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Lab 6 - Altitude Waivers

Group Members -

Nolan Lach, Jacob Sieber, Ryan Pirro, Elijah Meadows, Madison Baker, & Venkata Devapatla

This lab focused on understanding the process of requesting an operational waiver under 14 CFR Part 107, specifically for operations above 400 ft AGL using the MFE Believer aircraft. The workspace outlined the aircraft specifications, the applicable regulation being waived, and the overall concept of operations required for an FAA waiver submission.

A key part of the assignment was identifying potential hazards and outlining mitigation strategies through a safety risk assessment. This included considerations such as air traffic awareness, weather conditions, aircraft reliability, and the use of visual observers. Together, these elements demonstrated how an operation above standard altitude limits could be conducted safely and responsibly.

After reviewing the submitted waivers, the FAA ultimately canceled the individual waiver requests. Instead, they decided to work directly with us to hold a workshop next semester. The goal of this workshop is to develop a single, comprehensive waiver that will apply to the entire class, rather than having each group submit separate requests.

Overall, this experience provided insight into the complexity of FAA waiver process, helping me in my future academics and career.

Altitude Waiver

This assignment was completed by group 4 which consists of Nolan Lach, Elijah Meadows, Ryan Pirro, Madison Baker, Venkata Devapatla, and Jacob Sieber. We are working to submit a part 107 waiver to fly the MFE Believer, and more specifically, we are trying to fly it higher than 400’ AGL. This aircraft has a recommended takeoff weight of 4.2kg (9.2lbs) and a maximum takeoff weight of 5.5kg (12lbs). The flight duration will be approximately 2.0 hours, and the speed will be approximately 40 knots. The wingspan is 1,960mm, the fuselage length is 1,070mm, and the fuselage height is 180mm.

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An airspace authorization permits an operator to conduct operations within controlled airspace. These are submitted to the LAANC system and the authorization is automatically processed and issued. An operational waiver is, in effect, asking permission to deviate from the regulations in 14 CFR. The responsibility is on the operator to justify the deviation, provide a risk assessment, and offer solutions to potential safety risks posed by the deviation. These are manually reviewed by the FAA, and can take up to 90 days to receive approval. An operational waiver would be required to deviate from the regulation under part 107 limiting UAVs to a maximum of 400ft AGL. We will be waiving 14 CFR 107.51(b), which is “operating limitations for small unmanned aircraft.”

In section 2 of the FAA Part 107 Waiver Homepage, several specific points that evaluators are looking for in a waiver submitted to fly higher than 400 ft are described. For instance, the evaluator focuses their efforts on reviewing the applicant’s concept of operations (CONOPS) and the operational hazard and risk analysis submitted by the applicant. A CONOPS should include a detailed description of the proposed sUAS operation, sUAS, operational procedures, operational location, operational limitations, hazards, risks, and risk mitigations. A risk analysis should include the severity of each hazard’s effect(s), likelihood of each hazard’s effect(s), risk mitigations, and predicted residual safety risk with all mitigations in place. An evaluator reviews the following:

The CONOPS to understand the proposed sUAS operation, location, limitations, and proposed procedures.

The applicants risk analysis document and each hazard’s effects before mitigations are applied as provided in the waiver application, and the severity and likelihood of each hazards effects after mitigations are applied. FAA orders 8040.4 and 8040.6 provide examples and instructions on performing a risk assessment and definitions which may be used for severity and likelihood.

The rationale and supporting data provided by the applicant to substantiate how each mitigation reduces the severity or likelihood of each hazards effects or risk to an acceptable level.

The applicant’s predicted operational risk after mitigations are applied to the sUAS operation.

Safety Risk Assessment and Mitigation Steps

Safety Risk Assessment and Mitigation Steps

Hazard

Cause

Effect

Likelihood (1)

Severity (2)

Risk (3)

Mitigation

Emergency or Contingency Procedures (4)

Poor Weather

Atmospheric change

Loss of visibility or control

Moderate

Monitor forecasts and observations

Land or do not take off

Obstacles and obstructions

Light posts and fences

Collision risk

Low

High

Moderate

Scan for obstacles visually

Fly far above obstacles and possibly return home

Condition of Equipment

Deterioration of parts

Loss of controllability

low

moderate

low

Maintain equipment regularly

Land

Fatigue

Demanding schedule, sleeplessness

Forgetfulness, poor concentration

Moderate

Rest well, be in une with oneself

Cancel the flight or switch pilots

Terrain

Geographical changes

Possible flight into terrain

Low

Moderate

Low

Understand the flight area well beforehand

Return to home

Air Traffic

Small planes

Possble mid-air collisions

Low

High

Moderate

Monitor aircraft radio frequency

Maneuver to avoid traffic, land

Flight over people

Researcher presence

Poor regulation adherence, risk of collision

Low

Moderate

Low

Communicate with researchers

Maneuver to avoid people

Battery issues

Loss of charge

Premature flight conclusion

Moderate

Ensure batteries are charged fully and replaced accordingly

Return to home

Airspace permissions

Flying illegally or without permission

Certificate action

Low

Plan flight area thoroughly

Do not take off, land soon

Regulatory violation liability

Negligence, maliscious intent

Fines, legal action, certificate action

Low

Moderate

Low

Plan the flight well

Do not takeoff, land imeediately

Animals

Animals being researched at the facility

Stress to the animals, collisions

Moderate

Watch visually for animals

Fly over the hazard

Noise pollution

Operation of unmanned systems

Disturbances to people and wildlife

Low

Fly at an optimal time of day, limit sound profucing activities

Fly only as necessary and return promptly to starting point when finished

Line of sight violations

Failure to maintain visual line of sight

Regulatory compliance issues, compromised awareness

Low

Moderate

Low

Assign and follow roles well

Return to home ro try to regain line of sight

Control link loss

Loss of connection between system components

Loss of control of aircraft

Low

Moderate

Proper RTH settings

Return to home

There are no rows in this table

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1. Refer to the Part 107 Waiver Safety Explanation Guidelines and Guiding Questions document. Copy the five questions below and develop your responses to each of the questions. Refer to the Representative Sample of an approved waiver application for 14 CFR 107.51(b) as a guide for answering the five questions.

