October 8th, 2015 U.S. Department ofTransportation Docket Management System 1200New Jersey Ave., SE, West Building Ground Floor, Room W12-140, Washington, DC 20590 Re: Request for Exemptionunder Section 333 oftheFAAModernization and Reform Act and Part 11 ofthe 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 orMadam: Pursuant to Section 333 ofthe FAAModernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Unreal Freedom, LLC, an operator ofSmall Unmanned Aircraft (UA) hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits 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. QillCKREFERENCE SUMMARY :rype ofUAto 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 DataCollection & Closed Set/Scripted Filming

• Surveying • Inspections • Aerial Cinematography

1 .,The Petitioner will operate under the restrictions listed below and those inthe confidentially submitted operating manuals andMPTOM. The Petitioner agrees to all therestrictions inExemption# 11784 which are listed below. KINOFLY REQUESTS THAT THE PUBLICATION AND COMMENT PROCEDURES BE WAIVED IN ACCORDANCE WITH 14 C.F.R. 

### § 11.87. 

### § 11.87Arethere circumstances inwhich FAA may decide not to publish a summary of mypetition for exemption? The FAA may notpublish a summary ofyourpetition for exemption and request comments ifyou present orwe find good cause why we should not delay action on your petition. The factors we considerin deciding not to request comment include: (a) Whether granting your petition would set a precedent. 

### (b) Whetherthe reliefrequested is identical to exemptions grantedpreviously. (c) Whetherourdelaying action onyourpetitionwould affect you adversely. (d) Whether youfiled yourpetition in a timely manner. Correspondingto the above sub-sections, Unreal Freedom has good causeto requestthe FAAto waive the commentperiod andnot delay action onthe 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 reliefrequested is identical to that granted, withoutpublicationfor comment, in Exemption # 11784. (c) Delaying the granting ofthis petitionwould adversely affectthepublic, the FAA, and Unreal Freedom, LLC The public, as well as the FAA, would be better servedbythe FAA quickly granting this petition and thereby freeing up limited FAAresources and allowing FAA inspectors to dedicate theirtime and attention to muchhigher priorities. Moreover, Unreal Freedom, LLC is adversely affected bythe below listed regulations. (d) Thepetitionhas beenfiled 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 ajetorpistonpower aircraft carrying large amounts ofJet A or 1 OOLL. Notonly is the operation dangerous at the location, the aircraft mustfly to the location and backto the home airport. TheUA will weigh less than 55 lbs. andpoweredbybatteries that eliminates most ofthe riskbecause no highly flammable fuel will be involved. There are no pilots onboard the UA and due to the small size ofthe UA, there is less risk posed to the public on the ground in case of an emergency.

2Manned airplanes and helicopters produce a large amount ofnoise pollution when operating at low altitudes that disrupts the quiet enjoyment ofthe public onthe 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 ofthe UA listed under the restrictions proposed herein will provide an equivalent level ofsafety as the Federal Aviation Regulations.

PETITIONER'S CONTACT INFO: Unreal Freedom, LLC Attn: Email: Tony Thompson unrealfreedomllc@gmail.com Address: 901 W AlondraBlvd. Hangar R-1 D Compton, CA 90220 REGULATIONS FROMWHICH 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 inthe confidentially submitted operating manuals and MPTOM. The limitations below, from the previously granted exemption, will be followed ifthere is a conflict with the operating manual.

STATUTORYAUTHORITY TO GRANT THIS PETITION The Federal Aviation Act expressly grants the FAAthe authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the



### 3term is defined under§ 40101 ofthe 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 ofa regulationprescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administrator finds the exemption inthe public interest." 49 U.S.C. § 44701(f). See also 49 U.S.C. § 44711(b). This exemptionpetition 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 ofTransportation to consider whether certainunmanned aircraft systems may operate safely inthe 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 ofthe NAS orthe public orpose a threat to national security in light ofthe following:

• The UA's size, weight, speed, and operational capability; • Operation ofthe UA in close proximity to airports and populated areas; and, • Operation ofthe UA within visual line ofsight ofthe operator (VLOS).

Ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft inthe 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 onthe Administratorto not only process applications for exemptions under section 333, but for the Administratorto craft conditions for the safe operation ofthe UAS, ifit should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval. 

### EQUIVALENTLEVEL OF SAFETY The applicant proposes thatthe exemptionrequested 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 ofsafety to operations underthe currentregulatory 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 ofexemption are limited to the Unreal Freedom Mary 5, Mary 6, and Mary 7; all ofwhich weigh less than 55 pounds includingpayload. Proposed operations ofany other aircraft will require a newpetition or a petition to amend this exemption. 2. Operations for the purpose ofclosed-set motion picture and television filming are permitted as specified in the MPTOM.



### 43. The UA may not be operated at a speed exceeding 87 knots (100 miles perhour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UAbe operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UAmustbe operated at an altitude ofno more than 400 feet above ground level (AGL). Altitude mustbe reported in feet AGL. 5. The UAmust be operated within visual line ofsight (VLOS) ofthe 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 onthe 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 ofsight (VLOS) ofthe 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 mustbe 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 ofthe flight. The PIC must ensure thatthe VO canperform the duties required oftheVO. 7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated inthis grant of exemption, are hereinafter referredto as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator uponrequest. Ifa discrepancy exists betweenthe conditions and limitations inthis exemption and the procedures outlined in the operating documents, the conditions and limitations hereintake 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. Itis the operator's responsibilityto track suchrevisions 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 ifit petitions for extension or amendmentto this grant ofexemption. Ifthe operator determines that any update orrevision would affectthe basis upon which the FAA granted this exemption, then the operator mustpetition for an amendment to its grant ofexemption. The FAA's UAS Integration Office (AFS- 80) maybe contacted if questions arise regarding updates orrevisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa 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 mustremain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose anundue hazard to persons and property.



### 59. The operator is responsible for maintaining and inspectingthe 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. Thepre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has beenperformed 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 ofexemption, a PIC musthold 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 ofColombia, Puerto Rico, a territory, a possession, orthe 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 orher pilot certificate. 14. The operator may notpermit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with howthe UAS will be operated underthis 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 howthe UAS will be operated under this exemption are permitted under the terms ofthis 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 notbe 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 ofan airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) orfor airports not



### 6denoted with an

**ARP~** the centerofthe airJ>ort symbol as denoted on the current FAA published aeronautical chart, unless a letter ofagreement with that airport's management is obtained orotherwisepermittedby a COA issued to the exemption holder. The letterof agreement withthe airport management mustbe made available to the Administrator or any lawenforcementofficial upon request. 17. The UAmay not be operated less than 500 feet below orless than

**2~000** feet horizontally from a cloud orwhenvisibilityis less than 3 statute miles from the PIC. 18. Ifthe UAloses communications orloses its GPS signal, the UA mustreturn to a predeterminedlocation within the private orcontrolled-access property. 19. The PIC must abortthe flight inthe eventofunpredicted obstacles oremergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UAto conduct the intended operation and to operate after thatfor at least five minutes orwiththereserve power recommended bythe manufacturer ifgreater. 21. AirTraffic Organization (ATO) Certificate ofWaiver orAuthorization (COA). All operations shall be conducted in accordance with anATO-issued COA. The exemption holder may apply for a new oramended COA ifit intends to conduct operations that cannot beconducted underthe terms ofthe attached CO A. 22. All aircraft operated in accordance withthis exemption must be identified by serial number, registered in accordance with 14 CFRpart 47, and have identification (N Number) markings inaccordance with 14 CFRpart 45, Subpart C. Markings must be as large as practicable. 23. Documents usedbythe operatorto ensure the safe operation and flight ofthe UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC atthe Ground Control Station ofthe UAS any timethe aircraft is operating. These documents mustbe made available to the Administrator or any law enforcement official upon request. 24. The UAmustremain clear and give way to all manned aviation operations and activities at all times. 25. The UA may notbe operatedby the PIC from any moving device orvehicle. 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 presentthat sufficiently protect nonparticipatingpersons from the UAand/ordebris inthe event ofanaccident. The operator must ensure that nonparticipating persons remainunder such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight

