US Deportment of T r onsportotion Federal Aviation Administration



### AUG 1 3 2015
Mr. Jacob Senior Lockheed Martin Missiles and Fire Control 23 10 Hickory Drive Melbourne , FL 32935
Dea r Mr. Sen ior: 800 In depen d ence Av e
. S W Wash • nglon DC 20591



### Thi s is in response to your docket submission letter dated Jun e 23 , 2015 (public docket No. FAA-20 11-741) petitioning the Federal Aviation Administration on behalf of Lockheed Martin M issiles and Fire Control (LMMFC) for an extension to its c urrent exemption ( 10 326A) from§§ 91.9 and 91.203 ofTit le 14 , Co d e of Federal Regulations (CFR), allowing LMMFC to operate its unmanned aircraft syste m s (UAS) that do no t carry and display the aircraft ' s airworthiness , certification, and registration documents required under part 91.
On August 8 , 20 14 , the FAA Office of Chief Co un se l issued a legal interpretation re latin g to the requirements under§§ 91.9 and 91.203 to keep the a ircraft ' s airworthiness , certification , and reg i stration documents on board the aircraft. The FAA determined that maintaining these documents at th e pilot's control station wou ld meet the inte nt of the rule as the pi l ot wou ld be ab le to produ ce the documents for his or her own informati on or to an FAA inspector. A copy of thi s inte rpre tation is enclosed for your information. l t can a l so be found at http : //www . faa.gov/about/office erg/headquarters offices/age / pol adjudi cation/agc200 und er "Legal Interpretations & 

### Chief Counse l 's Opinions. "
Because the r e li ef you seek is now covered under thi s interpr etation , we will take no further action on your petition. Sincerely ,



# ~~ William C roz ier Acting Manager UAS In tegrat ion Office , AFS-80

AFS-15-2876-E

# Federal Aviation Administration 

# Memo randum
Date: To: From: Prepared by: Subject: AUG 

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

# ~~ Mark W. Bury, Assistant Chief Counse l for Intemationa'l

# t{~:f?{{r~~ 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) ofTitle 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 o f these regulations is met if the pilot of the urunanned 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 placard s . 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 ru le 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 cettificate 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 applicant for aircraft registration to carry "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 the2 airworthiness cer tificate and found that the r egulation permits displaying the certificate so that i t is only leg i ble to the fl ig ht c rew even if no t legible to passengers. 

### See Legal I nter pretation to Leonard A. Ceruzz i , from Donald P. Byrne, Acting A ss istant Ch ief Counsel, Regu latio ns and Enforcement Division {Aug. 7, 1990). Accord ingly, we find that maintaining these documents at the pilot 's contro l station would meet the i ntent of the ru l e as the pi lot wou ld be able to produce the docume n ts for his or he r own info rmation or to an FAA inspector.
We n ote th at this memorandu m is to b e narrow ly construed to unmanned ai r craft systems and i s not intended to apply to oper ation of manned a ircraft or optiona ll y p i toted airc raft with a pilo t on board.