IN THE MATTER OF THE PETITION FOR EXEMPTION 

OF: BENJAMIN H. CHENTNIK 

FOR AN EXEMPTION SEEKING RELIEF FROM THE 

REQUIREMENTS OF TITLE 14 OF THE CODE OF 

FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), AND 91.417(a) & (b) CONCERNING 

COMMERCIAL OPERATION OF 3D ROBOTICS SOLO 

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO 

SECTION 333 OFTHE FAA MODERNIZATION AND 

REFORM ACT OF 2012 (PUBLIC LAW 112­95) 

Submitted on April 25, 2015 

BENJAMIN H. CHENTNIK 

1460 Via De Pepi

Boynton Beach, FL 33426

TABLE OF CONTENTS 

GLOSSARY OF ABBREVIATIONS.................................3 

SUMMARY...............................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER.........4 

BACKGROUND.........................................................4 

BASIS FOR PETITION.................................................5 

NAME AND ADDRESS OF PETITIONER.........................8 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH 

BENJAMIN H. CHENTNIK SEEKS EXEMPTION...............8 
THE EXTENT OF RELIEF BENJAMIN H. CHENTNIK SEEKS 

AND THE REASON BENJAMIN H. CHENTNIK SEEKS THE 

RELIEF....................................................................12 

THE REASONS WHY GRANTING BENJAMIN H. CHENTNIK 

REQUEST WOULD BE IN THE PUBLIC INTEREST...........16 

THE REASONS WHY GRANTING THE EXEMPTION 

WOULD NOT ADVERSELY AFFECT SAFETY..................20 

CONCLUSION...........................................................39 

AGL AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL N

AS NOTAM PIC Section 333 Section 333 SO 

SOP UA UAS VFR VLOS VMC VTOL 

GLOSSARY OF ABBREVIATIONS 

Above Ground Level Area of Interest Air Traffic Control Air 

Traffic Organization Aerial Vehicle 

Code of Federal Regulations Certificate of Authorization Federal 

Aviation Administration Federal Aviation Regulation Ground 

Control Station 

Global Positioning System Loss of Link National Airspace System 

Notice to Airman 

Pilot In Command FAA Modernization and Reform Act of 2012 

(FMRA) 

Safety Observer Standard Operating Procedures Unmanned 

Aircraft Unmanned Aircraft System Visual Flight Rules Visual 

Line of Site Visual Meteorological Conditions Vertical Takeoff 

and Landing
SUMMARY 

Benjamin H. Chentnik seeks exemption from the requirements of 

14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &

(b), to operate an Unmanned Aircraft System pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA). 

This exemption will permit Benjamin H. Chentnik to operate an 

Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial video and photography, cell tower land and 

infrastructure inspection for civil operations within the United 

States of America. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

My name is Benjamin H. Chentnik, I am 29 years old and a recent 

graduate of Digital Media Arts College (DMAC) in Boca Raton, 

Florida. I have started a boutique sized design/marketing agency 

specializing in web design, graphic design, animation, marketing, 

photography, and videography. I would like to be able to offer 

aerial photography and videography to my clients as a safer and 

more cost efficient alternative to the traditional method of using a 

helicopter and SLR camera.

BACKGROUND 

Unmanned Aircraft Systems: 3D Robotics Solo UAS

Benjamin H. Chentnik seeks an exemption to operate 3D Robotics 

systems for compensation or hire within the NAS. The 3D 

Robotics Solo is a vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA). These UAS’s use a Ground Control Station (GCS), 

displayed on an electronic tablet or smartphone. The 3D Robotics 

Solo has a maximum gross weight of approximately 3 pounds 4 

ounces, a length of 18 inches width of 18 inches, height of 10 

inches, and a maximum speed of approximately 47.8 knots. The 

3D Robotics Solo UAS is equipped with four main rotors; driven
by Lithium Polymer battery powered electric motors. 

The 3D Robotics Solo UAS that will be operated by Benjamin H. 

Chentnik will be registered in accordance with 49 U.S.C. 44103,

Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45,

Identification and Registration Marking.