7operations must cease immediately in a manner ensuring the safety ofnonparticipating persons; and b. The owner/controller ofanyvessels, vehicles or structures has grantedpermission for operating closerto those objects and the PIC has made a safety assessment ofthe risk of operating closer tothose objects and determined that it does not present anundue 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 orcontrolled-access property with permissionfrom theproperty owner/controllerorauthorized representative. Permission from property owner/controller orauthorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COA must be reportedto the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must bereported to the National Transportation Safety Board (NTSB) perinstructions contained onthe NTSB Web site: www.ntsb.gov. Unreal Freedom's UA are rotorcraft, weighing 55 lbs. or less includingpayload. They operate, under normal conditions at a speed ofno morethan 50 knots and they have the capability to hover, and move inthe vertical and horizontal plane simultaneously. They will operate only within VLOS and only withinthe restrictions above and the confidentially submitted manual. Such operations will insure that the UA will "not create a hazard to users ofthe national airspace system or the public." Giventhe small size ofthe UA involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone ofsafety (an equivalent level ofsafety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations ofUAto commence immediately. Also, due to the size oftheUA and therestricted areas in whichthe relevant UAwill operate, approval ofthe 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 orplace to carry certification and registration documents orto display them onthe unmanned aircraft. An equivalent level ofsafety will be achieved by keepingthese documents atthe ground control pointwhere the pilot flying the UAwill have immediate access to them. Also, giventhe size ofthe unmanned aircraft, the FAAregistration number will bedisplayed onthe 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 couldbe used inlieu ofthe medical certificate provides an equivalent level of safety.



### 814 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 thatthere is an equivalent level ofsafety as the FAR'sbyrequiring the PIC to "hold either an airline transport, commercial, private, recreational, or sportpilot certificate." Likewise, KinoFly is also performing commercial UAS work and is asking for the same restrictions which have beenpreviously deemed to provide an equivalent level ofsafety as the burdensome regulations. 14 C.F.R. § 61.113 (a): Private Pilot Privileges and Limitations: Pilot In Command. Sub-sections 61.113(a) limitprivate pilots to non-commercial operations. Because the UA will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level ofsafety ofcurrent operations by requiring the PIC operating the aircraft to have a sport pilot license ratherthan a commercial pilot's license to operate this small UAS. Unlike a conventional aircraftthat carries the pilot and passengers, the UA is remotely controlled with no living thing onboard. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness. As there will be no airworthiness certificate issued for the unmanned aircraft, and no FAAregulatory standard will exist for determining airworthiness ofthe UA, the requirements contained in the confidentially submitted manual and the restrictions already agreed to will provide an equivalent level ofsafety. 14 C.F.R. § 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil 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 ofthe lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at orbelow 500 AGL. In addition, the low-altitude operations oftheUAS will ensure separation between these small UAS operations and the operations ofconventional aircraft that must comply with Section 91.119. 14 C.F.R. § 91.121: Altimeter Settings This regulation requires eachperson operating an aircraftto 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 UAS may nothave a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. Anequivalent level ofsafety will be achieved bythe operator, pursuantto following the confidentially submitted manual. Furthermore, many otherpetitions have been granted allowing GPS to be used in lieu ofan altimeter setting.

914 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "aflight in an airplane under VFRconditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes; or (2) Atnight, to fly after that for at least 45 minutes." Applicant believes that an equivalent level ofsafety canbe achieved by restricting operations to "the intended operation and to operate after that for at least five minutes or with the reserve powerrecommended by the manufacturer ifgreater." Exemption# 11284, atpage 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 ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis 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 ofsafety 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 oftime. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy conditionto provide the equivalent level ofsafety. Lastly, the petitioner will operate in accordance with the confidentially submitted manual that will provide an equivalent level ofsafety 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 ofsafety supporting the grant ofthe exemptions requested herein. Sincerely yours, 

# -, /fny Thompson



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