1: Application Information
Everyone who is going to operate under this waver is part of Purdue University’s School of Aviation and Transportation Technology (SATT). This school will be the responsible party for the oepration. The main pilots will include Venkata Devapatla, Jacob Sieber, Ryan Pirro, Madison Baker, Elijah Meadows, Nolan Lach, and Nathan Rose. All the pilots are certificated pilots under 14 CFR § 107. We will be rotating who is Remote Pilot in Command (rPIC). The other members will be acting as Visual Observers (VOs). Everyone has time as both rPIC and VOs in UAS operations. It should also be noted that most have experience in manned aviation as well, and some have certificates including Certified Flight Instructor for airplane single engine land.
Venkata Devapatla: (443) 824-9315, , 5076259 Jacob Sieber: (717) 668-4011, , 5083460 Ryan Pirro: (631) 372-3200, , 4918704 Madison Baker: (219) 575-3433, , 4924159 Elijah Meadows: (765) 426-2208, , 5093011 Nolan Lach: (708) 369-7013, 5092873
We will be operating a Makeflyeasy Believer that we have built as it is supposed to replicate the Windracers’ Ultra that Purdue University owns. We want to fly to the Believer near the ASREC (Animal Sciences Research and Education Center) Poultry Unit, which is located at 5465 Asrec Ln, West Lafayette, IN 47906. An image of this area can be seen below. The location of our launch point will be 40.4937110 o N and 87.0092924 o W. We will be flying it in a .5 nautical miles radius around the launch point. This is to simulate the flying traffic pattern for the Ultra. More images of the study area can be found below in the air risk section.
ASREC facility location in relation to Purdue University Airport on UAS maps
The Drone’s registration number is ______ and is registration under Purdue UAS Dispatch. Some specifications of the Makeflyeasy Believer can be seen below.
Fuselage Length - 1070mm Recommended Take-off weight: 4.2 kg (9.2lbs) Max. Take-off Weight: 5.5kg (12lbs) Flight Duration: 2 hours
2: Waiver Requested
We are requesting an exemption from 14 CFR § 107.51(b), which limits small unmanned aircraft operations to 400 feet above ground level (AGL), except under specific conditions. Our intent is to conduct operations with the Believer at altitudes up to 750 feet AGL. Operating at this altitude is necessary to gain a more comprehensive understanding of how the Windracers Ultra platform performs, particularly during critical phases of flight such as takeoff, climb, descent, and landing. The increased altitude also provides additional margin and reaction time in the event of an in-flight emergency, allowing the Remote Pilot in Command (rPIC) to diagnose issues and execute safe recovery procedures without compromising operational safety. We would like to get a waiver starting on January 20, 2026, to December 31, 2026.
3: Description of Proposed Operation
We intend to fly the Believer to build and strengthen our skills to be able to fly the Windracers’ Ultra safely. The purpose of these training flights is to allow our team to gain hands-on experience with aircraft performance, flight control response, and handling characteristics under real-world conditions. The maneuvers we plan to conduct include takeoffs, climbs, descents, approaches, and landings, along with any additional exercises recommended by Windracers to ensure each pilot is fully competent and comfortable with the system. Some of the flights will be conducted manually and others will be conducted by autopilot. This training is extremely critical to ensure safe operations when we are going to fly the Ultra. The Ultra is nothing like any of the other drones we flew during our time at Purdue.
To ensure safe and efficient communication throughout the operation, rPIC and VOs will remain in close proximity to one another during all flight activities. This proximity allows for clear, immediate communication and coordination, reducing the chances of any miscommunication during critical flight phases. If at any point a VOs or other crew member must move farther away from the rPIC to maintain proper line of sight, they will remain connected through a radio or phone call to ensure that communication remains continuous and effective. All team members will wear high-visibility safety vests so that each person is easily identifiable to other crew members, as well as to any bystanders in the area. Maintaining a visible and professional appearance also promotes situational awareness and overall operational safety.
