# Federal Aviation Administration 

# Memorandum
Date: To: From: Preparedby: Subject: 

### AUG -$ 

### 2014 John Duncan, Director, Flight Standards Service, AFS-1

# ~~ Mark W. Bury, Assistant ChiefCounsel for Intemationa:1

# t:kwtia

. and Regulations, AGC-200 DeanE. Griffith, Attorney, AGC-220 Interpretation regarding whether certainrequired documents may be kept at an unmanned aircraft's control station.

This memorandum addresses whether the pilot ofan unmanned aircraft may keep airworthiness certificates, aircraft manuals, and aircraft registration certificates at the unmanned aircraft's ground control station and satisfy the regulatory requirements ofsections 91.9(b), 91.203(a) and (b), 47.3(b)(2), and 47.3l(c) ofTitle 14, Code ofFederal Regulations. This question has been broughtto our attentionbecause ofthe impracticality ofplacing these documents on a small aircraft with no pilot onboard. As discussed below, we find that the intent ofthese regulations is met ifthe pilot ofthe unmanned aircraft has access to these documents at the control station from whichhe or she is operating the aircraft. Section 91.9(b) prohibits operation ofU.S.-registered civil aircraft unless "there is available in the aircraft" an Airplane or Rotorcraft Flight Manual or other material, markings and placards. The FAA stated that the purpose ofthis rule is to "insure that the information is readily available to the pilot" for use during operations. See 40 Fed. Reg. 24665 (June 9, 1975), 37 Fed. Reg. 20022 (Sept. 23, 1972). The text ofthe rule and preamble to subsequent revisions ofthe rule confirmthe intentthat the pilot is to have access to the material during flight. Accordingly, we find thatthe intent ofthe rule is met ifthe information is maintained atthe pilot's control station such that it is available to the pilot. Section 91.203(a) prohibits operation ofa civil aircraft "unless it has within it" an appropriate and current airworthiness ce1iificate and the aircraft's registration certification. Section 91.203(b) requires that the airw01ihiness certificate be "displayed at the cabin or cockpit entrance so that itis legible to passengers or crew." Similarly, sections 47.3(b)(2) and 47.3l(c) allow an applicant for aircraft registration to cany "inthe aircraft" the second copy ofthe registration application as temporary authority to operate without registration. These documents demonstrate that the aircraft is appropriately certificated and registered, or is in the process ofbeing registered. Additionally, the FAAhas previously addressed the requirementto display the2 airworthiness certificate and found that the regulation permits displaying the certificate so that it is only legible to the flight crew even ifnot legible to passengers. See Legal Interpretation to Leonard A. Ceruzzi, from Donald P. Byrne, Acting Assistant ChiefCounsel, Regulations and Enforcement Division (Aug. 7, 1990). Accordingly, we find that maintaining these documents at the pilot's control station would meetthe intent ofthe rule as the pilot would be able to produce the documents for his orher own information or to an FAA inspector. We note that this memorandum is to be narrowly construed to unmanned aircraft systems and is notintended to apply to operation ofmanned aircraft or optionally piloted aircraft with a pilot on board.