
Assisting an insurance company with operating UAS for conducting insurance claims inspections.
Helping agricultural operators secure FAA exemptions for UAS spray operations.
Providing guidance on DOT Part 375 foreign civil aircraft requirements for foreign civil aircraft/drone operations.
Collaborating with the Department of Transportation (DOT) on AAM economic matters.
Operators, original equipment manufacturers (OEMs), and distributors in the emerging Advanced Air Mobility (AAM) and Unmanned Aircraft Systems (UAS) marketplace face a wide range of complex regulatory and compliance challenges. These include navigating FAA regulations, DOT Part 375 requirements for foreign civil aircraft, Department of Defense contracting rules, university and state research program standards, data privacy concerns, counter-UAS technology regulations, product liability risks, and overall business strategy.
Jetlaw provides comprehensive legal guidance to help UAS manufacturers, operators, and users confidently navigate this evolving landscape. Whether you are an operator, OEM, or distributor, our team is here to help you manage risk, ensure compliance, and keep your focus where it belongs—on innovation and business growth.
How Jetlaw Can Help Your Drone Business
Jetlaw is a trusted legal partner for UAS and AAM stakeholders. We offer full-service legal and regulatory support, including:
Reconciling conflicting FAA and public aircraft operation (PAO) requirements for Department of Defense (DoD) and state contractor operations, both domestic and abroad.
Advising on FAA certification matters, including obtaining airworthiness certification for your drones.
Helping you obtain favorable National Environmental Policy Act (NEPA) review outcomes to expedite regulatory approval.
Securing FAA exemptions for AAM and UAS operations, including 44807 exemptions, and complex regulatory exemptions not previously granted by FAA (Lead Exemptions).
Advising on FAA registration matters for AAM and UAS, including issues related to privacy and foreign citizen trusts.
Navigating DOT Part 375 foreign civil aircraft requirements for international operations.
Assisting Part 135 operators in complying with FAA regulations for drone operations under Part 135.
Helping OEMs and operators ensure compliance with local, state, and federal regulations.
FAA 44807 Exemption for Large Drones (55 lbs or More)
Jetlaw works closely with drone distributors and agricultural operations to petition the FAA for 44807 exemptions in accordance with 14 C.F.R. Part 11 and 49 U.S.C. §44807. This exemption allows operators to legally fly drones weighing 55lbs or more in the NAS, offering a pathway to safe and compliant operations for large UAS.
We understand that the process of petitioning for a 44807 exemption can be complex, and our team is here to guide you through every step of the process. We assist in providing the necessary documentation and evidence to demonstrate that your drone can operate safely in the NAS, ensuring a smooth and efficient approval process.
Why Choose Jetlaw?
- Proven Track Record: We’ve successfully helped clients nationwide secure FAA exemptions, certifications, and resolve complex regulatory issues in the drone and AAM space.
- Comprehensive Legal Services: We are not just drone attorneys. Our team provides full-service legal support, addressing everything from risk assessments to policy advocacy. We understand the “big picture”, so we can advise you on how FAA policy changes in one area of the industry may impact your industry
- Industry Leadership: Our attorneys maintain close working relationships with FAA and DOT officials and stay ahead of regulatory developments to ensure your operations remain compliant and competitive.
History and Background on 44807 Exemptions
The FAA regulates the operation of small drones—those weighing less than 55 pounds—under 14 C.F.R. Part 107. For drones weighing 55 pounds or more, the FAA uses the 44807 exemption, along with its Conditions and Limitations, to authorize operations. This exemption is issued under 49 U.S.C. § 44807, which permits the FAA to approve the use of larger unmanned aircraft systems (UAS) within the National Airspace System (NAS). To obtain a 44807 exemption, operators must submit sufficient documentation and evidence demonstrating that their drone can operate safely in the NAS.
What is the history of the Exemption?
Congress first used Section 333 of the FAA Modernization and Reform Act of 2012 to require the Department of Transportation (DOT) to authorize commercial drone operations by exemption. Section 333 instructed the Secretary of Transportation to determine, on an expedited basis, whether certain unmanned aircraft systems could operate safely in the National Airspace System (NAS).
It directed the DOT to evaluate: (1) the risks posed by the UAS based on its characteristics and the proposed operation, and (2) whether additional certification or authorization would be required for the operation. Finally, Section 333 required the DOT to establish safety requirements for UAS operations.
