The Names and Address of the Applicant is:

Mixed Media Solutions, LLC

DBA: Alienworx

Mark Nguyen | Mark Addona | James West

7214 Golden Isles Way

Savannah, GA 31410

(912) 662-5015

July 4, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

RE: Exemption Request under Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR 

Part 11

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("FAA Reform Act") and 14 CFR Part 

11, Mixed Media Solutions, LLC hereby applies for exemptions from several provisions of the Federal Aviation 

Regulations ("FAR"), specifically Section 333. We are making this request so that Mixed Media Solutions, LLC, 

owner and operator of small Unmanned Aircraft Systems (UAS), may be exempted from specific Federal Aviation 

Regulations (FARs) which are listed later in this document. This requested will allow Mixed Media Solutions, LLC to 

operate its UASs commercially, in airspace regulated by the Federal Aviation Administration ("FAA"); as long as 

such operations are conducted within and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333.

Mixed Media Solutions, LLC is working to provide high quality imagery for a variety of commercial, public, 

residential and government uses. Some of the intended applications are:

• Aerial Inspections for public and private structures • Events – public and private

• Destination Promotion / City Promotion • Construction sites, before and after

• Real-Estate marketing • Search and Rescue operations

• General Aerial Imagery for Video Production • 3D Imagery Mapping & Data Research 

Approval of this exemption request would allow Mixed Media Solutions, LLC to operate their small, lightweight, 

unmanned UASs within predetermined, contained, specific areas of operation and within all current safety 

standards. 

Granting Mixed Media Solutions, LLC's request comports with the Secretary of Transportation's (FAA 

Administrator's) responsibilities to not only integrate UASs into the national airspace system, but to" ... establish 

requirements for the safe operation of such aircraft systems [UASs] in the national airspace system" under Section 

333 of the Reform Act. Further, Mixed Media Solutions, LLC will conduct its operations in compliance with the 

protocols described herein or as otherwise established by the FAA.

In accordance with 14 CFR § 11.81, Mixed Media Solutions, LLC provides the following information in support of its 

petition for exemption:

A. Name and Address of the Petitioner:

Mixed Media Solutions, LLC

DBA: Mixed Media Solutions, LLC

7214 Golden Isles Way

Savannah, GA 31410

(912) 662.5015

info@alienworx.media

B. The Specific Sections Of 14 CFR From Which Mixed Media Solutions, LLC Seeks Exemption;
14 CFR 21;

14 CFR 91;

14 CFR 45.23(b);

14 CFR 61.113 (a) & (b);

14 CFR 407 (a)(1);

14 CFR 409 (a)(2);

14 CFR 417 (a) & (b).

As well as exemption from Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from:

14 CFR 45.23(b);

14 CFR Part 21;

14 CFR 61.113 (a) & (b);

14 CFR 91.7 (a);

14 CFR 91.9 (b)(2);

14 CFR 91.103;

14 CFR 91.109;

14 CFR 91.119;

14 CFR 91.121;

14 CFR 91.151 (a);

14 CFR 91.203 (a) & (b);

14 CFR 91.405 (a);

14 CFR 91.407 (a)(1);

14 CFR 91.409 (a)(2);

14 CFR 91.417 (a) & (b).

C. The extent of relief you seek, and the reason you seek the relief;

Mixed Media Solutions, LLC submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 

331-334, seeking relief from any currently applicable FARs which pertain to UASs and operating to prevent 

Mixed Media Solutions, LLC contemplated commercial photographic, inspections and other flight operations 

within the national airspace system. 

The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into the

national airspace system as it is in the public's interest to do so. Mixed Media Solutions, LLC lightweight 

UASs meet the definition of "small unmanned aircraft" as defined in Section 331 and therefore are ideal 

recipients of an exemption by the Reform Act. 

Considerations for relief include:

• weight, size, speed and overall capabilities of the UAS; 

• Restricted operation in populated areas;

• Non-operation near airports;

• Operation of the UASs by visual line of site (VLOS)

112 P.L. 95 § 333 (a). Each of these items mitigates in favor of an exemption for Mixed Media Solutions, 

LLC and are outlined below.

14 CFR Part 21, Subpart H: Airworthiness Certificates

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR §91.203 (a)(1). Given the size and limited operating area 

associated with Mixed Media Solutions, LLC’s fleet of UASs, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, 

speed, operational capability, and proximity to airports and populated areas of the particular UAS.
The UASs that will be operated by Mixed Media Solutions, LLC are less than 55 lbs, and carries neither a 

pilot or passenger, carries no explosive materials or flammable liquid fuels, and operates within a secured 

area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by 

both the pilot (PIC) and camera operator, who will each have their own separate monitors for safety issues. 

These precautions to current safety practices and regulations, which already apply to civil aircraft, provide a 

greater degree of safety to the public and property owners than conventional aircraft operations conducted 

with airworthiness certificates issued under 14 CFR Part 21, Subpart H. Lastly, application of these same 

criteria demonstrates that there is no intrinsic credible threat to national security posed by the UAS, due to 

its size, speed of operation, location of operation, lack of intrinsic explosive materials or flammable liquid 

fuels, and inability to carry a substantial external load.

