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Stevens Aircraft Solutions, LLC James Stevens, Owner 345 Jolee Way Paducah, KY 42001 270-559-1489 U.S. Department ofTransportation DocketManagement System 1200 New Jersey Ave., SE Washington DC 20590 

# Steve

Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and**P~rt** 11 ofthe Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 9L119(c); 14 CFR91.121; 14 CFR 91.15l(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(l) and (2); 14 CFR 91.417(a) and (b) Dear Sir or Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Actof2012 (the "ReformAct") and 14 CFR Part 11, Stevens Aircraft Solutions, LCC, operator ofan Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation ofits UAS, so 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. Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:
• Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

• Aerial video and/or photography for public and/or private use inciudingtelevision, public. events, cinematography and news gathering.

e Aerial inspection/photography ofresidential/commercial structures under contract with the owners or local government authority.

• Aerial inspect-ion/photography ofresidential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers. 1 

### 345Jolee Way • Paducah, KY 42001 • 270-559-1489 jstevens@stevensaircraftsolutions.com • www.stevensaircraftsolutions.com• Aerial video/photography or providing live video feed to assist with search and rescue operations in cases ofan emergency ornatural disaster only when the local authorities or government has requested it by contract or donation.

• The ability to offertraining to persons individually or belonging to both private and/or public organizationsthat have interests in the use and application ofa UAS for the purpose ofthe safe operation ofa UAS to enhancethe safety ofthe National Airspace System (NAS) as well as for the protection ofthe persons and property. As described fully below, the requested exemption would permit the operation ofa UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancementsto the already safe operations in the industrypresentlyusingconventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "
....establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." The name and address ofthe applicant is: Stevens Aircraft Solutions, LLC James Stevens

- Owner 270-559-1489 EmaiI: jstevens@stevensaircraftsoI utions.com Address: 345 Jolee Way Paducah, KY 42001 Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR91.109 14 CFR91. 119 (c) 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)

2Stevens Aircraft Solutions, LLC will operate the following aircraft: • Yuneec 

### Q500 Typhoon models • DJIPhantom 3 Professional 

### I Advanced • DJI Inspire 1 • xCraftX Plus One Platinum Stevens Aircraft Solutions, LLC will operate the Yuneec Electric Aviation Model Q500 Typhoon UAS, with atotal weightof 1700g or4.75 lbs. The dimensions are 420mm x 420mm x 240mm or 16.54 inches x q6.54 inches x 9.45 inches. Under still air the maximum speed is no more than 6.7 m/s or 15 mph with acruising speedof6.7m/s or 15 mph. The Yuneec Q500 Typhoon has the abilityto hover and move along a vertical and horizontal plane simultaneously. The Yuneec Q500 Typhoon has four motors, motor model YUNM4234 KV700, powered by a 5400 mAh 3s 11.1v Lithium Polymerbattery. There are four counterrotating propellers, propeller models YUNQ500115A and YUNQ50011B, in use. The Yuneec Q500 Typhoon will be controlled with a Yuneec model ST10, 10 channel remote controller with an operating frequency of2.400GHz- 2.483GHz. The live video feed will have an operating frequency of5.728GHz- 5.850GHz. Stevens Aircraft Solutions, LLC will also operate the DJI Phantom 3 Professional and Advanced UAS with a total weight of 1280g or 2.82 lbs. The diagonal dimensions are 590mm x 590mm. Under still air, the DJIPhantom 3Professional and Advanced has a maximum speed ofno more than 16 m/s or 35.78 mph. The DJI Phantom 3 Professional and Advanced has the ability to hover and move along a vertical and horizontal plane simultaneously. The DJI Phantom 3 Professional and Advanced has four motors, powered bya 4480 mAh, 15.2v Lithium Polymer battery. The DJIPhantom 3 Professional and Advanced will be controlled with one ortwo DJItransmitters with an operating frequency of2.4GHz2.483GHz. The live video feed with have an operating frequency of5.78 GHz- 5.85GHz. Stevens Aircraft Solutions,LLCwill also operatethe DJI Inspire 1UAS with a total weight of2935g or 6.47 lbs. The dimensions are 438mm x 451mm x 301mm or 17.24 inches x 17.75 inches x 11.85 inches. Under still air, the DJI Inspire I has a maximum speed ofno more than 22 m/s or 49.2I mph. The DJI Inspire I has the ability to hover and move along a vertical and horizontal plane simultaneously. The DJI Inspire 1has four motors, model number DJI 3510, powered by a 4500 mAh, 6s, 22.2v Lithium Polymerbattery. There are four propellers, model DJI 1345 in use. The DJI Inspire I will be controlled with one ortwo DJItransmitters with a operating frequency of2.4GHz- 2.483GHz. The live video feed with have an operating frequency of5.78 GHz- 5.85GHz. Stevens Aircraft Solutions,LLC will also operate the Xcraft XplusOne Platinum UAS with a total weight of 1315.4g or 2.9lbs. The diagonal dimensions are 32.5 inches x 19 inches x 14 inches. Under still air, the Xcraft XplusOne Platinum has a maximum speed ofno more than 26.8 m/s or 60 mph. The Xcraft XplusOne Platinum has the ability to hover and move along a vertical and horizontal plane simultaneously. The Xcraft XplusOne Platinum has four motors, powered by a 5200 mAh, 3s, 11.1v Lithium Polymer battery. The Xcraft XplusOne Platinum will be controlled with one or two Xcraft transmitters with an operating frequency of2.4GHz- 2.483GHz. The live video feed with have an operating frequency of5.78 GHz- 5.85GHz.

