Below please find revised text for the “ Comments ” porti on of our Request for Exemption ( FAA

- 2016

-

0363

- 0005 ) as per US DOT/FAA Request for Additi onal Inform ation ( FAA

- 2016

- 0363

- 0006 ) . This tex t is
intended a s an update to the tex t originally submitted in Response to RFIA ( F AA

- 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
altime ter 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 UA V 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 i s 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 thi s 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 Ob server (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 eve ry 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 equiva lent level of safety.

In addition, approval of this exemption will benefit the public by enabling the FAA's Pathfinder prog ram 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 opportunitiesfor 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 op erations 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 addi tion to this improved service, the cost of these services can be reduced through economies of scale.