Navas Films

OFFICE

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PHONE

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CELL

9704764632

EMAIL

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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

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Vail,CO 81657

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•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	 	

Page 2

Navas Films

OFFICE

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Vail,CO 81657

PHONE

9704764660

CELL

9704764632

EMAIL

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Regula+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	

Page 3

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OFFICE

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opera+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)		

Page 4

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8. 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.	

Page 5

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14	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	

Page 6

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ac+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	presented	

with	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	

Page 7

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barometric	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

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OFFICE

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PHONE

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CELL

9704764632

EMAIL

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b)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.com
Privacy.	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.com
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