# Navas Films

OFFICE 183-10 Gore Creek Dr. Vail,CO 81657

PHONE 9704764660

CELL 9704764632

EMAIL Jnavasfilms@gmail.com February 03, 2016

Federal	Avia+on	Administra+on

US	Department	of	Transporta+on Docket	Management	System 1200	New	Jersey	Ave.	S.E Washington,	DC		20590

To	Whom	It	May	Concern:

This	applica+on	is	being	submiNed	on	my	own	behalf.

Pursuant	to	Sec+on	333	of	the	FAA	Moderniza+on	and	Reform	Act	of	2012 (the	Reform	Act)	and	14	C.F.R.	Part	11,	Navas	Films,	hereby	seeks	and applies	for	an	exemp+on	to	the	Federal	Avia+on	Regula+ons	(FARs)	to	allow Navas	Films	to	operate	Small	Unmanned	AircraW	Systems	(sUAS	and	UAS) commercially	in	airspace	regulated	by	the	Federal	Avia+on	Administra+on (FAA)	under	the	condi+ons	and	limita+ons	set	forth	in	this	pe++on	or	as	may be	established	by	the	FAA	as	required	by	Sec+on	333.1.	The	requested exemp+on	would	permit	Navas	Films	to	operate	sUAS	for	the	purpose	of providing:

• Aerial	photography	and/or	video	for	public	and/or	private	use	including	real

estate,	architecture,	land	surveying,	engineering,	construc+on	and	other related	professional	ac+vi+es;

• Aerial	video	and/or	photography	for	public	and/or	private	use	including

television,	public	events,	cinematography	and	news	gatherings;

• Aerial	inspec+on/photography	of	residen+al/commercial	structures,	either

exis+ng	or	under	construc+on,	under	contract	with	the	owners	or	local government	authority; 

# Navas Films

OFFICE 183-10 Gore Creek Dr. Vail,CO 81657

PHONE 9704764660

CELL 9704764632

EMAIL Jnavasfilms@gmail.com• Aerial	video/photography	or	providing	live	video	feed	to	assist	with	rescue and	recovery	opera+ons	in	cases	of	an	emergency	or	natural	disaster	only when	the	local	authori+es	or	government	has	requested	it	in	wri+ng	and with	the	proper	authority.

• The	UAS	for	the	proposed	opera+on	is	the	Solo	made	by	3DR.	Weight	3.3 lbs,	max	speed	55	mph.

As	described	more	fully	below,	the	requested	exemp+on	would	permit	the opera+on	of	small,	unmanned	and	rela+vely	inexpensive	sUAS	under controlled	condi+ons	in	airspace	that	is:

1. Limited; 2. Predetermined; 3. Access	Controlled; 4. A	safety	enhancement	by	limi+ng	exposure	of	flight	and	ground crews,	vehicles,	and	structures	to	the	weight,	speed,	fuel consump+on,	and	paths	of	conven+onal	aircraW	presently	used	in the	NAS	for	these	types	of	ac+vi+es.

Approval	of	this	exemp+on	would	thereby	enhance	safety	and	fulfill	the Secretary	of	Transporta+on’s	(the	FAA	Administrator’s)	responsibili+es	to “...establish	requirements	for	the	safe	opera+on	of	such	aircraW	systems	in the	na+onal	airspace	system.”	Sec+on	333(c)	of	the	Reform	Act.	The	name and	address	of	the	applicant	is:

Navas	Films Contact:	Jorge	A.	Navas 183-10	Gore	Creek	Dr Vail,	CO	81657 jnavasfilms@gmail.com
970-476-4632

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# Navas Films

OFFICE 183-10 Gore Creek Dr. Vail,CO 81657

PHONE 9704764660

CELL 9704764632

EMAIL Jnavasfilms@gmail.comRegula+ons	from	which	the	exemp+on	is	requested: 14	CFR	61.113	(a)	&	(b)	14	CFR	91.9	(b)	(2)	14	C.F.R.	91.103	14	C.F.	R.	91.119 14	C.F.R.	91.121	14	CFR	91.151	(a)	14	CFR	91.405	(a)	14	CFR	407	(a)	(1)	14 CFR	409	(a)	(2)	14	CFR	417	(a)	&	(b)

