Federal Aviation 

Administration 

Memorandum 

Date: 

To: 

From: 

Prepared by: 

Subject: 

AUG -$ 2014 

John Duncan, Director, Flight Standards Service, AFS-1 ~~ 

Mark W. Bury, Assistant Chief Counsel for Intemationa:1 t:kwtia . and 

Regulations, AGC-200 

Dean E. Griffith, Attorney, AGC-220 

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, aircraft manuals, and aircraft 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 47.3l(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 the control station from 

which he 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 of this 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 of the rule and preamble to subsequent revisions of the rule 

confirm the intent that the pilot is to have access to the material during flight. Accordingly, 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 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 it is legible to passengers or crew." Similarly, sections 47.3(b)(2) and 47.3l(c) allow an 

applicant for aircraft registration to cany "in the aircraft" the second copy of the 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 of being 

registered. Additionally, the FAA has previously addressed the requirement to display the 
2 

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.