In 2016, the FAA began regulating commercial operation of small UAS and certification of their remote pilots under 14 C.F.R. part 107 instead of the Section 333 exemption. Part 107 governed commercial operation of small UAS, weighing less than 55lbs, excluding model aircraft. The FAA permitted Section 333 exemption holders to operate under part 107 or the exemption, until the exemption expired, at which time small UAS operator needed to operate under the new rule. Part 107 still governs the operation of small UAS and certification of their remote pilots and large UAS operators still operate by exemption.
The FAA Reauthorization Act of 2018 codified the Section 333 exemption requirements in Title 49 of the United States Code Section 44807. While the move essentially constituted a name change and had little impact on the agency or drone operations, it created the 44807 exemption that we use today.
The FAA Reauthorization Act of 2024 changed the responsibility for determining how unmanned aircraft systems may operate safely in the national airspace system from the Secretary of Transportation to the Administrator of the Federal Aviation Administration. The 2024 bill also directed the FAA to establish a process for safe
and efficient operations of unmanned aircraft systems and issue approvals to enable low-risk operations beyond the pilot’s visual line of sight, including package delivery.
Currently, the FAA’s authority to issue 44807 exemptions extends through 2033. By that time, Congress expects the FAA to establish a permanent rule for operating drones and UAS weighing 55 pounds or more.
While the FAA has prioritized facilitating the use of drones for commercial purposes, the process of petitioning for a 44807 exemption can be complex and time-consuming. Jetlaw’s experienced team helps streamline this process. When petitions for exemptions are especially complex or delayed, we engage directly with the FAA to help move the process forward so our clients can stay focused on operations and growth.
Get Started Today
If you are looking for legal guidance on securing FAA exemptions or navigating drone regulations, Jetlaw is here to help. Jetlaw provides strategic legal guidance tailored to your operational goals. Contact us for a consultation to learn how we can accelerate your compliance pathway and mitigate regulatory risk.
Frequently Asked Questions
Our clients typically receive their 44807 exemptions within 4–6 weeks of submission.
Yes. We work closely with distributors nationwide to help their customers secure 44807 exemption.
Jetlaw can assist in submitting the necessary documentation to have your aircraft reviewed and added to the FAA’s approved list
Currently, the FAA has not approved external load operations through this exemption. Contact Jetlaw to learn more about external load operations with drones.
Learn more about the FAA’s Approved List of Unmanned Aircraft systems here. The FAA updates this list regularly.
On June 28, 2016, the FAA published “Operation and Certification of Small Unmanned Aircraft Systems; Final Rule”, creating 14 C.F.R. Part 107 and amending numerous existing regulations in 14 C.F.R. These regulations became effective on August 29, 2016.
A small unmanned aircraft means an unmanned aircraft weighing less than 55 pounds on takeoff, including everything that is on board or otherwise attached to the aircraft. Part 107 does not apply to model aircraft or UAS operated strictly for hobby or recreational use. Advisory Circular 91-57C has more information about operating UAS/drones for recreational purposes.
All drones must be registered, except those that weigh 0.55 pounds or less (less than 250 grams) and are flown under the Exception for Limited Recreational Operations. You can find more information about registering your drone here.
The paper (N-number) registration process must be used if:
- Your unmanned aircraft weighs 55 pounds or more.
- You want to qualify a small UAS for operation outside the United States.
- You hold title to a UAS in an owner trust.
- You use a voting trust to meet U.S. Citizenship requirements.
Part 107 eligibility requirements can be found here.
Part 107 states that the operator or pilot is a person who manipulates the flight controls of a small UAS. The FARs establish a new airman concept: Remote Pilot in Command, who may operate a small UAS. The pilot must hold a Remote Pilot airman certificate with a small UAS rating or be under the direct supervision of a Remote Pilot in Command
For current pilots that hold a certificate under Part 61:
- Complete the online training course “Part 107 small Unmanned Aircraft Systems (sUAS) ALC-451” available on the FAA FAASTeam website
- Complete FAA Form 8710-13 (FAA Airman Certificate and/or Rating Application for a remote pilot certificate)
- Validate applicant identity
- An appropriate FSDO representative, a DPE, or an ACR will then issue the applicant a temporary airman certificate
- A permanent remote pilot certificate will be sent via mail once all other FAA-internal processing is complete.
New pilots will take a longer aeronautical knowledge test and be vetted by the TSA, but otherwise will follow the same process as described above for current pilots. For FAA aeronautical knowledge test resources, learn more here.
Operators are required to obtain an unmanned aircraft operator certificate with a small UAS rating along with passing an initial aeronautical knowledge test at an FAA-approved knowledge testing center, followed by passing a recurrent aeronautical knowledge test every 24 months.