This	exemp+on	applica+on	is	expressly	submiNed	to	fulfill	Congress’	goal	in passing	Sec+on	333(a)	through	(c)	of	the	Reform	Act.	This	law	directs	the Secretary	of	Transporta+on	to	consider	whether	certain	unmanned	aircraW systems	may	operate	safely	in	the	na+onal	airspace	system	(NAS)	before comple+on	of	the	rule	making	required	under	Sec+on	332	of	the	Reform

Act.	In	making	this	determina+on,	the	Secretary	is	required	under	Reform Act	§	333(b)	to	determine	which	types	of	UASs	do	not	create	a	hazard	to users	of	the	NAS	or	the	public	or	pose	a	threat	to	na+onal	security	in	light of	the	following:

•	The	UAS’s	size,	weight,	speed,	and	opera+onal capability; •	Opera+on	of	the	UAS	in	close	proximity	to	airports	and populated	areas;	and •	Opera+on	of	the	UAS	within	visual	line	of	sight	of	the operator.

Lastly,	if	the	Secretary	determines	under	Reform	Act	§	333(c)	that	such vehicles	“may	operate	safely	in	the	na+onal	airspace	system,	the	Secretary shall	establish	requirements	for	the	safe	opera+on	of	such	aircraW	in	the na+onal	airspace	system.”

The	Federal	Avia+on	Act	expressly	grants	the	FAA	the	authority	to	issue exemp+ons.	This	statutory	authority	by	its	terms	includes	exemp+ng	civil aircraW,	as	the	term	is	defined	under	§40101	of	the	Act,	that	includes sUASs,	from	the	requirement	that	all	civil	aircraW	must	have	a	current airworthiness	cer+ficate.

Applicant	interprets	this	provision	to	place	the	duty	on	the	Administrator	to not	only	process	applica+ons	for	exemp+ons	under	sec+on	333,	but	for	the Administrator	to	craW	condi+ons	for	the	safe	opera+on	of	the	sUAS,	if	it	should be	determined	that	the	condi+ons	set	forth	herein	do	not	fulfill	the	statutory requirements	for	approval.

The	Administrator	may	grant	an	exemp+on	from	a	requirement	of	a	regula+on prescribed	under	subsec+on	(a)	or	(b)	of	this	sec+on	or	any	sec+ons 44702-44716	of	this	+tle	if	the	Administrator	finds	the	exemp+on	in	the	public interest.	49	U.S.C.	§44701(f)	See	also	49	USC	§44711(a);	49	USC	§44704;	14 CFR	§91.203	(a)	(1).

The	primary	vehicle	to	be	used	will	be	the	Solo	by	3DR.	While	vehicles	may	be upgraded	as	new	technological	and	safety	advanced	occur	the	bar	for

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# Navas Films

OFFICE 183-10 Gore Creek Dr. Vail,CO 81657

PHONE 9704764660

CELL 9704764632

EMAIL Jnavasfilms@gmail.comopera+on	and	safety	will	be	set	by	Solo	and	any	new	vehicles	or	versions will	exceed	the	current	safety	and	opera+onal	standards.	No	vehicle operated	by	Navas	Films	will	be	modified	from	the	manufacturers	design unless	specifically	directed	by	the	same	manufacturer.

Given	the	small	size	and	weight	of	our	sUASs,	the	applicant	falls	squarely within	that	zone	of	safety	(an	equivalent	level	of	safety)	in	which	Congress envisioned	that	the	FAA	must,	by	exemp+on,	allow	commercial	opera+ons of	UASs	to	commence	immediately.	Also	due	to	the	size	of	the	UASs	and	the restricted	areas	in	which	the	relevant	sUASs	will	operate,	approval	of	the

applica+on	presents	no	na+onal	security	issue.	Given	the	clear	direc+on	in Sec+on	333	of	the	Reform	Act,	the	authority	contained	in	the	Federal Avia+on	Act,	as	amended;	the	strong	equivalent	level	of	safety surrounding	the	proposed	opera+ons,	and	the	significant	public	benefit, including	enhanced	safety,	reduc+on	in	environmental	impacts,	including reduced	emissions	associated	with	allowing	UASs	for	photography,	the grant	of	the	requested	exemp+ons	is	in	the	public	interest.	Accordingly, the	applicant	respeclully	requests	that	the	FAA	grant	the	requested exemp+on	without	delay.

AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY

The	applicant	proposes	that	the	exemp+on	requested	herein	apply	to	civil aircraW	that	have	the	characteris+cs	and	that	operate	with	the	limita+ons listed	herein.	Such	opera+ons	will	insure	that	the	sUAS	will	“not	create	a hazard	to	users	of	the	na+onal	airspace	system	or	the	public.”	These limita+ons	provide	for	at	least	an	equivalent	or	even	higher	level	of	safety to	opera+ons	under	the	current	regulatory	structure	because	the	proposed opera+ons	represent	a	safety	enhancement	to	the	already	safe	filming opera+ons	conducted	with	conven+onal	aircraW.

These	limita+ons	and	condi+ons	to	which	Navas	Films	agrees	to	be	bound when	conduc+ng	commercial	opera+ons	under	an	FAA	issued	exemp+on include: 1. The	sUAS	will	weigh	less	than	55 lbs.; 2. Flights	will	be	operated	within	line	of	sight	of	the	pilot	in command	and/or	observer; 3. The	UAS	will	weigh	less	than	55 lbs. 4. The	UAS	will	have	a	maximum	opera+ng	speed	of	no	more than	55 mph; 5. Maximum	flight	+me	for	each	opera+onal	flight	will	be	25 minutes.	Flights	will	be	terminated	at	25%	baNery	power reserve	or	19 minutes	of	flight	+me	whichever	occurs	first; 6. Flights	will	be	operated	at	al+tude	of	no	more	than	400	feet AGL	or	no	more	than	200	feet	above	an	equivalent	plalorm from	which	filming	is	planned; 7. sUAS	Pilot	will	be	Pilot	in	Command	(PIC)

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# Navas Films

OFFICE 183-10 Gore Creek Dr. Vail,CO 81657

PHONE 9704764660

CELL 9704764632

EMAIL Jnavasfilms@gmail.com8. All	flights	will	occur	under	visual	flight	rules	meteorological condi+ons	(VFR	only); 9. WriNen	and/or	oral	permission	from	the	relevant	property	holders will	be	obtained; 10. If	the	UAS	loses	communica+ons	with	the	remote	controller	or loses	GPS	signal,	the	UAS	will	have	the	capability	to	return	to	a pre-determined	loca+on	within	a	designated	loca+on	and land;

As	of	March	23,	2015,	the	FAA	will	automa+cally	grant	a	"blanket"	COA	for

flights	at	or	below	200	feet	to	any	UAS	operator	with	a	Sec+on	333 exemp+on,	provided	the	aircraW	weighs	less	than	55	pounds,	opera+ons are	conducted	during	day+me	Visual	Flight	Rules	(VFR)	condi+ons and	within	visual	line	of	sight	(VLOS)	of	the	PIC,	and	stay	certain	distances away	from	airports	or	heliports.

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Cer+ficates	14	C.F.R.	§91.203 (a)	(1)	Subpart	H,	en+tled	Airworthiness	Cer+ficates,	establishes	the procedural	requirements	for	the	issuance	of	airworthiness	cer+ficates	as required	by	FAR	§91.203	(a)	(1).	Given	the	size	and	limited	opera+ng	area associated	with	the	aircraW	to	be	u+lized	by	the	Applicant,	an	exemp+on from	Part	21	Subpart	H	meets	the	requirements	of	an	equivalent	level	of safety	under	Part	11	and	Sec+on	333	of	the	Reform	Act.	The	Federal Avia+on	Act	(49	U.S.C.§44701	(f))	and	Sec+on	333	of	the	Reform	Act	both authorize	the	FAA	to	exempt	aircraW	from	the	requirement	for	an airworthiness	cer+ficate,	upon	considera+on	of	the	size,	weight,	speed, opera+onal	capability,	and	proximity	to	airports	and	populated	areas	of	the par+cular	UAS.	In	all	cases,	an	analysis	of	these	criteria	demonstrates	that the	UAS	operated	without	an	airworthiness	cer+ficate,	in	the	restricted environment	and	under	the	condi+ons	proposed	will	be	at	least	as	safe,	or safer,	than	a	conven+onal	aircraW	(fixed	wing	or	rotorcraW)	opera+ng	with an	airworthiness	cer+ficate	without	the	restric+ons	and	condi+ons	proposed.