3The applicant will operate the UAS in line ofsight within a closed offand predetermined area owned and/operated bythe property representative. Given the small size ofthe UAS and the controlled environmentprovided,the proposed operationswill adhere to the Reform Act's safetyrequirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay. AIRCRAFT AND EOUIV ALENT LEVEL OF SAFETY The operation limitations proposed below are for an equivalent, or higher level ofsafety. Because of these limitations, our operations will further enhance the safety ofthe persons and/or property and those flying conventional manned aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption include:

• The UAS will weigh less than 55 lbs.

• The UAS will have a maximum operating speed ofno more than 60 mph.

• A Visual Observer (VO) may be utilized when the Pilotin Command (PIC) deems necessaryto assist with the safe operation ofthe flight.

• Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/or Visual Observer (VO).
• Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 30 minutes offlight time, or 25% battery powerreserve, whichever occurs first.
• Flightswill be operated at an altitude ofno more than 400 feet Above GroundLevel (AGL) and not more than 200 feet above an elevated platform from which filming is planned.
• Minimum crew for each operation will consist ofthe UAS Pilot, and may include a Visual Observer (VO).
• The UAS pilot will be a designated Pilot in Command (PIC) and hold at least a satisfactory Sport Pilot's written exam, along with meeting and complying with the medical requirements for a SportPilot'sCertificate. IfthePIC feels another operatoris needed, theymustbe qualified with the necessary skills to be PIC & possess the satisfactory Sport Pilot written exam, be able to meet and comply with medical requirements ofthe Sport Pilot Certificate, then that person may be designated PIC provided theyhave a minimum of20hours offlight time with the UAS.
• A briefing will be performed regarding the planned UAS operations prior to each day's flight 4consisting ofall the day's production activities.

• All flights will occur under Day Visual Meteorological Conditions (DVMC) only.

• The flights will occur no closerthan a 5mile radius ofthe geographic center/AirportReference Point (ARP) ofa tower controlled or uncontrolled airport.

• Ifoperations will be within a 5 mile radius ofthe geographic center/ Airport Reference Point (ARP) ofa tower controlled or uncontrolled airport the respective airports will be contacted advising them ofthe estimated flight time, flight duration, elevation offlight and other pertinent information. Ifrequested by the airport manager or ATC facility, a Flight Service Station will be contacted for appropriate filing ofa Notice to Airmen (NOTAM) ofauthorized UAS activities, location in relation to the closest published VHF OmniDirectional Range (VOR), radial, distance, and altitude block ofthe UAS activity.

• The operator will attempt to obtain verbal/written consent ofall persons involved with the planned operation and ensure thatonlyconsentingpersons will be allowed within 50 feet ofthe flight operation, and the radius may be reduced to 20 feet based upon an equivalent level of safety determination, with the exception ofone person standing nextto the PIC for observation ofphoto/video performance, so long as the flight is not conducted over the PIC. With the advanced permission ofthe FSDO, operations at closer range ofadditional persons may be approved.

• ThePIC and VO will havebeentrained in operationofUAS andreceiveup-to-date information for the particular UAS to be operated.

• The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

• Written and/or verbal permission and permits will be obtained from territorial, state, county or cityjurisdictions, including law enforcement, fire or other appropriate governmental agencies.
• Ifthe UAS loses communications with the remote controller, the UAS will have the capability to return to a pre-determined location within a designated location and land autonomously.
• The UAS will have the capabilityto abort a flight in case ofunpredicted obstacles, weather, or emergencies. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) SubpartH, entitled Airworthiness Certificates, establishesthe procedural requirements for the issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part II and Section 333 ofthe Reform Act. The Federal AviationAct (49 U.S.C.§4470I (f)) and Section 333 oftheReform Actboth authorize the FAA to exempt aircraft from therequirementfor an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas ofthe 5particularUAS. In all cases, an analysis ofthese criteriademonstratesthattheUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS, to be operated hereunder, is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored byboth the operatorand underthe requirements and in compliance with local public safetyrequirements. These safety enhancements provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteriademonstrates thatthere is no credible threatto national securityposed bythe UAS, due to its size, speed ofoperation, location of operation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry a substantial external load. 14 C.F.R. § 45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft orexperimental orprovisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Giventhe size oftheUAS, two-inch letteringwill be impossible. Theword "Experimental"will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as "Experimental." 14 C.F.R. § 61.113 (a) and (b): Private PilotPrivileges and Limitations: Pilot in Command. Pursuantto 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command ofan aircraft that is carrying passengers or property for compensation or hire. Stevens Aircraft Solutions ,LCCmayachieve an equivalent level ofsafetyas achievedbycurrentRegulations because the applicant's UAS do not carry any pilots orpassengers norproperty. The risks attendant to the operation ofUAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC ofthe UAS will have a Private Pilot Written Exam completed satisfactorily along 

