October 8th, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE, 

West Building Ground Floor, Room W12-140, 

Washington, DC 20590 

Re: Request for Exemption under Section 333 ofthe FAA Modernization and Reform 

Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 61.23(a) and (c); 

61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 

91.407(a)(1 ); 91.409(a)(1) and (2); 91.417(a) & (b). 

PETITION FOR SUMMARY EXEMPTION 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the 

Reform Act) and 14 C.F.R. Part 11, Unreal Freedom, LLC, an operator of Small 

Unmanned Aircraft (UA) hereby applies for an exemption from the listed Federal 

Aviation Regulations ("F ARs") to allow commercial operation of its UA. Unreal 

Freedom, LLC is eligible for a summary exemption for aerial data collection and closed 

set/scripted filming; please reference exemptions #11440 and #11482. 

QillCK REFERENCE SUMMARY 

:rype ofUA to be flown: 

• Rotary-Wing (Electric Multi-Rotor) 

Manufacturer: 

• Unreal Freedom 

Model 

• Mary 5 

• Mary 6 

• Mary 7 

Weight: 

45 pounds 

9 pounds 

18 pounds 

The operations will be for: Aerial Data Collection & Closed Set/Scripted Filming 

• Surveying 

• Inspections 

• Aerial Cinematography 

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., 
The Petitioner will operate under the restrictions listed below and those in the 

confidentially submitted operating manuals and MPTOM. 

The Petitioner agrees to all the restrictions in Exemption# 11784 which are listed below. 

KINOFLY REQUESTS THAT THE PUBLICATION AND COMMENT 

PROCEDURES BE WAIVED IN ACCORDANCE WITH 14 C.F.R. § 11.87. 

§ 11.87 Are there circumstances in which FAA may decide not to publish a summary of 

my petition for exemption? 

The FAA may not publish a summary of your petition for exemption and request 

comments if you present or we find good cause why we should not delay action on your 

petition. The factors we consider in deciding not to request comment include: 

(a) Whether granting your petition would set a precedent. 

(b) Whether the relief requested is identical to exemptions granted previously. 

(c) Whether our delaying action on your petition would affect you adversely. 

(d) Whether you filed your petition in a timely manner. 

Corresponding to the above sub-sections, Unreal Freedom has good cause to 

request the FAA to waive the comment period and not delay action on the petition 

because: 

(a) Unreal Freedom, LLC would not set any precedent. Unreal Freedom, LLC agrees to 

the SAME exact limitations as Exemption# 11784. 

(b) The relief requested is identical to that granted, without publication for comment, in 

Exemption # 11784. 

(c) Delaying the granting of this petition would adversely affect the public, the FAA, and 

Unreal Freedom, LLC The public, as well as the FAA, would be better served by the 

FAA quickly granting this petition and thereby freeing up limited FAA resources and 

allowing FAA inspectors to dedicate their time and attention to much higher priorities. 

Moreover, Unreal Freedom, LLC is adversely affected by the below listed regulations. 

(d) The petition has been filed in a timely manner. 

PUBLIC BENEFIT 

This exemption will allow commercial operations ofUA's that will enhance safety 

by reducing risk. The alternative to using a UA is to use a jet or piston power aircraft 

carrying large amounts of Jet A or 1 OOLL. Not only is the operation dangerous at the 

location, the aircraft must fly to the location and back to the home airport. The UA will 

weigh less than 55 lbs. and powered by batteries that eliminates most of the risk because 

no highly flammable fuel will be involved. There are no pilots on board the UA and due 

to the small size of the UA, there is less risk posed to the public on the ground in case of 

an emergency. 

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Manned airplanes and helicopters produce a large amount of noise pollution when 

operating at low altitudes that disrupts the quiet enjoyment of the public on the ground. 

UA are much quieter and will not disrupt the public as much as manned aircraft; thus, the 

public will benefit from their use. Additionally, the UA has multiple motors, providing 

redundancy, while most manned aircraft have only one engine. The operations of the U A 

listed under the restrictions proposed herein will provide an equivalent level of safety as 

the Federal Aviation Regulations. 