The	sUAS	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	area.	Unlike	other	civil aircraW,	opera+ons	under	this	exemp+on	will	be	+ghtly	controlled	and monitored	by	the	operator.	These	safety	enhancements	provide	a	greater degree	of	safety	to	the	public	and	property	owners	than	conven+onal opera+ons	conducted	with	airworthiness	cer+ficates	issued	under	14	C.F.R. Part	21,	Subpart	H.

Lastly,	applica+on	of	these	same	criteria	demonstrates	that	there	is	no	credible threat	to	na+onal	security	posed	by	the	UAS,	due	to	its	size,	speed	of opera+on,	loca+on	of	opera+on,	lack	of	explosive	materials	or	flammable liquid	fuels,	and	inability	to	carry	a	substan+al	external	load.

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# Navas Films

OFFICE 183-10 Gore Creek Dr. Vail,CO 81657

PHONE 9704764660

CELL 9704764632

EMAIL Jnavasfilms@gmail.com14	C.F.R.	§	45.23	(b).	Marking	of	the	AircraW.	The	regula+on	requires: When	marks	include	only	the	Roman	capital	le5er	"N" and	the	registra9on	number	is	displayed	on	limited, restricted	or	light-sport	category	aircra=	or experimental	or	provisionally	cer9ficated	aircra=,	the operator	must	also	display	on	that	aircra=	near	each entrance	to	the	cabin,	cockpit,	or	pilot	sta9on,	in le5ers	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	cer+ficate,	an	exemp+on may	be	needed	as	the	UAS	has	no	entrance	to	a	cabin,	cockpit	or	pilot sta+on	on	which	the	word	“Experimental”	can	be	placed.	Given	the	size	of the	sUAS,	two-inch	leNering	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	sUAV	marked on	its	fuselage	as	required	by	§45.29	(f)	where	the	pilot,	observer	and others	working	with	the	sUAV	will	see	the	iden+fica+on	of	the	UAS	as “Experimental.”

No	person	may	operate	a	U.S.-registered	civil	aircraW	... For	which	an	Airplane	or	Rotorcra=	Flight	Manual	is not	required	by	§21.5	of	this	chapter,	unless	there	is available	in	the	aircra=	a	current	approved	airplane	or Rotorcra=	Flight	Manual,	approved	manual	material, markings,	and	placards,	or	any	combina9on	thereof.

The	sUAS,	given	its	size	and	configura+on	has	no	ability	or	place	to	carry such	a	flight	manual	on	the	aircraW,	not	only	because	there	is	no	pilot	on board,	but	because	there	is	no	room	or	capacity	to	carry	such	an	item	on	the aircraW.

The	equivalent	level	of	safety	will	be	maintained	by	keeping	the	flight	manual at	the	ground	control	point	where	the	pilot	flying	the	sUAS	will	have immediate	access	to	it.	The	FAA	has	issued	the	following	exemp+ons	to	this regula+on:	Exemp+on	Nos.	8607,	8737,	8738,	9299,	9299A,	9565,	9565B, 10167,	10167A,	10602,	32827,	and	10700.