BASIS FOR PETITION 

Petitioner, Benjamin H. Chentnik, pursuant to the provisions of the 

Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA 

Modernization and Reform Act of 2012 (FMRA), Section 333,

Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the 3D 

Robotics Solo UAS in the National Airspace System (NAS), and 

for an exemption from the requirements of 14 C.F.R §§ 61.113(a) 

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating 

area associated with the unmanned aircraft and its operation, 

Benjamin H. Chentnik operation of 3D Robotics Solo UAS meets 

the conditions of FMRA Section 333 and therefore, will not 

require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. 

Accordingly, Benjamin H. Chentnik requests relief from Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b), as these sections set forth requirements for maintenance that 

only apply to aircraft with an airworthiness certificate. 

Benjamin H. Chentnik submits that the requested relief is proper 

since an equivalent level of safety will be ensured. Benjamin H. 

Chentnik will use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS's 

using the methods, techniques, and practices prescribed in the 
operating documents (i.e., Monthly Maintenance Log, and 3D 

Robotics Solo Instruction Manual). Furthermore, Benjamin H. 

Chentnik will document and maintain all maintenance records for 

the 3D Robotics Solo UAS. 

Relief from certain requirements of Section 61.113(a) and (b), 

entitled Private pilot privileges and limitations: Pilot in command,

is requested by Benjamin H. Chentnik to the extent necessary to 

allow a Pilot in Command (PIC) holding a private pilot or higher 

level certificate, as well as an airman medical certificate, and who 

has demonstrated, by meeting minimum flight- hour and currency 

requirements, that the PIC is able to safely operate the 3D Robotics 

Solo UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Benjamin H. Chentnik seeks relief from Section 91.7(a), entitled

Civil aircraft airworthiness, because the 3D Robotics Solo UAS 

does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, Benjamin H. Chentnik submits 

that he will ensure that the 3D Robotics Solo UAS is in an 

airworthy condition, prior to every flight, by determining that the 

UAS is in compliance with the operating documents (i.e., Monthly 

Maintenance Log, and 3D Robotics Solo Instruction Manual), and 

that the aircraft is in a condition for safe flight. 

Benjamin H. Chentnik also seeks an exemption from the 

requirements of Section 91.121, entitled Altimeter Settings, as the 

3D Robotics Solo UAS will not have a typical barometric altimeter 

onboard. However, altitude information of the 3D Robotics Solo 

UAS will be provided to the PIC via Global Positioning System 

(GPS) equipment and radio communications telemetry data link, 

which downlinks from the UA to the GCS for active monitoring of 

the flight path. This altitude information, combined with Benjamin 

H. Chentnik’s operation of the 3D Robotics Solo UAS within 

visual line of sight, at or below 500 feet AGL, will ensure a level 
of safety equivalent to Section 91.121. 

Additionally, Benjamin H. Chentnik seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel requirements for 

flight in VFR conditions. Benjamin H. Chentnik submits that safety 

will not be affected by operation of the 3D Robotics Solo UAS 

during daylight hours in visual meteorological conditions (VMC) 

under visual flight rules (VFR), with enough battery power to fly 

for a total duration of approximately 15 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after 

that for at least 5 minutes. 

In accordance with 14 C.F.R. § 11.81, Benjamin H. Chentnik 

provides the following information in support of its petition for 

exemption: 

A. Name And Address Of The Petitioner. 

The name and address of the Petitioner and point of contact is: 

Benjamin H. Chentnik 

1460 Via De Pepi

Boynton Beach, FL 33426

315-225-4032

Ben@lucidprints.biz

B. The Specific Sections Of 14 C.F.R. From Which Benjamin 

H. Chentnik Seeks Exemption. 

1. Benjamin H. Chentnik Seeks Exemption From The 

Requirements Of Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations:

Pilot in command, subsections (a) and (b) prescribe the following, 

in relevant part: 
(a) No person who holds a private pilot certificate may act as a 

pilot in command (PIC) of an aircraft that is carrying passengers or 

property for compensation or hire; nor may that person, for 

compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an 

aircraft in connection with any business or employment if—

(1) The flight is only incidental to that business or employment; 

and 

(2) The aircraft does not carry passengers or property for 

compensation or hire. 

2. Benjamin H. Chentnik Seeks Exemption From The 

Requirements Of Section 91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), 

states the following: 

(a) No person may operate a civil aircraft unless it is in an 

airworthy condition. 

