US Deportment 

of Tronsportotion 

Federal Aviation 

Administration 

AUG 1 3 2015 

Mr. Jacob Senior 

Lockheed Martin Missiles and Fire Control 

23 10 Hickory Drive 

Melbourne, FL 32935 

Dear Mr. Senior: 

800 Independence Ave . S W 

Wash•nglon DC 20591 

This is in response to your docket submission letter dated June 23, 2015 (public docket No. 

F AA-20 11-741) petitioning the Federal Aviation Administration on behalf of Lockheed 

Martin Missiles and Fire Control (LMMFC) for an extension to its current exemption 

(10326A) from§§ 91.9 and 91.203 ofTitle 14, Code of Federal Regulations (CFR), allowing 

LMMFC to operate its unmanned aircraft systems (UAS) that do not carry and display the 

aircraft's airworthiness, certification, and registration documents required under part 91. 

On August 8, 2014, the FAA Office of Chief Counsel issued a legal interpretation relating to 

the requirements under§§ 91.9 and 91.203 to keep the aircraft's airworthiness, certification, 

and registration documents on board the aircraft. The FAA determined 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. A copy 

of this interpretation is enclosed for your information. lt can also be found at 

http://www.faa.gov/about/office erg/headquarters offices/age/pol adjudication/agc200 

under "Legal Interpretations & Chief Counsel's Opinions." 

Because the relief you seek is now covered under this interpretation, we will take no further 

action on your petition. 

Sincerely, 

William 

~~ Crozier 

Acting Manager 

UAS Integration Office, AFS-80 

AFS-15-2876-E 
Federal Aviation 

Administration 

Memorandum 

Date: 

To: 

From: 

Prepared by: 

Subject: 

AUG -a· 2014 

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

Mark W. Bury, Assistant Chief Counsel 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 of 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 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 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 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 pi toted aircraft with a pilot on 

board.