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Altitude Waiver

Overview

Throughout this semester, my team and I, have been working on preparing the MFE Believer to ensure that it is ready for flight operations next semester. Since the MFE Believer is a fixed-wing training aircraft that, while can maintain flight at 400 feet AGL, will require higher altitudes for training purposes. The maximum altitude for UAS Pilots is 400 feet AGL, however, the FAA allows for UAS Pilots to submit an Operational Waiver to deviate from certain regulations while still demonstrating safe operations. My team and I have drafted and submitted an Operational Waiver to the FAA in preparation for practice flights with the sUA, the Believer.

Group 6

Isabella Avedician
Kenzie Florkiewicz
Diego Hernandez
Nico Jaekle
Clayton Brown

What Part 107 Regulation Are We Trying To Waive?

14 CFR § 107.51 (b) (Operating Limitations: Altitude): Operating limitations for small unmanned aircraft.
Section B: The altitude of the small unmanned aircraft cannot be higher than 400 feet above ground level, unless the small unmanned aircraft
Why?
We are requesting to waive FAR 107.51 (b) for altitude of 650 feet AGL in the vicinity of the Animal Sciences Research and Education Center for training flight.

Aircraft Details

Type of UAS

image.png
Figure 1. Believer
True Believer V2

Size

Wingspan: 1960 m (77.2 in)
Fixed Wing sUA
Fuselage Length: 1070 mm (42.1 in)
Fuselage Height: 185 mm (7.3 in)

Maximum Flight Time, Range, Speed, Weight, and Battery Life

Flight Time
120 minutes
Ground Speed
20 m/s (44.7 mph)
Speed
90 km
Weight
5500g (11.46 lbs)
Battery Life
120 minute

Right of Way

Yes

Maximum Altitude

650 ft AGL

Control Station

Stationary Vehicle

Internal Load

Internal: The battery, and additional components will be secured internally by velcro strips

How to ensure aircraft flies where it is directed?

Use of remote control and autonomous flight modes
Flight Controller, GPS and Sonar, Telemetry, ESCs, ArduPilot Mission Planner, Open-Source Software

Termination System

If power is lost, the UAS will lose flight capabilities and crash. The crash will not result in any infrastructural damage due to the rural area of operation

What external or internal load could be dropped from the aircraft when flying, and will you ensure the safety of people, or other people’s property, if it is dropped or detached when flying?

We plan to not have flight coordinated drops.
In the event of a component failing and falling off of the UAS, our flight operations are over open fields and sparse populations.
In addition, any Visual Observers will initiate a verbal warning to surrounding personnel.

Personnel Details

Minimum Level of Experience of Remote PIC?
Part 107
Flight hours with other sUAS
Timed Hours on the Believer Simulation
How Many Personnel will you use for operations?
At least 2 personnel to act as RPIC and VO
However, we will have 5 personnel involved
What training will personnel have before flying under this Waiver?
All personnel will have their current Part 107, flights hours with other sUAS, and timed hours on the believer simulation
The simulation is a course on how to fly a fixed wing UAS. This will be documented on a flight simulator with specified rubric from Purdue UAS Dispatch.
Purdue UAS Dispatch will ensure the qualifications of each pilot meets a specified standard.

Operational Details

Location

Google Map link:
image.png
Figure 2. Area of Flight Operation and Boundaries
A screenshot of a map

Description automatically generated
Figure 3. LAANC for Area of Flight Operation
Animal Sciences Research and Education Center, or ASREC, is our intended area of operations. ASREC is located in West Lafayette, IN, USA at 40°30'32.56"N, 87°1'17.06"W. The intended area of flight operation is 0.68 NM by 0.56 NM rectangular area around the location, Figure 2 in the red box. We intend to only be airborne each period no longer than 60 minutes, to preserve battery life.

Nearest Airport

Purdue University Airport (KLAF)
ASREC is located 7 NM NE of KLAF Airport.

Areas we will fly over

Our intended area of operations is over sparse population. It is mainly fields, with a few roads and small infrastructures. However, we do not intend to fly over roads or infrastructures. In addition, there is a small local water tower. This is our main risk in the area, however we have risk mitigations in place, refer to Risk Assessment Table located at the end of the document.