Question 1: Describe how the small unmanned aircraft (sUA) will be able to avoid non participating aircraft and structures when operating at altitudes other than those prescribed in Title 14, Code of Federal Regulations (14 CFR) § 107.51(b).

The RPIC will be able to avoid non-participating aircraft and structures when operating with a limit of 800 feet AGL, using a combination of several methods.

Geo fencing will be preset to avoid any trees, power lines and other structures in the flight area. As well as a limit to the altitude of no higher than 750 feet AGL, allowing a 50-foot buffer for altitude and measuring errors. Our lateral limit will be set so that we will not be operating beyond visual line of site of the sUA from the ground control station. As seen from the attached overhead view, there are few obstacles to consider at this site.

A Visual observer will assist with the avoidance of both structures and any non-participating aircraft. These may include another sUA or manned aircraft, such as GA airplanes or helicopters. Should an aircraft approach the flight area, it would first be noticed first by the aural sound of engine noise. The RPIC would immediately lower the altitude to below 400 feet AGL. Upon sighting of another aircraft by the VO or RPIC action would be taken to either land or decrease altitude to 50 feet AGL until the area is clear of any risk. The VO will use specific language to alert the RPIC of an encroaching aircraft or if he/she believes that the sUA is too close to a structure of obstacle. We will conduct a pre- brief about the communication to be used so there is no confusion during the planned flight. The landing zone would be preplanned, and with our small working area it would most likely be the same as our takeoff zone.

The RPIC will use the ground control station to monitor the sUA’s altitude and location in proximity to the trees. These trees will be marked on the viewable page as an area to avoid. The sUA will also be equipped with a GPS receiver and a telemetry system, continuously sending position data to the ground controller.

For aircraft avoidance, that is an imminent threat of collision. The RPIC will maintain altitude and make an assessment as to whether it is best to maintain the given altitude up to 800 feet AGL or make a quick descent. In no case should the sUA be descended when the non-participating aircraft is lower than the sUA. Making a turn to avoid collision would be a good yielding method.

Question 2: Describe the area of operations using latitude/longitude, street address, identifiable landmarks, or other maps to include the distance from and direction to the nearest airport (e.g., 4.8 miles SE of XYZ Airport). - In addition to filing a NOTAM, describe how the RPIC will communicate/coordinate with Air Traffic Control (ATC) if required by a Special Provision in your Certificate of Waiver and based on the complexity of your operation.

The Animal Science Research and Education Center area is located in West Lafayette, Indiana at the following location: 40.4937110, -87.0092924. A NOTAM issued 48 hours in advance will list the location with the longitude and latitude shown, as well as the BVT 155 radial roughly 7 nm northwest of KLAF. The intended area is a .1 nm circle around the location. We will be airborne for no longer than 1 hour each flight, to preclude battery exhaustion. The best way for us to stay in touch with ATC would be handheld radios tuned to the correct frequency. Please reference the attached map.

Question 3: Describe how all manned aircraft pilots are able to detect and avoid the small unmanned aircraft (sUA) and know they must yield the right-of-way to the sUA. How will operators of other aircraft know they need to give way to your sUA in flight? - What procedure will you use to ensure the operator of the manned aircraft is aware the sUA does not need to yield the right-of-way? How will operators of other aircraft visually locate your sUA inflight?

We will use a NOTAM posted 48 hours prior to flight to the local airport. This way, all traffic in the area will be notified that we are flying our sUA. The aircraft can be seen in flight visually, given that it is white.

Question 4: Describe how you will account for the communication latency between the Visual Observer(s) (VO) and the Remote Pilot in Command (RPIC).

To ensure safe and timely communication between the Visual Observer(s) (VO) and the Remote Pilot in Command (rPIC) during operation, we will implement a structured communication protocol designed to minimize latency and maintain situational awareness at all times. The VO(s) will be positioned to maintain continuous visual contact with the aircraft and have unobstructed lines of sight both to the aircraft and to the rPIC when possible. Since we have six people in our group we will have more than one VOs. To ensure at least one person will have sight of the drone at all times. If for any reasons the RPIC and VO needs to be at different places we will have another person with the RPIC who is in active communication with the VO, probably using a phone or a radio.

Question 5: Describe how the RPIC will be able to accurately determine the sUA altitude, attitude, and direction of flight.

On the Ground Control Station (GCS), the display provides the small Unmanned Aircraft’s (sUA) altitude, attitude, and direction of flight. To ensure there are no faulty readings, the Remote Pilot in Command (rPIC) and Visual Observer (VO) will confirm that all system calibrations, such as compass, IMU, and GPS, have been properly completed before flight.

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