PETITIONER'S CONTACT INFO: 

Unreal Freedom, LLC 

Attn: 

Email: 

Tony Thompson 

unrealfreedomllc@gmail.com 

Address: 901 W Alondra Blvd. Hangar R-1 D 

Compton, CA 90220 

REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED 

14 C.F.R. § 61.23(a) and (c) 

14 C.F.R. § 61.101(e)(4) and (5) 

14 C.F.R. § 61.113(a) 

14 C.F.R. § 61.315(a) 

14 C.F.R. § 91.7(a) 

14 C.F.R. § 91.119(c) 

14 C.F.R. § 91.121 

14 C.F.R. § 91.15l(a)(1) 

14 C.F.R. § 91.405(a) 

14 C.F.R. § 91.407(a)(l) 

14 C.F.R. § 91.409(a)(l) & (2) 

14 C.F.R. § 91.417(a) & (b) 

OPERATING DOCUMENTS 

Unreal Freedom, LLC will operate only within the limitations below and the 

limitations listed in the confidentially submitted operating manuals and MPTOM. The 

limitations below, from the previously granted exemption, will be followed if there is a 

conflict with the operating manual. 

STATUTORY AUTHORITY TO GRANT THIS PETITION 

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority by its terms includes exempting civil aircraft, as the 

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term is defined under§ 40101 of the Act that includes UAS's, from the requirement that 

all civil aircraft must have a current airworthiness certificate. "The Administrator may 

grant an exemption from a requirement of a regulation prescribed under subsection (a) or 

(b) of this section or any sections 44702-44716 of this title if the Administrator finds the 

exemption in the public interest." 49 U.S.C. § 44701(f). See also 49 U.S.C. § 44711(b). 

This exemption petition is expressly submitted to fulfill Congress' goal in passing 

Section 333(a) through (c) ofthe FAA Modernization and Reform Act of2012. This law 

directs the Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in the national airspace system (NAS) before completion of 

the rulemaking required under Section 332 ofthe FAA Modernization and Reform Act. 

In making this determination, the Secretary is required to determine which types ofUA 

do not create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following: 

• The UA's size, weight, speed, and operational capability; 

• Operation of the UA in close proximity to airports and populated areas; and, 

• Operation of the UA within visual line of sight of the operator (VLOS). 

If the Secretary determines that such vehicles "may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system." ld. § 333(c) (emphasis added). 

The FAA has already established requirements for summary grants that will be 

further discussed below. Applicant interprets this provision to place the duty on the 

Administrator to not only process applications for exemptions under section 333, but for 

the Administrator to craft conditions for the safe operation of the UAS, if it should be 

determined that the conditions set forth herein do not fulfill the statutory requirements for 

approval. 

EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein applies to civil aircraft 

that have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure. 

These limitations and conditions are identical to Exemption # 11784 except for the 

difference in aircraft. Unreal Freedom, LLC agrees to be bound when conducting 

commercial UA operations. The list oflimitations and conditions include the following: 

1. Operations authorized by this grant of exemption are limited to the Unreal Freedom 

Mary 5, Mary 6, and Mary 7; all of which weigh less than 55 pounds including payload. 

Proposed operations of any other aircraft will require a new petition or a petition to 

amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are 

permitted as specified in the MPTOM. 

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3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum U A operating airspeed recommended by the aircraft 

manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC's FAA-issued airman medical certificate or 

U.S. driver's license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The 

VO and PIC must be able to communicate verbally at all times; electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before the 

flight and cannot transfer his or her designation for the duration of the flight. The PIC 

must ensure that the VO can perform the duties required ofthe VO. 

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, the 

conditions and limitations herein take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operating documents. The operator 

may update or revise its operating documents. It is the operator's responsibility to track 

such revisions and present updated and revised documents to the Administrator or any 

law enforcement official upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment to this grant of exemption. 

If the operator determines that any update or revision would affect the basis upon which 

the FAA granted this exemption, then the operator must petition for an amendment to its 

grant of exemption. The FAA's UAS Integration Office (AFS- 80) may be contacted if 

questions arise regarding updates or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with aVO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property. 

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9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g. inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer's maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver's license issued by a state, 

the District of Colombia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 14 CFR 

§ 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 14 

CFR § 61.51(b). Flights for the purposes oftraining the operator's PICs and VOs 

(training, proficiency, and experience- building) and determining the PIC's ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under 

this exemption are permitted under the terms of this exemption. However, training 

operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations 

are considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) 

as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

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denoted with an ARP~ the center of the airJ>ort symbol as denoted on the current FAA 

published aeronautical chart, unless a letter of agreement with that airport's management 

is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of 

agreement with the airport management must be made available to the Administrator or 

any law enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2~000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAloses communications or loses its GPS signal, the UA must return to a 

predetermined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an A TO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of the attached CO A. 

