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 303.249.8423
with 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 flight

procedures 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 303.249.8423
The 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 303.249.8423
Regulation 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 303.249.8423
UNMANNED 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 303.249.8423
OPERATING 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 documents 

associated 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 M10 Manual

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 303.249.8423
Appendix 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