14	C.F.R.	§	91.103:	Preflight	ac+on.	This	regula+on	requires	each	pilot	in command	to	take	certain	ac+ons	before	flight	to	insure	the	safety	of	flight.	As FAA	approved	rotorcraW	flight	manuals	will	not	be	provided	for	the	aircraW	an exemp+on	will	be	needed.	An	equivalent	level	of	safety	will	be	provided	by	the PIC	in	checking	the	sUAS	before	each	flight	for	physical	condi+on,	calibra+on	of instruments	as	required	by	the	sUAS	manual,	and	ensuring	that	all	flight surfaces	and	controls	are	consistent	with	safe	flight.	The	PIC	will	take	all

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# Navas Films

OFFICE 183-10 Gore Creek Dr. Vail,CO 81657

PHONE 9704764660

CELL 9704764632

EMAIL Jnavasfilms@gmail.comac+ons	including	reviewing	weather,	flight	baNery	requirements,	landing and	takeoff	distances	and	aircraW	performance	data	before	ini+a+on	of flight.

14	C.F.R.	§91.109:	Flight	instruc+on.	Sec+on	91.103	provides	that	no	person may	operate	a	civil	aircraW	(except	a	manned	free	balloon)	that	is	being used	for	flight	instruc+on	unless	that	aircraW	has	fully	func+oning	dual controls.	sUASs	and	remotely	piloted	aircraW,	by	their	design	do	not	have fully	func+onal	dual	controls.	Flight	control	is	accomplished	through	the	use of	a	control	box	that	communicates	with	the	aircraW	via	radio

communica+ons.	The	FAA	has	approved	exemp+ons	for	flight	training without	fully	func+onal	dual	controls	for	a	number	of	aircraW	and	for	flight instruc+on	in	experimental	aircraW.	See	Exemp+on	Nos.5778K	&	9862A. The	equivalent	level	of	safety	provided	by	the	fact	that	neither	a	pilot	nor passengers	will	be	carried	in	the	aircraW	and	by	the	size	and	speed	of	the aircraW.

14	C.F.R.	§91.119:	Minimum	safe	al+tudes.	Sec+on	91.119	establishes	safe al+tudes	for	opera+on	of	civil	aircraW.	Sec+on	91.119	(d)	allows	helicopters to	be	operated	at	less	than	the	minimums	prescribed,	provided	the	person opera+ng	the	helicopter	complies	with	any	route	or	al+tudes	prescribed	for helicopters	by	the	FAA.	As	this	exemp+on	is	for	a	sUAS	that	is	a	helicopter and	the	exemp+on	requests	authority	to	operate	at	al+tudes	up	to	400 AGL,	or	not more	than	200	above	an	elevated	plalorm	from	which	filming is	planned,	an	exemp+on	may	be	needed	to	allow	such	opera+ons.	As	set forth	herein,	except	for	the	limited	condi+ons	stated	in	the	Manual,	the UAS	will	never	operate	at	higher	than	400	AGL.	It	will	however	be	operated in	a	restricted	area	with	security	perimeter,	where	buildings	and	people	will not	be	exposed	to	opera+ons	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	loca+on	where	it	is	operated.	No	flight	will	be	taken without	the	permission	of	the	property	owner	or	local	officials.	Because	of	the advance	no+ce	to	the	property	owner	and	par+cipants	in	the	filming	ac+vity, all	affected	individuals	will	be	aware	of	the	planned	flight	opera+ons. Compared	to	flight	opera+ons	with	aircraW	or	rotorcraW	weighing	far	more than	the	maximum		5	lbs.	proposed	herein	and	the	lack	of	flammable	fuel,	any risk	associated	with	these	opera+ons	is	far	less	than	those	presently	presentedwith	conven+onal	aircraW	opera+ng	at	or	below	500	AGL.	In	addi+on,	the	lowal+tude	opera+ons	of	the	sUAS	will	ensure	separa+on	between	these	sUAS opera+ons	and	the	opera+ons	of	conven+onal	aircraW	that	must	comply	with Sec+on	91.119.