To further enhance safety and maintain full situational awareness during all operations, we will also carry a handheld radio to communicate directly with Purdue University’s Air Traffic Control (ATC) Tower. Maintaining this line of communication ensures that ATC is aware of our operations and can provide timely updates or instructions regarding nearby manned aircraft. In the event of an emergency or unexpected deviation, immediate coordination with the tower will help mitigate any potential risks to manned aviation activity in the area. Additionally, since our proposed flight area lies within the approach corridor of the VOR-A procedure into Purdue University Airport, we will also maintain communication with Grissom Approach. This coordination will ensure that both controlling agencies are fully informed of our activities and can provide traffic advisories as needed.
Risk Assessment Matrix for proposed operation
4: Ground Risk Mitigation
Ground Risk will be minimized through strict access control, equipment reliability, and defined emergency procedures. The launch and recovery area we are utilizing will be a cleared open field within a .5 NM radius near the ASREC Poultry Unit. Only authorized SATT (School of Aviation Transportation Technology) personnel will be present, all wearing reflective vests for high visibility. A safety perimeter using cones will be used to restrict access to non-participants.
Prior to each flight performed, the rPIC will inspect the sight of obstacles to verify weather suitability, and confirm that no people, vehicles, or livestock are within the area. The takeoff and landing zone will remain clear of structures, power lines, and any other debris. VOs will monitor both airspace and ground area for any potential incursions and will immediately notify the PIC to terminate the flight if safety is compromised. The Believer will undergo pre- and post-flight inspections to ensure a full system of integrity. Batteries, link connections, and control surfaces will be verified before takeoff. In the event of a lost link or control failure, the aircraft will automatically execute a return home (RTH) to the Lauch or selected point. If that is not possible, the rPIC will direct a controlled decent into a pre-identified area in the field of use of the operating zone.
The operations will only take place during daylight VFR conditions with winds under 15 knots and no precipitation or convective activity. After landing, power will be disconnected before approaching, and a short debrief will be conducted to make sure any issues or safety concerns are taken care of before the next mission. An overview of the area of practice and the lateral boundaries of the proposed operation can be seen in the below image.
5: Air Risk Mitigation
The process of air risk mitigation takes place continuously during the flight. The RPIC is primarily responsible for ensuring the aircraft follows the desired flight path and that its attitude, speed, altitude, and heading are appropriate for the phase of flight. As such, the RPIC will spend most of their time looking either directly at the aircraft itself, or cross-referencing the instruments presented by the GCS.
The visual observers will be watching the aircraft along with the RPIC. The VOs are also capable of monitoring external factors as they are not constantly managing the aircraft’s flight path. As such, they will be primarily responsible for calling out any potential conflicts or hazards with the aircraft itself, as well as outside factors.
Before flight, the crew must arrive at a consensus that weather conditions are suitable and that the RPIC selected for the flight has the skills necessary to operate the aircraft safely. In any situation where the weather presents an unacceptable risk, this will be communicated by the visual observers or the RPIC, and the flight will be discontinued.
Our area of operation is uncongested at the altitudes we are requesting. In the case that a manned aircraft enters within 100 ft of our maximum altitude, the aircraft will be avoided, and flight will be discontinued until the aircraft passes. The visual observers will be primarily responsible for monitoring the airspace for potential incursions.
The RPIC is primarily responsible for ensuring that the aircraft is in a condition for safe operation during the flight. If a system failure occurs which jeopardizes the safety of the operation, then the RPIC has the discretion to discontinue the flight. In a lost link scenario, the RPIC will attempt to regain connection. If the RPIC manages to establish link, then they are to discontinue the flight while ensuring the aircraft remains as close to the GCS as practicable to ensure adequate link during the approach and landing.
Distance to Purdue University Airport
VOR-A at Purdue Airport with ASREC location markings
The above three images show the ASREC area in question, and it is apparent that there will be no major issues with the airspace in which the flight intends to take. In the first of the three images, it is apparent that the ASREC area is not within the class D airspace of Purdue University Airport (nor is it within LAANC range). The second image highlights the distance of ASREC to the airport, which is approximately 6 nautical miles. The third image shows the VOR-A approach plate, which highlights manned aircraft flight over the approach corridor in which the ASREC area resides. It was found that with the approximate ground elevation (700’ MSL) and proposed flight altitude (750’ AGL) that the Believer would fly at around 1,550’ MSL, which would allow for at least 500’ of separation from manned aircraft at that stage in the approach.
