NEEDMORE TOWERS

, INC. PETITION FOR EXEPMTION JUNE 8, 2015 Exhibit

EFederal Aviation Administration Memorandum Date: To: From: Prepared by: Subject:

AUG-a· 2014 Jolm Duncan, Director, Flight Standards Service, AFS-1**~~** Mark W
.Bury, Assistant Chief Counsel for Internationa:f**{{..0,f[£~a**

·and Regulations, AGC-200 Dean E. Griffith, Attorney, AGC-220 Interpretation **~egarding**whether certain required documents maybe kept atan unmanned aircraft's control station.

· This memorandum addresses whether the pilot of anunmanned aircraft may keep airworthiness certificates, aircraft manuals, and aircraft registration certificates

at the unmanned aircraft's ground contwl 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 ourattention because of the impracticality
of placing tl1ese documents onasmall ail'craft with no pilot onboard. As discussed below, wefind that the intent of these regulations

is met if the pilot of the unmam1ed aircraft has accessto these documents

at the control station from which he orshe is operating the aircraft

. Section 91.9(b) prohibits operation ofU.S

.-registered civil aircraft unless "there is available
in the aircraft" an AiJ:plane orRotorcraft Flight Manual orother material, markings and placards. The FAA stated that the purposeof this rule is to "insure that the infonnation

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 accessto 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
tothe pilot. Section 91.203(a) prohibits operation of acivil aircl'aft "unless it has within it" an appropriate and cunent airworthiness certificate and the aircraft's registration certification. Section 91.203 (b) requires that the airw01thiness ce1tificate be "displayed

at the cabin or cockpit entrance sothat it is legible to passengers
orcrew." Similarly, sections 47.3(b)(2) and 47.31(c) allow an applicant for aircraft registration

to can

·y"in the aircraft" the second copyof the registration application

as temporary authority
to operate without registration. **The~e**documents demonstrate that the aircraft is appropriately certificated and registered,
oris in the processof being registered. Additionally, the FAA has previously addressed the requirement

to display the., l

2 airworthiness certificate and found that the regulation permits displaying the certificate
sothat it is only legible tothe flight crewevenif not legible to passengers.See Legal Interpt·etation

to Leonard A. Ceruzzi, from Donald P. Byrne, Acting Assistant Chief Counsel, Regulations and Enforcement Division (Aug. 7, 1990). Accordingly, wefind that maintaining these documents

atthe pilot's control station would meetthe intent of the rule asthe pilot would be able to produce the documents for his orher owninformation
ortoanFAA inspector. We notethat this memorandum

is tobe 11arrowly construed
to unmanned aircraft systems and is not intended
to apply to operation of manned aircraft or optionally piloted aircraft with a pilot onboard.