14	C.F.R.	§91.121	Al+meter	Sevngs.	This	regula+on	requires	each	person opera+ng	an	aircraW	to	maintain	cruising	al+tude	by	reference	to	an	al+meter that	is	set	“...to	the	eleva+on	of	the	departure	airport	or	an	appropriate al+meter	sevng	available	before	departure.”	As	the	sUAS	may	not	have	a

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# Navas Films

OFFICE 183-10 Gore Creek Dr. Vail,CO 81657

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EMAIL Jnavasfilms@gmail.combarometric	al+meter,	but	instead	a	GPS	al+tude	read	out,	an	exemp+on may	be	needed.	An	equivalent	level	of	safety	will	be	achieved	by	the operator,	pursuant	to	the	Manual	and	Safety	Check	list,	confirming	the al+tude	of	the	launch	site	shown	on	the	GPS	al+tude	indicator	before	flight.

14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Condi+ons. Sec+on	91.151	(a)	prohibits	an	individual	from	beginning	“a	flight	in	an airplane	under	VFR	condi+ons	unless	(considering	wind	and	forecast weather	condi+ons)	there	is	enough	fuel	to	fly	to	the	first	point	of	intended landing,	and,	assuming	normal	cruising	speed	–	(1)	During	the	day,	to	fly

aWer	that	for	at	least	30	minutes;	or	(2)	At	night,	to	fly	aWer	that	for	at least	45	minutes.”	The	baNery	powering	the	sUAS	provides	approximately 25	minutes	of	powered	flight.	To	meet	the	reserve	requirement	in	14	CFR §91.151,	sUAS	flights	would	be	limited	to	no	more	than	19	minutes	in length.	Given	the	limita+ons	on	the	UAS’s	proposed	flight	area	and	the loca+on	of	its	proposed	opera+ons	within	a	predetermined	area,	a	longer +me	frame	for	flight	in	daylight	or	night	VFR	condi+ons	is	not	required.

Applicant	believes	that	an	exemp+on	from	14	CFR	§91.151(a)	falls	within the	scope	of	prior	exemp+ons.	See	Exemp+on	10673	(allowing	Lockheed Mar+n	Corpora+on	to	operate	without	compliance	with	FAR	91.151	(a)). Opera+ng	the	sUAS	in	a	+ghtly	controlled	area	where	only	people	and property	owners	or	official	representa+ves	who	have	signed	waivers	will	be allowed,	with	less	than	30	minutes	of	reserve	fuel,	does	not	engender	the type	of	risks	that	Sec+on	91.151(a)	was	intended	to	alleviate	given	the	size and	speed	of	the	sUAS.	Addi+onally,	limi+ng	sUAS	flights	to	no	more	than 19	minutes	would	greatly	reduce	the	u+lity	for	which	the exemp+on	will	be granted.

Applicant	believes	that	an	equivalent	level	of	safety	can	be	achieved	by limi+ng	flights	to	19	minutes	or	25%	of	baNery	power	whichever	happens first.	This	restric+on	would	be	more	than	adequate	to	return	the	sUAS	to	its planned	landing	zone	from	anywhere	in	its	limited	opera+ng	area.

Similar	exemp+ons	have	been	granted	to	other	opera+ons,	including Exemp+ons	2689F,	5745,	10673,	and	10808.

14	C.F.R.	§91.203	(a)	and	(b):	Carrying	Civil	AircraW	Cer+fica+on	and Registra+on.	The	regula+on	provides	in	per+nent	part:

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

1) An	appropriate	and	current	airworthiness	cer+ficate.	.	.	.

Page 8 

# Navas Films

OFFICE 183-10 Gore Creek Dr. Vail,CO 81657

PHONE 9704764660

CELL 9704764632

EMAIL Jnavasfilms@gmail.comb) No	person	may	operate	a	civil	aircraW	unless	the airworthiness	cer+ficate	required	by	paragraph (a)	of	this	sec+on	or	a	special	flight	authoriza+on 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	cer+fica+on

and	registra+on	documents	or	to	display	them	on	the	sUAS.	An	equivalent level	of	safety	will	be	achieved	by	keeping	these	documents	at	the	ground control	point	where	the	pilot	flying	the	sUAS	will	have	immediate	access to	them,	to	the	extent	they	are	applicable	to	the	sUAS.	The	FAA	has	issued numerous	exemp+ons	to	this	regula+on.	A	representa+ve	sample	of	other excep+ons	includes	Exemp+on	Nos.	9565,	9665,	9789,	9789A,	9797, 9797A,	9816A,	and	10700.