6: Communication
The purpose of this portion is to ensure continuous, clear, and reliable communication between all members of the flight crew and relevant external agencies such as ATC. During operations above 400 feet AGL, this plan minimizes the risk of miscommunication that could compromise airspace safety of flight operations, and supports safe operations in compliance with all applicable waiver conditions.
All communication between RPIC and visual observers will be conducted verbally using standard aviation phraseology. As a backup we will all have cell phones on us in the event the surrounding area noise is too much for us to talk effectively. This is not a major concern since we will be performing operations in a relatively quiet area, and we’ll be in close proximity to rely on verbal communication. The VO will continuously report any observed manned aircraft or potential hazards, and the RPIC will immediately descend if a crew member reports an airspace conflict.
Prior to each operation, we will contact Lafayette (KLAF) tower to confirm mission times, altitude, and boundaries of the operational area. The RPIC will monitor the assigned ATC frequency for real-time coordination if required. In the case of loss of control, near miss, or other airspace hazard, the RPIC will notify ATC immediately.
If the ability to verbally communicate is lost, VO’s will use visual signals to direct the RPIC to land the aircraft. If ATC contact is lost during coordinated operation, the RPIC will immediately descend below 400 feet AGL until communication is restored. The RPIC will retain soul authority to terminate the flight if communication failure or confusion occurs.
All personnel involved in the flight operations will partake in a pre-mission brief covering procedures and roles of flight crew members, such as emergency response and ATC contact protocols. Prior to each flight, a communications check will be performed between all crew members. It must be restated, however, that most communication between crewmembers will be verbal since all will be in close physical proximity.
7: Safety Justification
Safety needs to be the primary objective of any operation in aviation, and it is certainly the primary goal of this operation. All remote pilots in command have experience in risk assessment during unmanned aircraft flights, and most have several Part 61 pilot certificates as well. Special care was taken to thoroughly examine all risks on the ground and in the air for this operation, and mitigations for each were thoughtfully planned out. Situational awareness, maintained by careful planning, lengthy preflight checks, continuous communication, and visual scanning, will be the main tool which we will use to ensure safety of this operation.
The safety of the aircraft will be ensured first by careful assembly of parts in the coming weeks. This assembly will be completed under the supervision of staff at Purdue University, and the function of components will be tested before this operation commences. Before flight, a thorough checklist will be created and used to confirm the reliability and function of flight components before takeoff. During the flight, the well being of the aircraft will be closely monitored by operators with the use of telemetry and status indicators on the flight controller.
The safety of the operation in general will be maintained primarily through constant surveillance of threats to safety and communication of those threats. To ensure no factor gets overlooked, operators will use the PAVE acronym for risk assessment which stands for Pilot, Aircraft, enVironment, and External factors. This acronym ensures no risk area of the operation is forgotten from start to finish. All operators will have the ability to call and message each other, but primarily, the operators will be in close enough physical proximity that they can speak to each other in person. All operators will be able to use cell phones to call the ATC tower at Purdue University Airport, the ASREC Poultry Unit staff, as well as Purdue University staff. In the event of an emergency resulting from a wide array of malfunctions and hazards, contingency planning is in place and ready to use. All remote pilots in command will be briefed and trained in emergency procedures, and any other nearby flight operations will know of normal and emergency operations conducted as early as possible.
In the time until the proposed operation begins, the crew will continue to train on related matters to this operation as well as gain further familiarity with the Makeflyeasy Believer platform. Safety strategies and skills will be enhanced further in that time, and the next major item to become familiar with is the checklist. Additionally, if this application is not accepted and approved, this will prove to be a good learning moment to understand ways to improve the safety and efficiency of operations. Overall, critical lessons will be learned from this process no matter the outcome.