14 CFR 45.23: Marking of the Aircraft.

This regulation requires limited, restricted or light-sport category aircraft or experimental or provisionally 

certificated aircraft to be marked with letters between 2 and 6 inches in height the words “limited,” 

“restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

Even though the UASs will have no airworthiness certificate, an exemption may be needed as the UASs will 

have no cabin, cockpit or pilot station entrances on which the word "Experimental" can be placed. Given the 

small size of the UASs, two-inch lettering will be impossible to fit on the body of the aircraft. The word 

"Experimental" will be placed on the body of the UAS in compliance with §45.29 (f) at a size suitable for the 

available space.

The equivalent level of safety will be provided by having the UASs marked on its fuselage as required by

§45.29 (f) where the pilot, observer and others working with the UASs will see the identification of the UAS 

as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 

10700, 8738, 10167 and 10167A.

14 CFR 61.113: Private Pilot Privileges and Limitations. 

Pursuant to 14 CFR §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. Mixed 

Media Solutions, LLC can achieve an equivalent level of safety as achieved by current regulations because 

Mixed Media Solutions, LLC UASs do not carry any pilots or passengers. Further, while a private pilot 

license is helpful, this will not ensure capability and piloting skills to operate and control a UAS. Mixed 

Media Solutions, LLC pilot vetting and training programs (which include a required completion of an FAA 

Approved Ground School and a self-administered UAS training program) will make sure that their pilots are 

prepared and capable of operating their fleet of UASs safely. The risks associated with the operation of the 

UASs are so diminished from the level of risk associated with commercial operations contemplated by Part 

61 when drafted, that allowing operations as requested with a private pilot in the ground crew exceeds the 

present level of safety achieved by 14 C.F.R. §61.1 13 (a) & (b).

14 CFR 91.7 (a): Civil Aircraft Airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained in the Manuals for maintenance and use of safety checklists prior to each flight, an 

equivalent level of safety will be provided.

14 CFR 91.9 (b)(2): Civil Aircraft Flight Manual, Marking, and Placard Requirements

Given its size and configuration, the UAS has no ability or place to carry a flight manual on the aircraft as

there is no room or capacity to carry such an item on the aircraft as well as the fact that there is no pilot on 

board. The equivalent level of safety will be maintained by keeping any manuals at the ground control point 

where the pilot flying the UAS will have immediate access to it. The FAA has issued the following 

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

10167A, 10602,32827, and 10700.
14 CFR 91.103: Preflight Action

This regulation requires each pilot in command (PIC) take certain actions before flight to ensure the safety 

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. The pilot in command will take several specific actions including checking the weather conditions, 

flight battery requirements, take off and landing areas and completing a proprietary preflight checklist. 

These actions will provide an equivalent level of safety.

14 CFR 91.109: Flight Instruction

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual controls. By design, UASs and 

remotely piloted aircraft do not have fully functional dual controls. Flight control is accomplished through the 

use of a control box that communicates with the aircraft via radio communications. The FAA has previously 

approved exemptions for aircraft without fully functional dual controls. See Exemption Nos.5778K & 9862A. 

The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the 

aircraft, the ability to control the UAS via radio signals from the controller, and by the size and speed of the 

aircraft.

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. This exemption is for a UAS that

flies in a similar manner to a helicopter, which will typically operate at an altitude below 400 feet. Due to this 

operation, an exemption may be needed to allow such operations. Mixed Media Solutions, LLC will not 

operate at an altitude above 400 feet.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the 

location where it is operated. No flight will be taken without the permission of the property owner or local 

officials. Because of the advance notice to the property owner and participants in the remote sensing 

activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations 

with aircraft or rotorcraft weighing far more than the UASs proposed herein, and carrying flammable fuel, 

any risk associated with operation is far less than those presently presented with helicopters and other 

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

ensure separation between these UAS operations and the operations of conventional aircraft that must 

comply with Section 91.119.

14 CFR 91.121: Altimeter Settings

Section 91.121 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 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, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight.

14 CFR 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.”

The batteries in Mixed Media Solutions, LLC’s UASs provide approximately 18 minutes of powered flight 

time. Given this limited flight time, and the limited areas that the UASs will be operated within, Mixed Media 

Solutions, LLC will not be able to meet the required 30 minute reserve requirement and will require an 

exemption from 14 CFR 91.151. An equivalent level safety can be achieved by limiting flights to 30 minutes, 

or 20% of battery power, whichever happens first. This restriction would be more than adequate and would 

allow the UASs to return to their planned landing area safely. Similar exemptions have been granted to 

other operations, including Exemptions 2689F, 5745, 10673,and 10808.
14 CFR 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

The regulation provides: 

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate ....

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of 

this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As there is no 

on board pilot present, there is no ability or place to carry certification and registration documents or to 

display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the 

ground flight control point where the pilot flying the UAS will have immediate access to these documents. 

The FAA has issued multiple exemptions to this regulation. See exemption nos. 9565, 9665,9789, 9789A, 

9797, 9797A, 9816A, and 10700.

