Falkor Aerials Larkin Carey 1074 Sunshine Canyon Drive Boulder, Colorado, 80302 Larkin@FalkorAerials.com 303.249.8423

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590

To Whom It May Concern: Pursuant to Section 333 of the FAA Modernization Reform Act of 2012, and 14 CFR Part 1Falkor LLC (DBA Falkor Aerials), request exemption from the following sections of Title 14, Code of Federal Regulations§§ 61.123(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.7(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) and (b) in order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA). Falkor Aerials will operate these UAS for the purposes of aerial imaging, specifically, closed-set motion picture and television filming and production, photography, cinematography, videography, search and rescue, surveying, scientific measurement, inspections and education that can be performed more safely and cost effectively with UAS as compared to manned aircraft.
INTRODUCTION OF THE PETITIONER Falkor Aerials has 25 years experience flying RC and Full Size aircraft, as well as deep roots in aerospace engineering, search and rescue, and adventure and travel photography. UAS open the door to exciting new prospects and potentials on our planet, making it possible to get sensors places humans cannot easy go. They set the camera free on a creative director's set, in turn telling more engaging stories. UAS enable more effective searches and rescues in dangerous conditions, helping those in need without needlessly putting public servants in harms way. UAS allow scientists to image things previously inaccessible, in turn gaining knowledge of parts of our world that are still a mystery again, without putting humans in compromising situations. We are just now beginning to develop and utilize a new way we can study, create, perceive, and explore our world, and UAS are a key element of this. Thank you for considering Falkor Aerials' exemption request for commercial UAS use in the National Airspace. Science, search and rescue, and cinematography, are some of the things I personally care about the most, and some of the basic pillars of Falkor Aerials business, and UAS has upped the level of what is possible in all of these areas. However, to maximize effectiveness, and make possible a better and safer planet I need this requested exemption granted, opening up the door to collaborations

FALKOR Aerials, 1074 Sunshine Canyon Drive, Boulder, Colorado. falkoraerials.com 303.249.8423with the worlds meaningful industry and organizations.
BASIS FOR PETITION I (Larkin Carey, founder of Falkor Aerials) have been building and flying RC aircraft since 1992, and have logged over 6,000 hours in a multirotor since 2011. I have a background in Search and Rescue, Aerospace Engineering, and Photography, and have meshed these together into my UAS practice. Falkor Aerials utilizes state of the art equipment professionally built tuned and tested. We utilize flightprocedures and pre-checks echoing my SAR background, to create stunning images for good-for-theworld projects in a safe, respectful, and controlled manner. Falkor Aerials currently flies to the FAA's UAS proposed regulations from Docket No.: FAA-2015- 0150 released earlier this year, and will continue to until they (hopefully) become released regulations, as these are logical and well thought out rules. The key points of these are listed below for reference:

• Unmanned aircraft must weigh less than 55 lbs. (25 kg).

• Visual line-of-sight (VLOS) only; the unmanned aircraft must remain within VLOS of the operator or visual observer.

• At all times the small unmanned aircraft must remain close enough to the operator for the operator to be capable of seeing the aircraft with vision unaided by any device other than corrective lenses.

• Small unmanned aircraft may not operate over any persons not directly involved in the operation.

• Daylight-only operations (official sunrise to official sunset, local time).

• Must yield right-of-way to other aircraft, manned or unmanned.

• May use visual observer (VO) but not required.

• First-person view camera cannot satisfy “see-and-avoid” requirement but can be used as long as requirement is satisfied in other ways.

• Maximum airspeed of 100 mph (87 knots).

• Maximum altitude of 500 feet above ground level.

• Minimum weather visibility of 3 miles from control station.

• No operations are allowed in Class A (18,000 feet & above) airspace.

• Operations in Class B, C, D and E airspace are allowed with the required ATC permission.

• Operations in Class G airspace are allowed without ATC permission

• No person may act as an operator or VO for more than one unmanned aircraft operation at one time.

• No careless or reckless operations.

• Requires preflight inspection by the operator. (details in Appendix ###)

• A person may not operate a small unmanned aircraft if he or she knows or has reason to know of any physical or mental condition that would interfere with the safe operation of a small UAS. Additionally, Falkor Aerials conducts aerials operations according to our internal Flight Standard Operating Guidelines attached in Appendix C.

FALKOR Aerials, 1074 Sunshine Canyon Drive, Boulder, Colorado. falkoraerials.com 303.249.8423The specific sections of Title 14 of the code of federal regulations from which Falkor Aerials request exemption are: 61.123(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.7(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) and (b)

I, Larkin Carey (Falkor Aerials) submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent me, Larkin Carey (Falkor Aerials), or any PIC who qualifies under this exemption, and additional Falkor Aerials pilot qualifications document and Standard Operating Guidelines (SOGs attached in Appendix C), from practicing commercial cinematic, academic and other flight operations on behalf of Falkor Aerials, within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public's interest to do

so. Permitting Falkor Aerials, and any PIC who qualifies under this exemption, and additional Falkor Aerials pilot qualifications document and Standard Operating Guidelines (SOGs) to operate UAS under this proposed exemption is in the best interest of the public good because it reduces manned helicopter flights for the purpose of aerials cinematography and photography, and therefore considerably reducing the risk to the general public. It allows for aircraft to be budgeted and integrated in local Search and Rescue teams increasing effectiveness in the hundreds of missions Colorado Search and Rescue agencies go on each year, when full-size aircraft are either out of scope of the mission or beyond the budget. It puts aerial imaging in the hands of scientists in new ways where previously full size aircraft were difficult to operate or ineffective, in turn increasing the public knowledge. And finally, we are at the cutting edge of this field, and there are many applications being worked out daily that Falkor Aerials continues to help develop. Falkor Aerials' UAS are inherently safer than manned aircraft, using non-combustible fuel, intelligence assisted flight response, Return to Home features, redundant power systems, as well as being lighter and slower than any manned aircraft needed for a similar task.