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (N 

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as 

large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS 

and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request. 

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UA may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UA and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

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operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each 

flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 

Unreal Freedom's UA are rotorcraft, weighing 55 lbs. or less including payload. 

They operate, under normal conditions at a speed of no more than 50 knots and they have 

the capability to hover, and move in the vertical and horizontal plane simultaneously. 

They will operate only within VLOS and only within the restrictions above and the 

confidentially submitted manual. Such operations will insure that the UA will "not create 

a hazard to users of the national airspace system or the public." 

Given the small size of the UA involved and the restricted sterile environment 

within which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations ofUA to commence immediately. Also, due to 

the size of the UA and the restricted areas in which the relevant UA will operate, 

approval of the application presents no national security issue. 

Since the UA fully loaded weighs no more than 55lbs. and is operated without an 

onboard pilot, there is no ability or place to carry certification and registration documents 

or to display them on the unmanned aircraft. An equivalent level of safety will be 

achieved by keeping these documents at the ground control point where the pilot flying 

the UA will have immediate access to them. Also, given the size of the unmanned 

aircraft, the FAA registration number will be displayed on the airframe in as large a font 

as possible. 

REGULATIONS FROM WHICH EXEMPTION IS NEEDED 

14 C.F.R. § 61.23(a) & (c): Medical Certificates 

Exemption# 11221, # 11284, and many others have provided that a U.S. driver's 

license could be used in lieu of the medical certificate provides an equivalent level of 

safety. 

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14 C.F.R. § 61.101(e)(4) & (5): Recreational Pilot Privileges and Limitations & 14 

C.F.R. § 61.315(a): Sport Pilot Limitations. 

Exemption# 11221, # 11284, and many others have declared that there is an 

equivalent level of safety as the FAR's by requiring the PIC to "hold either an airline 

transport, commercial, private, recreational, or sport pilot certificate." Likewise, KinoFly 

is also performing commercial UAS work and is asking for the same restrictions which 

have been previously deemed to provide an equivalent level of safety as the burdensome 

regulations. 

14 C.F.R. § 61.113 (a): Private Pilot Privileges and Limitations: Pilot In Command. 

Sub-sections 61.113(a) limit private pilots to non-commercial operations. Because 

the UA will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft 

to have a sport pilot license rather than a commercial pilot's license to operate this small 

UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UA is 

remotely controlled with no living thing on board. 

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

As there will be no airworthiness certificate issued for the unmanned aircraft, and 

no FAA regulatory standard will exist for determining airworthiness of the UA, the 

requirements contained in the confidentially submitted manual and the restrictions 

already agreed to will provide an equivalent level of safety. 

14 C.F.R. § 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes 

prescribed for helicopters by the FAA. Because of the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with 

conventional aircraft operating at or below 500 AGL. In addition, the low-altitude 

operations ofthe UAS will ensure separation between these small UAS operations and 

the operations of conventional aircraft that must comply with Section 91.119. 

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 ofthe departure airport 

or an appropriate altimeter setting available before departure." As the U AS may not have 

a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to following the 

confidentially submitted manual. Furthermore, many other petitions have been granted 

allowing GPS to be used in lieu of an altimeter setting. 

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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 cruising 

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." 

Applicant believes that an equivalent level of safety can be achieved by restricting 

operations to "the intended operation and to operate after that for at least five minutes or 

with the reserve power recommended by the manufacturer if greater." Exemption# 

11284, at page 5. 

14 C.F.R. § 91.405 (a); § 91.407 (a) (1); § 91.409 (a) (2); § 91.417(a) & (b): 

Maintenance Inspections 

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) ofthis section, have discrepancies repaired as 

prescribed in part 43 of this chapter"5 and others shall inspect or maintain the aircraft in 

compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with 

an airworthiness certificate, these sections will not apply to the applicant. An equivalent 

level of safety will be achieved because these small UAS's are very limited in size and 

will carry a small payload and operate only in restricted areas for limited periods of time. 

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. 

Lastly, the petitioner will operate in accordance with the confidentially submitted manual 

that will provide an equivalent level of safety as the burdensome regulations. 

CONCLUSION 

The operation ofUnreal Freedom's small UAS, weighing less than 55lbs., 

conducted under the proposed restrictions outlined above as well as the confidentially 

submitted manuals, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein. 

Sincerely yours, 

-, /fny Thompson 

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