September	20,	2015

U.S	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.	SE

Washington,	DC		20590

Rich	Carter

Tandem	Axle	Inc	(dba	Mixed	Media	Creations)

2300	Rockbrook	Dr	Ste	D

Lewisville,	TX		75067

RE:	Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Modernization	and	

Reform	Act	of	2012,	and	14	CFR	Part	11.

Dear	Sir	or	Madam:

I	request	an	exemption	from	14	CFR	Part	21,	14	CFR	45.23(b),	14	CFR	61.113(a)(b),	

14	CFR		91.7(A),	91.9(b)(2),	91.109,	91.119,	91.121,	91.151(a),	91.203(a)(b),	

91.205(b),	and	91.401-417	as	was	granted	in	Exemption	Numbers	11062,	11109,	

11112,	and	11213.

The	requested	exemption	would	allow	Tandem	Axle	Inc	(dba	Mixed	Media	

Creations)	and	its	agents	(ATP	certified	pilots)	to	pursue	its	commercial	interests	in	

providing	services	to	it’s	customers	interested	in	aerial	photography	using	small	

unmanned	aircraft	to	include	but	not	limited	to:

Residential	Real	Estate	Photography

Commercial	and	Multifamily	Real	Estate	Photography

Land	Development	Surveys

UAS	Operator	Training

Artistic	Photography

The	Mixed	Media	Creations	requests	to	operate DJI	Phantom	2	with	a	Zenmount	

GoPro	Mount, DJI	Phantom	3	Pro,	DJI	Inspire	1	multi-rotor	UAS	equipped	with	a	3-

axis	gimbal	mounted	camera,	and	a	Yuneec	Q500	4K	Quadcopter.		

Operation	will	be	conducted	following	the	NPRM	FAA-2015-0150.

-Visual	Line	of	sight (VLOS)	Only;	the	unmanned	aircraft	will	remain	within	

the	VLOS	of	the	operator	and	visual	observer

-At	all	times	the	small	unmanned	aircraft	(sUA)	will	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	as	prescribed	on	medical	

or	drivers	license.

-SUA	may	not	operate	over	any	persons	not	involved	in	the operation.
-Day	VFR	only	(official	sunrise	to	official	sunset)

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

-Will	use	visual	observer	(VO)

-Maximum	airspeed	of	100mph	(87kts)

-Maximum	Altitude	of	400	AGL

-Minimum	weather	to	meet	91.155	Basic	VFR	weather	minimums.	(3	miles	

visibility,	500ft	AGL)

-No	operation	in	Class	A	airspace

-Operations	in	Class	B,	C,	D airspace	are	allowed	with	prior	ATC	

authorization.

-Operations	in	Class	G	airspace	are	allowed	with	no	ATC	authorization.

-No	person	may	act	as	an	operator	or	VO	for	more	than	one	unmanned	

aircraft	operation	at	one	time.

-Requires	preflight	inspection	by	the	operator.

-A	person	may	not	operate	a	small-unmanned aircraft	if	her	or	she	knows	or	

has	reason	to	know	of	any	physical	or	mental	condition	that	would	interfere	

with	the	safe	operation	of	a	small	sUA.

To	enhance	the	level	of	safety	Mixed	Media	operators	will	meet	a	standard	of	

operating	experience	to	reach	the	level	of	safe	operation	similar	to	that	of	the	sport	

pilots	license.		Each	operator	will	have	15	hours	operating	said	sUA	prior	to	

commencing	commercial	activities.		In	addition	all	operators	and	Visual	Observers	

will	be	trained	to	understand	the	proper	roles	of	observer,	communication	

procedures,	proper	visual scan	techniques,	operations	at	non	towered	airports,	and	

appropriate	sections	of	the	Aeronautical	Information	Manual	(AIM).		Proper	training	

and	safety	will	be	of	utmost	importance.

All	active	drones	will	be	programmed	not	to	exceed	400	ft	AGL.		All	aircraft	will	be	

maintained	and	operated	in	accordance	with	the	manufacturer	recommendations.		

All	aircraft	will	use	a	failsafe	function	of	the	autopilot	in	the	case the	communication	

between	the	controller	and	the	transmitter	is	lost	(return	to	home	feature).		These	

sUA’s	are	considered	COTS	products	and	will	not	be	altered	or	modified	in	any	way.

EXEMPTIONS:

I	request	exemption	from14	CFR	Part	21.		This	part	establishes	the	procedures	for	

the	issuance	of	an	airworthiness	certificate.		While	the	FAA	continues	to	work	to	

develop	airworthiness	standards	for	Unmanned	Aerial	Systems(UAS)	we	request	an	

exemption	until	such	time	as	the	standards	are	implemented.	