Target Dates and Times

Flight operations are scheduled to being as soon as possible next semester, which begins January 12th, 2026 and will continue though the end of the semester, which ends May 9th, 2026. All operations will take place during daylight. However, we are requesting an operational time frame extension from January 20th 2026 - June 1st 2027, for our submitted Operational waiver. This would give us flexibility with weather, airspace restrictions, and surrounding other hazards. Additionally, this would provide more opportunities for training flights, in preparation for the upcoming flight demonstrations and proficiency.

How high will the aircraft fly and maximum lateral distance?

Maximum 650 ft AGL
Although we may not reach a maximum of 650 ft AGL, this allows a 25-foot buffer for altitude and measuring errors.
Maximum lateral limit of 0.49 NM lateral distance from the ground control station.
Allows for enough distance to accurately avoid and give leeway to incoming aircraft.

Operation Over People or Moving Vehicles?

No

How to ensure operations remain safe at all times, even in unusual circumstances?

Our team consists of 5 personnel. This means we will always have at least 3 Visual Observers at all times. In our first few flights, the PIC will be buddy boxed with an instructor with experience flying fixed wing UAS, more specifically the Believer. This is to ensure all members of our team are maintaining safe operations at al times as well as minimizing risk to the Believer crashing.
Each member of the team will be communicate and confirm what the intent of each mission, what each personnels’ role and responsibility is, and risks and plans we have in place to minimize them. Each Visual Observer is responsible to communicate as clearly and regularly as possible with the PIC and other Visual Observers.

Provide circumstances and ways to resolve

How the sUA will be able to avoid nonparticipating aircraft and structures when operating at altitudes other than those prescribed in Title 14, Code of Federal Regulations (14 CFR) § 107.51(b)?
If required by the FAA, we will employ a NOTAM to show the area we area flying in.
This increases the likelihood that pilots in the area are aware of our sUA operations. In addition, we will be equipped with a radio to listen to nearby pilots’ communication. If detected that a pilot nearby is not aware of our operation, we will avoid the aircraft by flying lower than the manned aircraft.
Due to our maximum ceiling of 650 ft AGL, the RPIC will be able to avoid non-participating aircraft and structures.
At all times, we will have at least 3 Visual Observers. The Visual Observers will assist the RPIC in avoiding structures and non-participating aircraft.
Before each flight, the team will brief about communication to be used to ensure no confusion during the planned flight.
There will also be a pre-planned landing zone.
The flight controller, cube orange, will also be used to receive ADS-B signals from corresponding aircraft.
How will the visual conspicuity of the sUA be increased to be seen at a distance of at least 3 statute miles?
The Believer drone will be equipped with 2 high-intensity anti-collision strobe lights, that will be securely mounted, that are rated by the manufacturer to be seen for at least 3 statute miles in the daylight.
These strobe lights will be mounted on both sides of the fuselage to provide 360-degree visibility in our daylight operations.
How will the RPIC be able to accurately determine the sUA altitude, attitude, and direction of flight?
The RPIC will be able to determine the altitude, attitude, and direction of flight using natural eyesight and depth perception along with the tablet and software provided by the sUA ground control station.
The ground control station will provide real-time information that will depict the orientation and altitude of the sUA in feet above the ground (AGL).
Visual Observers will also be used to see verify the RPIC by looking at the aircraft and the ground control station.
How will the RPIC be able to be contacted by Air Traffic Control (ATC) in case the operation needs to be terminated, as well as a procedure to notify ATC when the operation begins and ends?
During flight operations we will have a working cellular phone with cellular connection at the site and will have a Visual Observer answer the phone in case of a termination request by ATC.
The main phone number, tested at the are is 219-802-0920
A back up number, also tested is 260-908-5052

What will be done in case of lost link and loss of control?

We have reduced our risk of lost link by decreasing our distance from the sUA and limited our flight duration to a maximum of 60 minutes. However, we have a contingency plan in case of lost link, such that is we lose control of the sUA. First, there will be a verbal warning to others in the area that we have lost control. Then, if the sUA continues to fly during a lost link, ATC will be called and given last known altitude, attitude, and direction of flight.

What is the avoidance of persons plan?

We intend to conduct the flight operations when normal operations at ASREC are not in progress. However, if this is not possible, the RPIC and Visual Observers will place a traffic cone perimeter marking around the ground control station and inform people that they will need to remain outside of the barrier for safety. If non-participating civilian do not heed to this warning, we will discontinue operation until they are clear of the area.

