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Stevens Aircraft Solutions, LLC 

James Stevens, Owner 

345 Jolee Way 

Paducah, KY 42001 

270-559-1489 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Steve 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and P~rt 11 of the 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 CFR 91.121; 

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: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 

CFR Part 11, Stevens Aircraft Solutions, LCC, operator of an Unmanned Aircraft System (UAS), 

hereby applies for an exemption from the listed Federal Aviation Regulations (F ARs) to allow 

commercial operation of its 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 of an 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 inciuding television, public. 

events, cinematography and news gathering. 

e Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority. 

• Aerial inspect-ion/photography of residential/commercial utility infrastructure including but 

not limited to electrical power lines, wind turbines and cell towers. 

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345 Jolee 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 of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation. 

• The ability to offer training to persons individually or belonging to both private and/or public 

organizations that have interests in the use and application of a U AS for the purpose of the safe 

operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for 

the protection of the persons and property. 

As described fully below, the requested exemption would permit the operation of a UAS under 

controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will 

provide safety enhancements to the already safe operations in the industry presently using conventional 

aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA Administrator's) responsibilities to " .... establish requirements for the safe 

operation of such aircraft systems in the national airspace system." 

The name and address ofthe applicant is: 

Stevens Aircraft Solutions, LLC 

James Stevens - Owner 

270-559-1489 

Emai I: j stevens@stevensaircraftso I uti on s. 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 CFR 91.109 

14 CFR 91. 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) 

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Stevens Aircraft Solutions, LLC will operate the following aircraft: 

• Yuneec Q500 Typhoon models 

• DJI Phantom 3 Professional I Advanced 

• DJI Inspire 1 

• xCraft X Plus One Platinum 

Stevens Aircraft Solutions, LLC will operate the Yuneec Electric Aviation Model Q500 Typhoon 

UAS, with a total weight of 1700g or 4.75 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 a cruising speed of 6. 7 m/s or 15 mph. The Yuneec Q500 Typhoon has the ability to 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 3 s 11.1 v Lithium Polymer battery. 

There are four counter rotating 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 of 5.728GHz- 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 DJI Phantom 3 Professional and Advanced has a maximum speed of no 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 by a 4480 mAh, 15.2v Lithium Polymer battery. The DJI Phantom 3 Professional and 

Advanced will be controlled with one or two DJI transmitters with an operating frequency of2.4GHz2.483GHz. The live video feed with have an operating frequency of 5.78 GHz- 5.85GHz. 

Stevens Aircraft Solutions, LLC will also operate the DJI Inspire 1 UAS 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 of no 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 1 has four motors, model number DJI 3510, powered by a 4500 mAh, 

6s, 22.2v Lithium Polymer battery. There are four propellers, model DJI 1345 in use. The DJI Inspire I 

will be controlled with one or two DJI transmitters with a operating frequency of 2.4GHz- 2.483GHz. 

The live video feed with have an operating frequency of 5.78 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 of no 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, 11.1 v 

Lithium Polymer battery. The Xcraft XplusOne Platinum will be controlled with one or two Xcraft 

transmitters with an operating frequency of 2.4GHz- 2.483GHz. The live video feed with have an 

operating frequency of 5. 78 GHz- 5.85GHz. 

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The applicant will operate the UAS in line of sight within a closed off and predetermined area owned 

and/operated by the property representative. 

Given the small size of the UAS and the controlled environment provided, the proposed operations will 

adhere to the Reform Act's safety requirements. The approval of this application presents no national 

security issues. Regarding the level of safety surrounding the proposed operations and the public 

benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, 

the grant of the 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 of safety. Because of 

these limitations, our operations will further enhance the safety of the 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 of no more than 60 mph. 

• A Visual Observer (VO) may be utilized when the Pilot in Command (PIC) deems necessary to 

assist with the safe operation of the flight. 

• Flights will be operated within line of sight of the 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 of flight time, or 25% battery power reserve, whichever occurs first. 

• Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and 

not more than 200 feet above an elevated platform from which filming is planned. 

• Minimum crew for each operation will consist of the 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 Sport Pilot's Certificate. If the PIC feels another operator is needed, they must be qualified 

with the necessary skills to be PIC & possess the satisfactory Sport Pilot written exam, be able 

to meet and comply with medical requirements of the Sport Pilot Certificate, then that person 

may be designated PIC provided they have a minimum of20 hours of flight time with the UAS. 

• A briefing will be performed regarding the planned UAS operations prior to each day's flight 

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consisting of all the day's production activities. 

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

• The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference 

Point (ARP) of a tower controlled or uncontrolled airport. 