I	request exemption	from	14	CFR	45.23(b).		The	standard	size	and	location	for	

registration	numbers	was	established	with	a	common	size	for	manned	airframe	in	

mind.		As	these	sUA	are	smaller	than	the	prescribed	sizes.		We	propose	to	add	the	

registration	numbers	as	large	as	practical	in	the	most	conspicuous	location	on	the	

sUA
I	request exemption	from	14	CFR	61.113(a)(b).		As	professional	(ATP	Certified)	we	

propose	not	employ	any	operator	that	does	not	hold	at	a	minimum	sport	pilot	

license	and	either	3rd class	medical	or	drivers	license.		

I	request	exemption	from	14	CFR		91.7(A).		No such	certificate	is applicable	in	the	

form	contemplated	by	the	FARs	this	Regulation	is	inapplicable.

I	request	exemption	from	14	CFR	91.9.		We	assume	that	the	intention	of	this	

regulation	is	to	ensure	the	flight	information	is	available	to	the	aircrew	while	

operating	the	aircraft.		As	the	aircraft	is	unmanned	it	is	inappropriate	to	include	

onboard.		We	suggest	that	to	meet	an	equivalent	level	of	safety	and	meet	the	intent	a	

current	and	approved	UAS	Flight	Manual	documentation	would	be	held	in	proximity	

to	the	operator	on	the	ground	so	to	be	available	as	needed.

I	request	exemption	from	14	CFR	91.109.		To	reach	the	standard	of	safety	set	forth	

in	this	regulation	we	will	use	a	UAS system	to	operate	the	aircraft	simultaneously,	

either	through	means	of	a	override	device	with	a	second	controller	or	if	that	is	not	

available	both	operators	(student	and	instructor)	available	to	take	control	as	

needed.

I	request	exemption	from	14	CFR	91.119.		Operations	will	only	be	flown	over	

property	or	persons	where	permission	has	been	obtained	either	verbally	or	in	

writing.		The	aircraft	will	be	operating	at	a	low	altitude	allowing	if	there	is	a	loss	of	

propulsion	an	emergency	landing	without	undue	hazards	to	persons	or	property	on	

the	ground.		We	suggest	that	due	to	the	small	size	the	hazard	to	persons	vehicles	

and	structures	is	minimal	in	comparison	to	the	risk	of	similar	missions	in	a	manned	

aircraft.

I	request	an	exemption	from	14	CFR	91.12.		The	sUA	uses	an	AGL	altimeter	

measurement	above	the	takeoff	point	that	is	transmitted	via	radio	to	the	display	

screen	held	by	the	operator	providing	a	constantly	updated	AGL	readout.		Since	the	

aircraft	will	not	be	operated	above	500	ft	AGL	and	the	aircraft	will	not	be	

maintaining	cruising	altitudes	this	technology	will	provide	at	least	equivalent	level

of	safety.

I	request	an	exemption	from	14	CFR	91.151.		The	operator	will	not	begin	a	flight	

unless	(considering	wind	and	forecast	weather	conditions)	there	is	enough	available	

power	for	the	UA	to	conduct	the	intended	operation	and	to	operate	after	that	for	at	

least	five	minutes	or	with	the	reserve	power	recommended	by	the	manufacturer	if	

greater

I	request	an	exemption	from	14	CFR	91.203(a)(b).		The	sUA	will	be identified	by	

serial	number,	registered	in	accordance	with	14	CFR	part	47,	and	have	identification	

(N−Number)	markings	in	accordance	with	14	CFR	part	45,	Subpart	C.	Markings	

must	be	as	large	as	practicable.
I	request	an	exemption	from	14	CFR 91.205(b).	 The	requirement	of	this	regulation	

is	to	provide	the	minimum	standard	of	information	for	the	PIC	to	understand	the	

operating	condition	of	the	aircraft.		The	sUA	provides	a	similar	standard	of	

information	through	computer	relayed	sensor	information	available	to	the	operator	

on	the	handheld	device	(controller).		The	sUA	also	will	provide	the	added	level	of	

safety	by	interfacing	with	the	onboard	camera	giving	the	operator	a	“view	from	the	

seat”.

I	request	an	exemption	from	14	CFR	91.401-417.		The	UAS	that	has	undergone	

maintenance	or	alterations	that	affect	the	UAS	operation	or	flight	characteristics,	

e.g.,	replacement	of	a	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	a	VO	and	must	remain	at	least	500	feet	from	

other	people.	The	functional	test	flight	must	be	conducted	in	such	a	manner	so	as	to	

not	pose	an	undue	hazard	to	persons	and	property.		In	addition	the	operator	will	

ensure	that	the	aircraft	is	in	airworthy	condition	prior	to	every	flight	and	will	

conduct	inspections	after	every	two	hours	of	flight.		Maintenance	performed	by	the	

operator	is	limited	to	repairing	small	cracks,	replacing	a	propeller,	checking	

electrical	and	updating	software	and	firmware	for	the	on-board	computer.		All	other	

maintenance	will	be	performed	by	the	manufacturer	or	their	designated	repair	

facility.

Thank	you	for	your	consideration.

Rich	Carter

Mixed	Media	Creations

2300	Rockbrook	Dr	Ste D

Lewisville,	TX		75067