Below please find revised text for the “Comments” portion of our Request for Exemption (FAA-2016-

0363-0005) as per US DOT/FAA Request for Additional Information (FAA-2016-0363-0006). This text is 

intended as an update to the text originally submitted in Response to RFIA (FAA-2016-0363-0007).

14 CFR 91.121

Exemption to 14 CFR, Section 91.121, Altimeter Settings

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set "...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure."

As PrecisionHawk will be operating a UAV, there is no concept of setting the altimeter, other than 

zeroing (similar to a tare) the pressure altimeter prior to launch. When the UAV is not equipped with a 

barometric altimeter, an alternate means for measuring and reporting UA altitude is necessary, such as 

GPS. PrecisionHawk will work with altitude reported in feet above ground level (AGL). We will set the 

altitude indicator in the Lancaster to zero feet AGL prior to take off, instead of setting a local barometric 

pressure in the altimeter before flight. Considering the limited altitude of the proposed operations, the 

use of the GPS reported altitude AGL will provide an equal level of safety. As such, PrecisionHawk is 

requesting exemption to 14 CFR, Section 91.121. In similar settings, the FAA has granted exemption 

relief under section 333 from the altimeter requirement.

It is anticipated that 14 CFR §91.113 See and Avoid will be waived as a part of the COA process, and so it 

is not included in the list of exemption petitions. However, to be clear about the view of this section, the 

following is provided. The pilot in command has a responsibility to see any intruder aircraft at all times 

and must avoid any intruding aircraft. This EVLOS operation will be a “See and Avoid” operation at all 

times. During the research flights a Safety Observer (SO) will be stationed next to the pilot in command 

as an extra set of eyes to supplement the pilot’s observation of the sky. The remote visual observer will 

be part of the flight crew to enhance situational awareness of the pilot in command and to maintain 

visual surveillance of the airspace in which the UAV is flying at all times. Prior to conducting UAS 

operation a notification will be sent out to impacted aviation community to ensure awareness and 

enhance safety, and a NOTAM will be filed for every day that flight activities will be conducted. These 

requirements for the flight crew obligation to see traffic and the pilot’s responsibility to maneuver to 

avoid the traffic combined with the notification provisions and the NOTAM will provide an equivalent 

level of safety.

In addition, approval of this exemption will benefit the public by enabling the FAA's Pathfinder program 

to eventually extend the commercial use of unmanned aerial vehicles in the NAS to include extended 

and beyond visual line of sight operations, thereby opening up countless new commercial opportunities 
for American businesses. The Pathfinder initiative is a public-private partnership with the FAA with the 

objective of expanding the current regulatory framework for the benefit of the Unmanned Aircraft 

Vehicle industry at large. Under EVLOS operations a UAS operator will be able to conduct its agriculture 

analysis over a much larger area, possibly 5 times as large, thereby enhancing the effectiveness of this 

air commerce and providing a better service to the farmers and property owners. In addition to this 

improved service, the cost of these services can be reduced through economies of scale.