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U.S. Department of Transportation Pederal Aviation Administrotion 800 Independence Ave.. S.W. Washington. D.C. 20591

August 26, 2014



### Al Youberg Titan Aerospace P.O. Box 1129 50 George Applebay Way, Hangar 76 Moriarry, NM 87035-1129
Dear Mr. Youberg:
This is in response to your Apri125, 2014, letter sent to the public docket (No. FAA-2012- 0618) petitioning the Federal Aviation Administration on behalf of Titan Aerospace for an extension of Exemption No. 10602. That exemption from §§ 91.9(b)(2) and 91.203(a) and (b) of Title 14, Code of Federal Regulations (14 CFR) allows Titan Aerospace to operate an unmanned aircraft system (UAS) that does not carry and display the aircraft's airworthiness, certification, and registration documents required under part 91.
We have reviewed your reasons for requesting an exemption from 14 CFR §§ 91.9(b)(2) and 91.203(a) and (b). Based on our review and consideration of FAA Memorandum subject "Interpretation regarding whether certain required documents may be kept at an unmanned aircraft's control station", (copy enclosed) dated August 8, 2014, we find this relief not necessary. Accordingly, Docket No. FAA-2412-0618 is being closed.

Sincerely,

/s/ 

### James H. Williams Manager, UAS Integration Office

Fnclosure

# Federal Aviation

Administration



# Memorandum

Date: AUG 4 2014
To: John Duncan, Director, Flight Standards Service, AFS-1
1?rom: Mark W. Bury, Assistant Chief Counsel for International a, egi.4a ' and

Regulations, AGC-200 Prepared by: Dean E. Griffith, Attorney, AGC-220 Subject: Interpretation regarding whether certain required documents may be kept at an

unmanned aircraft's control station.

This memorandum addresses whether the pilot of an unmanned aircraft may keep airworthiness certificates, aireraft manuals, and aireraft registration certificates at the unmanned aircraft's ground control station and satisfy the regulatory requirements of sections 91.9(b), 91.203(a) and (b), 47.3(b)(2), and 47.31(c) of Title 14, Code of Federal Regulations. This question has been brought to our attention because of the impracticality of placing these documents on a small aircraft with no pilot on board. As discussed below, we find that the intent of these regulations is met if the pilot of the unmanned aircraft has access to these documents at thc control station fi•om which he or she is operating the aircraft.
Section 91.9(b) prohibits operation of U.S.-registered civil aircraft unless "there is available in the aircraft" an Aiiplane or Rotorcraft Flight Manual or other material, markings and placards. The FAA stated that the purpose of this rule is to "insure that the information is readily availabie to the pilot" for use during operations. 

### See 40 Fed. Reg. 24665 (June 9, 1975), 37 Fed. Reg. 20022 (Sept. 23, 1972). The text of the rule and preamble to subsequent revisions of the rule confirm the intent that the pilot is to have acccss to the material during flight. According(y, we find that the intent of the rule is met if the information is maintained at the pilot's control station such that it is available to the pilot.
Section 91.203(a) prohibits operation of a civil aircraft "unless it has within it" an appropriate and current airworthiness certificate and the aircraft's registration certification. Section 91.203(b) requires that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." Similarly, sections 47.3(b)(2) and 47.31(c) allow an appl.icant for aiucraft registration to carry "in the aircraft" the second copy of the registration application as temporary authority to operate without registration. '1'hese documents demonstrate that the aircraft is appropriately certificated and registered, oi• is in the process of being registered. Additionally, the FAA has previously addressed the requirement to display the2

airworthiness certificate and found that the regulation permits displaying the certificate so that it is only legible to the flight crew even if not legible to passengers. 

### See Legal Interpretation to Leonard A. Ceruzzi, from Donald P. Byrne, Acting Assistant Chief Counsel, Regulations and Enforcement Division (Aug. 7, 1990). Accordingly, we find that maintaining these documents at the pilot's control station would meet the intent of the rule as the pilot would be able to produce the documents for his or her own information or to an FAA inspector.
We note that this memorandum is to be narrowly construed to unmanned aircraft systems and is not intended to apply to operation of manned aircraft or optionally piloted aircraft with a pilot on board.