14	C.F.R.	§91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b):	Maintenance Inspec+ons.	These	regula+ons	require	that	an	aircraW	operator	or	owner “shall	have	that	aircraW	inspected	as	prescribed	in	subpart	E	of	this	part and	shall	between	required	inspec+ons,	except	as	provided	in	paragraph (c)	of	this	sec+on,	have	discrepancies	repaired	as	prescribed	in	part	43	of this	chapter...,”	and	others	shall	inspect	or	maintain	the	aircraW	in compliance	with	Part	43.	Given	that	these	sec+on	and	Part	43	apply	only	to aircraW	with	an	airworthiness	cer+ficate,	these	sec+ons	will	not	apply	to the	applicant.	Maintenance	will	be	accomplished	by	the	operator	pursuant to	the	flight	manual.	An	equivalent	level	of	safety	will	be	achieved	because these	small	UASs	are	very	limited	in	size	and	will	carry	a	small	payload	and operate	only	in	restricted	areas	for	limited	periods	of	+me.	If	mechanical issues	arise	the	UAS	can	land	immediately	and	will	be	opera+ng	from	no higher	than	400	feet	AGL.	As	provided	in	the	Manual,	the	operator	will ensure that	the	UAS	is	in	working	order	prior	to	ini+a+ng	flight,	perform	required maintenance,	and	keep	a	log	of	any	maintenance	performed.	Moreover,	the operator	is	the	person	most	familiar	with	the	aircraW	and	best	suited	to maintain	the	aircraW	in	an	airworthy	condi+on	to	provide	the	equivalent	level of	safety.

The	opera+on	of	small	UASs,	weigh+ng	less	than	55	lbs.,	conducted	in	the strict	condi+ons	outlined	above,	will	provide	an	equivalent	level	of	safety suppor+ng	the	grant	of	the	exemp+ons	requested	herein,	including	exemp+ng the	applicant	from	the	requirements	of	Part	21	and	allowing	commercial opera+ons.	These	lightweight	aircraW	operate	at	slow	speeds,	close	to	the ground,	and	in	a	sterile	environment	and,	as	a	result,	are	far	safer	than conven+onal	opera+ons	conducted	with	turbine	helicopters	opera+ng	in	close proximity	to	the	ground	and	people.

Page 9 

# Navas Films

OFFICE 183-10 Gore Creek Dr. Vail,CO 81657

PHONE 9704764660

CELL 9704764632

EMAIL Jnavasfilms@gmail.comPrivacy.	All	flights	will	occur	over	private	or	controlled	access	property	with the	property	owner’s	prior	consent	and	knowledge.	Any	people	in	the	area that	might	be	filmed	will	have	also	consented	to	being	filmed	or	otherwise have	agreed	to	be	in	the	area	where	filming	will	take	place.

Sa+sfac+on	of	the	criteria	provided	in	Sec+on	333	of	the	Reform	Act	of 2012--size,	weight,	speed,	opera+ng	capabili+es,	proximity	to	airports	and populated	areas	and	opera+on	within	visual	line	of	sight	and	na+onal security	–	provide	more	than	adequate	jus+fica+on	for	the	grant	of	the requested	exemp+ons	allowing	commercial	opera+on	of	applicant’s	UAS	for

the	purposes	and	under	the	condi+ons	stated	above.

Sincerely, Jorge	A.	Navas Sole	Proprietor NavasFilms 183-10	Gore	Creek	Dr. Vail,	CO	81657 jnavasfilms@gmail.com 970-476-4632

Page 10 

# Navas Films

OFFICE 183-10 Gore Creek Dr. Vail,CO 81657

PHONE 9704764660

CELL 9704764632

EMAIL Jnavasfilms@gmail.comPage 11Page 12Page 13Page 14Page 15Page 16Page 17