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

12 00 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 oper ator 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 reg ulated 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 provid e 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 Pr omotion • 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 t his 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 Transpo rtation'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 t he 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 i nformation 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 P art 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 FAR s which pertain to UASs an d 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 sy stems 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 Se ction 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 requi rements 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, u pon 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 pa ssenger, 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 wi ll 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 aircr aft 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, spee d 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 UAS s wil l have no airworthiness certificate, an exemption may be needed as the UAS s will have no cabin, cockpit or pilot station entrances on which the word "Experimental" can be placed. Given the

small size of the UAS s , two

- inch lettering will be impossible to fi t 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 UAS s marked on its fuselag e as required by §45.29 (f) where the pilot, observer and others working with the UA Ss 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 r egula tions because Mixed Media Solutions, LLC UASs do not carry any pilots or passengers. Fu r ther, 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 vetti ng 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 associ ated with the operation of the

UAS s 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 issue d 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 ea ch 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
th ere 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 h ave 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 i ncluding 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. 10 9 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 function al 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 No s.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.

1 4 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

comp lies with any route or altitudes prescribed for helicopters by the FAA. This exemption is for a UAS th at flies in a similar manner to a helicopter, which will typically operate at an altitude below 400 f eet . Due to this operation, an exemption may be neede d 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 t o 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 ope rating 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 ha ve 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 CF 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 th e 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 a n 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 p rovided 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 para graph (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 cont rol 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); 40 9 (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, exc ept 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, LL C

, 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 safe ty 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 work ing 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 conte nds 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 well

controlled 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 nationa l 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 oper ate 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 a ddition , 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 with in 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 ru les, and in nearly every instance, greater than existing rules. Mixed Media Solutions, LLC UAS s 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 o f the UASs reduces the need to put people at risk compared to flying a manned helicopter and provide s 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 boar d. 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 u se 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 M edia 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 (55l bs 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 seal ed 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 allo wing 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

Feder al 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