General Flight Risk Mitigation Precautions

Prior to constructing the waivers, for these prescribed boundaries and operations, we have been granted approval for the requested operational boundaries by Animal Sciences Research and Education Center. If there is any dispute, while conducting operations, the VO will converse with the subjected authorities and determine a solution, even if it means immediate discontinuation of the operation until disputes are settled.
Launch points are defined on the “Aerial Flight Boundary” map as green dots, in Figure X. These are the only designated takeoff and landing locations. Mainly determined for their flight proximity to flight area, to not traverse over public roadways, to avoid power lines, structures, other hazards, and to have a predetermined location for if immediate action needs to be taken during flight operations. All of this will be discussed in our pre-flight meeting.
Our sUA, Believer, will be equipped with securely mounted strobe lights visible within at least 3 statute miles during day light operations, and redundant flight control software to determine altitude, direction, speed, orientation, etc. In our pre-flight meeting we’ll discuss our pre-flight checklist to ensure flight software is operational, additional sensors and lights are mounted securely, and finally to ensure that the sUA is airworthy prior to conducting the flight operation.

Risk Assessment

Safety Risk Assessment and Mitigation Steps
Hazard
Cause
Effect
Likelihood (1)
Severity (2)
Risk (3)
Mitigation
Emergency or Contingency Procedures (4)
Water Tower
On takeoff and landing, the sUA is flying lower than the operating altitude, which poses the risk of crashing into the water tower. In addition, if flying above it, the sUA will need to fly 400 ft AGL above the water tower.
This could result in serious damage to the sUA and potential damage to the water tower and surrounding area.
Possible
Would be very severe if a collision were to occur.
Collision
Our team will not takeoff or land near the water tower. Prior to flight, we will plan our flight path so that we avoid flying directly above the water tower.
The RPIC will stay clear of the water tower. Visual Observers will also be paying attention and give a verbal warning if RPIC is approaching near the water tower. If the sUA comes near the water tower, the RPIC will direct the sUA away from it to maintain a safe lateral distance and ceiling.
Infrastructures
During the flight, there is a possibility of flying over infrastructures. There is a low possibility of damage to the infrastructures.
In the event of an emergency, the drone could crash on the infrastructures or something could fall off/drop from the sUA.
Possible/Low
Severe
Collision and Damage
We will not operate the sUA near any infrastructures. We do not have any payloads that could fall off of the sUA. VOs and RPIC will be diligent to avoid all infrastructures.
The RPIC will not operate the sUA near any infrastructures. If the sUA is approaching an infrastructure, they will direct the sUA away to maintain a safe lateral distance and ceiling. Visual Observers will give a verbal warning to the RPIC if the sUA is approaching an infrastructure. In the event a piece of equipment were to fall off of the sUA, the RPIC would safely land the sUA, and the team would assess any damage. An incident report would be made to the FAA if damage to property was more than $500. In addition, a report would be made to Purdue University Dispatch no matter the severity.
High tension power line running from North to South
During flight, there are power lines that could interfere with the sUA.
This could interfere with sUA if descending or flying near the high tension power lines.
Possible
Severe
Collision and damage
These high-tension power lines are located to the east of the ASREC property and run north to south. These power lines can cause EMI, which would cause the sUAS to lose control. In order for that not to happen, we will avoid having the believer fly near these power lines.
The RPIC will plan to avoid all high-tension power lines and maintain a safe lateral distance and ceiling from them. If approaching near the RPIC and Visual Observers will make a verbal warning and the RPIC will direct the drone away from the high-tension power lines.
Roads
Traffic and non-participating vehicles
Could cause sUA to fly over non-participating vehicles
Highly likely
Moderate
Could result in the sUA operating over non-participating vehicles
We will not fly over the roads.
The RPIC will plan to avoid all roads. If approaching near the RPIC and Visual Observers will make a verbal warning and the RPIC will direct the drone away from the roads.
Drone flyaway
EMI could potentially interfere with the signal of the drone leading to a lost signal
Because of this lost signal, the sUA would lose communication and need to start lost link procedures to safely land the sUA
Likely
High severity
Could result in lost link and the RPIC would have no control over the sUA.
Lost link procedures will be implemented once the drone shows signs of a lost link.
We have reduced our risk of lost link by decreasing our distance from the sUA and limited our flight duration to a maximum of 60 minutes. However, we have a contingency plan in case of lost link, such that is we lose control of the sUA. First, there will be a verbal warning to others in the area that we have lost control. Then, if the sUA continues to fly during a lost link, ATC will be called and given last known altitude, attitude, and direction of flight.
There are no rows in this table

Link to Team’s Application Draft

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