FALKOR Aerials, 1074 Sunshine Canyon Drive, Boulder, Colorado. falkoraerials.com 303.249.8423Regulation Details: 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as UAS listed in this exemption request utilizes electronic global positioning systems with a barometric sensor or controlled GPS. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by the PIC 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. Falkor Aerials' UAS can be marked with the appropriate “N” number once this “N” number has been given. It can be marked in the largest size applicable for the aircraft. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. Equivalent level of safety is achieved by current regulations because Falkor Aerials' UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing the PIC to operate the UAS and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Falkor Aerials' UAS will never operate at an altitude greater than 400 AGL as specified in the SOGs attached in Appendix C. I, Larkin Carey, or the PIC, will however operate the UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or above 91.119 in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of the UAS listed in the exemption request, an equivalent or higher level of safety will be achieved. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): The cited Regulations require, amongst other things, aircraft owners and operators to“have [the] 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. . . .”These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to Falkor Aerials' UAS. However, as a safety precaution we inspect my UAS before and after each flight.

FALKOR Aerials, 1074 Sunshine Canyon Drive, Boulder, Colorado. falkoraerials.com 303.249.8423UNMANNED AERIAL SYSTEMS The aircraft requested to be allowed to be flown commercially by Falkor Aerials under this exemption are as follows:

Aircraft Year N# S# Max Weight Dimensions Max velocity DSLR Octocopter 2014 unasigned FK001 35lbs 57”X config 40mph Cinema Octocopter 2015 unasigned FK002 40lbs 58”X config 40mph

The N#s will be inserted into this document when assigned.
NAME AND ADDRESS OF THE PETITIONER Falkor Aerials (FALKOR LLC) ATTN: LARKIN CAREY 1074 Sunshine Canyon Drive Boulder, Colorado, 80302 Larkin@FalkorAerials.com 303.249.8423

SUMMARY FOR PUBLICATION For publication in the Federal Register, Falkor Aerials provides this summary: An exemption is requested from the following regulations in order to allow commercial operation of UAS for such purposes as closed-set motion picture and television filming, aerial cinematography and photography, additional aerial imaging for search and rescue purposes, forestry management, surveying, data acquisition and other scientific applications. Title 14 CFR Section 61.123(a) and (c); Title 14 CFR Section 61.101(e)(4) and (5); Title 14 CFR Section 61.113(a); Title 14 CFR Section 61.315(a); Title 14 CFR Section 91.7(a); Title 14 CFR Section 91.119(c); Title 14 CFR Section 91.121; Title 14 CFR Section 91.151(a)(1); Title 14 CFR Section 91.405(a); Title 14 CFR Section 91.407(a)(1); Title 14 CFR Section 91.409(a)(1) and (2); Title 14 CFR Section 91.417(a) and (b)

FALKOR Aerials, 1074 Sunshine Canyon Drive, Boulder, Colorado. falkoraerials.com 303.249.8423OPERATING DOCUMENTS The comprehensive operations manuals, users guides, ands safety guides provided by the UAS manufacturers are attached to this petition as appendices listed below: Attached additionally in the Appendices are the current and comprehensive industry documents associated with these aircraft including specifically flight controllers and transmitter radios.

UAS Manuals: Appendix A: FALKOR DSLR Octocopter Manual Appendix B:FALKOR Cinema Octocopter Manual The appendices are comprehensive and current for reach UAS, and offer a complete description of each aircraft, including operating features and protocals, speficications, maintenance recommendations, and more. Attached additionally in the Appendices are the current and comprehensive industry documentsassociated with these aircraft including specifically flight controllers, transmitter radios, and camerastabilizing gimbals. Industry Documents: Appendix C: DJI A2 Flight Controller Manual Appendix D: Gryphon Dynamics DSLR Octocopter Manual Appendix E: Freefly Cinestar 8 Cinema Octocopter Manual Appendix F: DJI IOSD Mark 2 Manual Appendix G: Spektrum Dx7 Transmitter Radio Manual Appendix H:Futaba 14sgh Transmitter Radio Manual Appendix I: FreeFly Systems Movi M5 Manual Appendix J: FreeFly Systems Movi M10Manual Appendix K: Connex by Amimon HD Downlink Also attached are Falkor Aerials specific documents denoting our Standard Operating Guidelines, including preflight checklists, briefings, pilot training requirements, maintenance schedule, flight log sheet and FALKOR Aerials Motion Picture and Television Operation Manual. FALKOR Specific documents: Appendix L: FALKOR Preflight Checklist

FALKOR Aerials, 1074 Sunshine Canyon Drive, Boulder, Colorado. falkoraerials.com 303.249.8423Appendix M: FALKOR Aerial Operations Standard Operating Guidelines (SOGs) Appendix N: FALKOR Pilot Training and Operating Requirements Appendix O: FALKOR Flight Log Sheet Appendix P: FALKOR Motion Picture and Television Operation Manual (MPTOM)

CONCLUSION Falkor Aerials requests the exemption discussed herein be granted based on the information presented in this and attached documents, the increased level of safety, service of public good, invigoration of the world economy, and exploration of what is not yet known in our universe. Thank you for your consideration,

Larkin Carey CEO and Founder, Falkor Aerials

FALKOR Aerials, 1074 Sunshine Canyon Drive, Boulder, Colorado. falkoraerials.com 303.249.8423