• If operations will be within a 5 mile radius of the geographic center/ Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport the respective airports will be contacted 

advising them of the estimated flight time, flight duration, elevation of flight and other 

pertinent information. If requested by the airport manager or A TC facility, a Flight Service 

Station will be contacted for appropriate filing of a Notice to Airmen (NOT AM) of authorized 

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 of all persons involved with the 

planned operation and ensure that only consenting persons will be allowed within 50 feet of the 

flight operation, and the radius may be reduced to 20 feet based upon an equivalent level of 

safety determination, with the exception of one person standing next to the PIC for observation 

of photo/video performance, so long as the flight is not conducted over the PIC. With the 

advanced permission of the FSDO, operations at closer range of additional persons may be 

approved. 

• The PIC and VO will have been trained in operation ofUAS and receive up-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 

city jurisdictions, including law enforcement, fire or other appropriate governmental agencies. 

• If the 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 U AS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

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 the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H 

meets the requirements of an equivalent level of safety under Part II and Section 333 of the Reform 

Act. The Federal Aviation Act (49 U.S.C.§4470I (f)) and Section 333 ofthe 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 

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particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS 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 under this exemption will be tightly 

controlled and monitored by both the operator and under the requirements and in compliance with local 

public safety requirements. These safety enhancements provide a greater degree of safety 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 of these same criteria demonstrates that there is 

no credible threat to national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial 

external load. 

14 C.F .R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally 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. Given the size of the UAS, two-inch lettering will be impossible. The word "Experimental" will 

be placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety 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 Pilot Privileges and Limitations: Pilot in Command. 

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot 

in command of an aircraft that is carrying passengers or property for compensation or hire. Stevens 

Aircraft Solutions , LCC may achieve an equivalent level of safety as achieved by current Regulations 

because the applicant's UAS do not carry any pilots or passengers nor property. 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 of the 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. 

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14 C.F.R. §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 siz~ of the aircraft for 

maintenance and use of safety check lists prior to each flight an equivalent level of safety will be 

provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 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 or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, 

but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of 

safety will be maintained by keeping the flight manual at the ground control point where the pilot flying 

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 

of flight. 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 

takeoff distances and aircraft performance data before initiation of flight. 

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 of a 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 number of aircraft and for flight instruction in experimental aircraft. The equivalent level 

of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft 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. As this 

exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes 

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up 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. It will 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 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 filming 

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

operations with aircraft or rotorcraft weighting far more than the maximum 551bs. proposed herein and 

the lack of flammable fuel, any risk 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 of the 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 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, pursuant to the safety, check list and live flight data monitoring, confirming the altitude of the 

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 "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 battery powering the UAS provides approximately 25 minutes of powered flight. To meet the 30 

minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately I 0 

minutes in length. Given the limitations on the UAS's proposed flight area and the location of its 

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 of prior 

exemptions. Operating the UAS, in a tightly controlled area where only people and property owners or 

official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve 

fuel, does not engender the type of risks that Section 91.151 (a) was intended to alleviate given the size 

and speed ofthe small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the 

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utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can 

be achieved by limiting flights to 25 minutes or 25% of battery power, 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 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 such, 

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 control point 

where the pilot flying the UAS will have immediate access to them to the extent they 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 subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter ... ," and 

others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to 

the flight manual and operating handbook. An equivalent level of safety 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. If mechanical 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 of any 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 of safety. 

An equivalent level of safety will be achieved because maintenance and inspections will be performed 

in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will 

ensure that the UAS is in working order prior to initiating flight and perform required maintenance 

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needed. 

Public Interest 

The exemption request will permit Stevens Aircraft Solutions, LLC to operate sUAS's 

commercially for the purpose of aerial filming and photographing inspections of infrastructure, 

aerial acquisition (mapping), real estate, and other applicable areas. Stevens Aircraft Solutions, 

LLC will provide a service that is beneficial to an industry that is already using, and seeking to use, 

sUAS's for these purposes with a legal and safe option. This will benefit the public with the 

controlled operation of sUAS's and increase integration into the National Airspace System (NAS). 

Stevens Aircraft Solutions sUASs are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By 

reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption 

allowing the use of a sUAS would reduce the amount ofmanned aircraft in the NAS, reduce noise 

and air pollution, as well as increase the safety of life and property in the air and on the ground. 

Conducting aerial acquisitions with Stevens Aircraft Solutions sUASs, instead of manned aircraft, 

will greatly benefit the public by drastically reducing the levels of air and noise pollution generated 

during traditional aerial survey flight operations. Previously high resolution digital aerial real 

estate photography was only affordable to a few select agencies with deep pockets. 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 can provide new and 

enhanced information about a location being surveyed, inspected, or otherwise measured 

Additional Information 

The applicant and primary pilot, James Stevens, has an in-depth understanding of the 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-Engine Land Airplanes, as well as holds 

a second class medical. Satisfaction of criteria provided in Section 333 ofthe Reform Act of2012 

provide more than adequate justification for the grant of the requested exemptions allowing the 

commercial operation of the applicant's UAS. 

Sincerely, 

q 0~ ~ 

James Stevens- Owner 

Stevens Aircraft Solutions, LCC 

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