14 CFR 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above-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 

Mixed Media Solutions, LLC, should its requested exemption be granted. Mixed Media Solutions, LLC 

conducts an extensive maintenance program that involves regular software updates and constant 

inspection for assessment of any damaged hardware. Therefore, an equivalent level of safety will be 

achieved as the UASs are limited in size and carry a smaller payload. If any mechanical issues arise during 

operation, the UAS can immediately land. The UAS will also be inspected prior to each flight operation to 

confirm that the UAS is in working order.

E. The reasons why granting the exemption would not adversely affect safety, or how the exemption would 

provide a level of safety at least equal to that provided by the rule from which you seek the exemption;

Mixed Media Solutions, LLC contends that operations of their UASs will not “create a hazard to users of the 

national airspace system or the public.” as stated in 112 P.L. 95 Section 333 (b). Given the small size and 

weight of Mixed Media Solutions, LLC UASs, along with their operation in predetermined and wellcontrolled areas, Mixed Media Solutions, LLC UASs fall within Congress's contemplated safety zone. 

Indeed, Mixed Media Solutions, LLC UASs have a demonstrable safety record and do not pose any threat 

to the general public or national security. The FAA has the authority to issue the exemption to Mixed Media 

Solutions, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

Mixed Media Solutions, LLC operate UASs weighing less than 55 pounds and only operate their UASs 

below 400 feet. In order to make sure that the UAS will return safely, flights are landed when the battery 

reaches 25%. Flights are also operated by VLOS, with both a UAS pilot and camera operator. As a 

precaution, the pilot also has a video backup if VLOS is temporarily lost. In addition, Mixed Media Solutions, 

LLC UASs have the ability to automatically return to their starting location in the event of communication 

loss or GPS signal loss.

Mixed Media Solutions, LLC has insured their UASs for protection against accidental damage and carries a 

substantial amount of coverage for any accidental damage or injury. 

Mixed Media Solutions, LLC does not operate its UASs near airports and generally has only operated its 

UASs on private grounds within predetermined areas. All safety precautions are taken to ensure the safety 

of all involved. All necessary permission and permits are always obtained prior to operation.

Mixed Media Solutions, LLC provides a level of safety at least equal to existing rules, and in nearly every 

instance, greater than existing rules. Mixed Media Solutions, LLC UASs have operated and will continue to 

operate at and above current safety levels.
D. The reasons why granting your request would be in the public interest; that is, how it would benefit the 

public as a whole;

Mixed Media Solutions, LLC believes that granting this exemption request will further the public interest by 

providing a safe manner to record aerial imagery to meet the needs of clients. The unmanned nature of the 

UASs reduces the need to put people at risk compared to flying a manned helicopter and provides similar 

imagery. The increased control and small size of the UASs allows for a diminished risk to potential loss of 

life, as there are no persons on board. As the UASs are battery powered, the risk of fire or explosion is 

greatly reduced, providing for a much safer environment. As Mixed Media Solutions, LLC will also be 

working to provide inspections for both public and private structures, the ability to use their fleet of UASs 

will reduce the danger associated with these inspections, by allow imagery to be recorded remotely, instead 

of requiring a person to physically climb high off of the ground or on a potentially compromised structure.

Granting Mixed Media Solutions, LLC exemption request substantially furthers the public's interest in ways 

known and currently unknown. Permitting Mixed Media Solutions, LLC to immediately fly within the United 

States furthers advancements in publicly usable technologies or advancements in equipment available to 

law enforcement personnel and first responders with state of the art equipment that does not cost millions 

of dollars.

F. A summary we can publish in the Federal Register, stating:

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed: 

Mixed Media Solutions, LLC seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 

C.F.R 45.23(b); 14 C.F.R. §§61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 91.103{b); 91.109; 91.119; 91.121; 

91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1 ); 91.409 (a) (2); 91.409 (a) {2) and 91.417 (a) & (b) to 

operate commercially their fleet of small unmanned vehicle (55lbs or less) in elevated photographic, video 

and inspection operations.

Approval of exemptions allowing commercial operations of UASs in the media industry will enhance safety 

by reducing the risk associated with conventional aircraft operations and other means of elevated 

photography and video collection. The public benefit served by approval of this petition is increased 

awareness of characteristics of items or locations that are difficult to document. A UAS weighing fewer than 

55 lbs. and powered by sealed batteries eliminates virtually all associated risk inherent in operating 

conventional aircraft in close proximity to buildings or persons or otherwise elevating persons to a position 

they would be able to collect needed data. The operation of small UASs, weighting less than 55lbs., 

conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 

21 and allowing commercial operations.

Mixed Media Solutions, LLC DBA Alienworx, respectfully requests that the FAA grant its exemption request without 

delay. The FAA has the authority to issue the exemption sought by Mixed Media Solutions, LLC pursuant to the 

Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

Thank you,

Mark Nguyen, Co-Owner | Mark Addona, Co-Owner | James West, Co-Owner

Mixed Media Solutions, LLC | DBA: Mixed Media Solutions, LLC

7214 Golden Isles Way, Savannah, GA 31410

(912) 662-5015

info@alienworx.media