### with a current Third Class or higher Medical exceeding the current safety levels in relation to 14 CFR 61.113 (a) & (b). I feel the operation and limitations set forth in the FOM will equate to the safe operation ofthe UAS.
614 C.F.R. §91.7(a): Civil AircraftAirworthiness. Theregulation requires thatnopersonmayoperate acivil aircraftunless itis in airworthycondition. 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**siz~** ofthe aircraft for maintenance and use ofsafety check lists priorto each flight an equivalent level ofsafety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in theAircraft. Section 91.9 (b) (2) provides: No person may operate aU.S.-registered civil aircraft
... (2) Forwhich an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability orplaceto carry such aflight manual on the aircraft, notonlybecause there is no pilot on board, butbecause there is no room or capacityto carry such an item on the aircraft. The equivalent level of safety will be maintained bykeepingthe flight manual atthe ground control pointwhere the pilotflying the UAS will have immediate access to it. 14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight. 14 C.F.R. §91.109: Flight Instruction. Section 91.103 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. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a numberofaircraft and for flight instruction in experimental aircraft. The equivalentlevel ofsafetyprovided bythe fact thatneitherapilotnorpassengers will be carried in the aircraft and bythe size and speed ofthe aircraft. 14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation ofcivil 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. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes 7up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft orrotorcraftweighting far more than the maximum 551bs. proposed herein and the lack offlammable fuel, anyrisk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations ofthe UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119. 14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "
...to the elevation ofthe 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 ofsafety will be achieved bythe operator, pursuantto the safety,check list and live flight data monitoring, confirmingthe altitude ofthe launch site shown on the GPS altitude indicator before flight. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "aflight in an airplane underVFRconditions unless (consideringwind and forecast weatherconditions)there is enough fuel to fly to the first pointof intended landing, and, assumingnormal cruising speed- (1)Duringthe day, to fly afterthat for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The battery powering the UAS provides approximately 25 minutes ofpowered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately I0 minutes in length. Given the limitations on the UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope ofprior exemptions. Operatingthe UAS, in a tightly controlled areawhere onlypeople and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engenderthe type ofrisks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limitingUAS flights to 10 minutes would greatlyreducethe
8utility for which the exemption will be granted. Applicantbelievesthat an equivalentlevel ofsafetycan be achieved by limiting flights to 25 minutes or 25% ofbatterypower, whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (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 certificaterequired byparagraph (a) ofthis section ora special flight authorization issued under §91.715 is displayed atthe cabin orcockpit 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 such, there is no ability or place to carry certification and registration documents orto display them on the UAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them to the extentthey are applicable to the UAS. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpartE ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section,have discrepanciesrepaired as prescribedin part43 ofthischapter
...,"and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will not applyto the applicant. Maintenance will be accomplished by the operatorpursuantto the flight manual and operating handbook. An equivalent level ofsafety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. An equivalent level ofsafety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's UserManual. As provided in the FOM, the operator will ensure that the UAS is in working orderpriorto initiating flight and perform required maintenance
9needed. 

### Public Interest 

### The exemptionrequest will permit Stevens Aircraft Solutions, LLC to operate sUAS's commercially for the purpose ofaerial filming andphotographing inspections ofinfrastructure, aerial acquisition (mapping), real estate, and other applicable areas. StevensAircraft Solutions, LLC willprovide a servicethatis beneficialto anindustrythatis alreadyusing, and seekingto use, sUAS's for these purposes with a legal and safe option. This will benefitthepublic withthe controlled operation ofsUAS'sandincreaseintegrationinto theNationalAirspace System (NAS). Stevens Aircraft Solutions sUASs are batterypowered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionallyutilizedto obtain aerial imagery. By reducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa sUAS wouldreduce the amount ofmanned aircraft inthe NAS, reduce noise and airpollution, as well as increase the safetyoflife and property inthe air and onthe ground. Conducting aerial acquisitions with StevensAircraft Solutions sUASs, instead ofmanned aircraft, will greatlybenefitthepublicbydrasticallyreducingthe levels ofairand noisepollutiongenerated during traditional aerial survey flight operations. Previouslyhigh resolution digital aerial real estatephotography was only affordable to a few select agencies with deeppockets. Stevens Aircraft Solutions, LLC would like to help change this by employing our sUASs and make aerial photography affordable to everyone. High quality aerial imagery and data canprovide new and enhanced information about a location being surveyed, inspected, orotherwise measured Additional Information The applicant and primary pilot, James Stevens, has an in-depth understanding ofthe capabilities and safety concerns involved in using this technology as an asset to the community. In addition, James Stevens, holds an Airline Transport Pilot Certificate for Multi-EngineLand Airplanes, as well as holds a second class medical. Satisfaction ofcriteria provided in Section 333 oftheReform Act of2012 provide more than adequatejustification for the grant ofthe requested exemptions allowing the commercial operation ofthe applicant's UAS. Sincerely, 

# q**~ 0~**  James Stevens- Owner Stevens Aircraft Solutions, LCC



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