PRE-FLIGHT	CHECKLIST

1.	Weather	conditions	are	suitable	for	VFR	flight	and	wind	is	18	mph	or	less.	

2.	Measure	battery	voltage	to	make	sure	batteries	are	sufficiently	charged	before	takeoff.

3.	Verify	that	all	wiring	connections	are	tight.

4.	Raise	and	lock	all	rotor	arms.	Inspect	for	cracks,	damage,	and	loose	hardware.

5.	Check	to	make	sure	propellers	are	secure	and	free	from	dirt,	cracks	and	chips.	

6.	Install	main	battery	and	check	balance.

7.	Turn	on	camera	equipment.

8.	Verify	all	switch	positions	on	the	RC	transmitters.	Generally	they	are	all	in	the	forward	

position	with	the	exception	of	the	Mode	which	should	be	set	to	“GPS”.

9.	Turn	on	radio	control	transmitters	and	video	equipment.	

10.	Connect	the	UAS	main	battery.	Check	for	radio	connection	with	RC	transmitters	and	

video	downlink.	11.	During	warmup,	check	the	A2	Flight	Controller	LED	indicator.	One	

green	flash	indicates	GPS	mode.	Wait	for	both	of	the	following	LED	indications:	a.	A	string	of	

10	or	more	green	flashes	indicating	that	the	forward	direction	has	been	recorded.	b.	2	or	

less	red	flashes	to	indicate	that	5	or	more	GPS	satellites	have	been	obtained.	This	may	also	

be	observed	in	the	video	telemetry	information.	

12.	Announce	your	intention	to	take	off	by	announcing	“Take	Off”.

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN 

EXEMPTION 

A. 14 C.F.R. §§ 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in 

Command. 

These	regulations	limit	private	pilots	to	non-commercial	operations.	Because	the	UAS	

will	not	carry	a	pilot	or	passengers	and	be	operated	within	limited	areas	and	altitudes,	

the	proposed	operations	can	achieve	the	equivalent	level	of	safety	of	current	operations	

by	requiring	the	PIC	operating	the	aircraft	to	have	a	private	pilot’s	license	rather	than	a	

commercial	pilot’s	license	to	operate	this	small	UAS.

B. 14 C.F.R. § 91.7(a) Civil Aircraft Airworthiness 

While the UAS will not have an airworthiness certificate in accordance with 14 C.F.R. part 

21, Subpart H, the airworthy condition of the UAS will be the responsibility of the PIC in 

accordance with 14 C.F.R. § 91.7(b). 
C. 14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and other areas 

This regulation establishes safe altitudes for operation of civil aircraft over areas other than 

congested areas. BEAP requests relief from this section with respect to persons involved in 

the operation as well as vehicles and structures. The UAS will not be operated above 400 feet 

altitude. It will be operated in a defined area where people and buildings will not be exposed 

to operations without their pre-obtained consent. 

D. 14 C.F.R. § 91.121 Altimeter Settings 

This	regulation	requires	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	the	UAS	does	not	have	a	

barometric	altimeter,	an	exemption	is	requested.	The	UAS	Flight	Controller	utilizes	GPS	

equipment	aided	by	a	static	pressure	sensor	to	determine	and	maintain	altitude.	The	

aircraft	altitude	above	the	takeoff	point	is	provided	in	the	video	downlink	telemetry	

information	and	provides	sufficient	information	for	the	PIC	to	maintain	altitudes	at	or	

below	the	400	foot	(122	meter)	limitations.

E. 14 C.F.R. § 91.151(a) Fuel requirements for flight in VFR conditions 

Section	91.151(a)	prohibits	an	individual	from	beginning	“a	flight	in	an	airplane	under	

VFR	conditions	unless	(considering	wind	and	forecast	weather	conditions) there	is	

enough	fuel	to	fly	to	the	first	point	of	intended	landing,	and,	assuming	normal	cursing	

speed	– (1)	During	the	day	to	fly	after	that	for	at	least	30	minutes;	or	(2)	At	night,	to	fly	

after	that	for	at	least	45	minutes.”

Given	that	the	UAS	aircraft only	fly	for	a	maximum	of	20	minutes	and	typically	carry	

about	15	minutes	of	batter	power,	an	exemption	is	requested.	The	UAS	operations	are	

always	conducted	within	a	few	minutes	of	the	takeoff	and	landing	point	and	within	a	

restricted	area.	BEAP	believes that	terminating	the	flight	with	25%	remaining	battery	

power	provides	an	equivalent	amount	of	safety	that	is	intended	by	section	191.151(a).

F. 14 C.F.R. § 91.405(a) Maintenance Required; 

14 C.F.R. § 91.407(a)(1) Operation after maintenance, preventative maintenance, rebuilding 

or alteration;

14 C.F.R. §§ 91.409(a)(1) and (2) Inspections;

14 C.F.R. §§ 91.417(a) and (b) Maintenance Records 
These regulations require that an aircraft operator or owner “shall have that aircraft inspected 

as prescribed in subpart E of this part and shall between required inspections, except as 

provided in paragraph (c) of this section have discrepancies repaired as prescribed in part 43 

of this chapter...,” and others shall inspect or maintain the aircraft in compliance with part 

43. 

Given that the sections and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the Petitioner. Maintenance will be accomplished by the 

operator pursuant to the Owner’s Manuals. An equivalent level of safety will be achieved 

because these small UAS are very limited in size and will carry a small payload and operate 

only in restricted areas for limited periods of time. If mechanical issues arise, the UAS can 

land immediately and will be operating from no higher than 400 feet AGL. The operator will 

ensure that the UAS is in working order prior to initial flight, perform required maintenance 

and keep a log of any maintenance performed. Moreover, the operator is the person most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to 

provide the equivalent level of safety. The FAA issued exemption to these regulations in 

Exemption No. 11062.

SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER 

Petitioner: Brian Jones iDream Images, LLC. 

Sections of 14 C.F.R Affected: §§ 61.113(a) and (b); § 91.7(a); § 91.119(c); § 91.121; § 

91.151(a); § 91.405(a); § 91.407(a)(1); §§ 91.409(a)(1) and (2); §§ 91.417(a) and (b)

Description of Relief Sought: Brian Jones iDream Images, LLC. seeks relief from the 

requirements of 14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 

14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 

14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b) to operate small unmanned 

aircraft systems (UAS) for the purpose of aerial photography, videography, and 

photogrammetry. 

Submitted By,

Brian Jones

Owner

iDream Images

322 Devon Rd

Chillicothe, OH 45601

Phone: 740-701-6989