3. Benjamin H. Chentnik Seeks Exemption From The 

Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states 

the following, in part: 

(a) Each person operating an aircraft shall maintain the cruising 

altitude or flight level of that aircraft, as the case may be, by 

reference to an altimeter that is set, when operating-- 

(1) Below 18,000 feet MSL, to-- 

(i) The current reported altimeter setting of a station along the 

route and within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph 
(a)(1)(i) of this section, the current reported altimeter setting of an 

appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the 

elevation of the departure airport or an appropriate altimeter setting 

available before departure. 

4. Benjamin H. Chentnik Seeks Exemption From The 

Requirements Of Section 91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR 

conditions, subsection 

(b), states the following: 

(b) No person may begin a flight in a rotorcraft 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, to fly after that for 

at least 20 minutes. 

5. Benjamin H. Chentnik Seeks Exemption From The 

Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), 

states the following: Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of 

this part and shall between required inspections, except as provided 

in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter.

6. Benjamin H. Chentnik Seeks Exemption From The 

Requirements Of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, subsection (a)(1), states the 

following: 
(a) No person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration 

unless-- 

(1) It has been approved for return to service by a person 

authorized under § 43.7 of this chapter.

7. Benjamin H. Chentnik Seeks Exemption From The 

Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the 

following: (a) Except as provided in paragraph (c) of this section, 

no person may operate an aircraft unless, within the preceding 12 

calendar months, it has had -- 

(1) An annual inspection in accordance with part 43 of this chapter 

and has been approved for return to service by a person authorized 

by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. 

8. Benjamin H. Chentnik Seeks Exemption From The 

Requirements Of Sections 91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and 

(b), state the following: 

(a) Except for work performed in accordance with §§ 91.411 and 

91.413, each registered owner or operator shall keep the following 

records for the periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and 

alteration and records of the 100-hour, annual, progressive, and 

other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft. The records must include-- 
(i) A description (or reference to data acceptable to the 

Administrator) of the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving 

the aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the 

aircraft which are required to be overhauled on a specified time 

basis. 

(iv) The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) 

and safety directives including, for each, the method of 

compliance, the AD or safety directive number and revision date. 

If the AD or safety directive involves recurring action, the time and 

date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for 

each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the 

periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall 

be retained until the work is repeated or superseded by other work 
or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall 

be retained and transferred with the aircraft at the time the aircraft 

is sold. 

(3) A list of defects furnished to a registered owner or operator 

under § 43.11 of this chapter shall be retained until the defects are 

repaired and the aircraft is approved for return to service. 

C. The Extent Of Relief Benjamin H. Chentnik Seeks And The 

Reason Benjamin H. Chentnik Seeks The Relief. 

1. Extent Of Relief Benjamin H. Chentnik Seeks And The 

Reason Benjamin H. Chentnik Seeks Relief From Section 

61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot 

privileges and limitations: Pilot in command, is requested to the 

extent necessary to allow a PIC holding a private pilot or higher 

level certificate, as well as a current and valid airman medical 

certificate, and who has met certain flight-hour and currency 

requirements, to conduct the proposed UAS flight operations for 

compensation or hire. 

This relief is requested since the limitations set forth in Section 

61.113(a) and (b) state that a private pilot may, for compensation 

or hire, act as PIC of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or 

employment; and (2) The aircraft does not carry passengers or 

property for compensation or hire. 

As set forth more fully below, Benjamin H. Chentnik submits that 

an equivalent level of safety will be maintained because no PIC 

will be allowed to operate the 3D Robotics Solo UAS unless that 

PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate either the 3D 
Robotics Solo UAS in a manner consistent with the operations 

specifications as described in this exemption, including evasive 

and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Further, Benjamin H. Chentnik submits that all flights of the 3D 

Robotics Solo UAS conducted by the PIC pursuant to the grant of 

this Petition: (1) will be incidental to Benjamin H. Chentnik's 

business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent Of Relief Benjamin H. Chentnik Seeks And The 

Reason Benjamin H. Chentnik Seeks Relief From Section 

91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is 

requested to the extent required to allow Benjamin H. Chentnik to 

determine that the 3D Robotics Solo UAS is in airworthy condition 

prior to every flight by ensuring that the UAS is in compliance 

with the operating documents (i.e., the Benjamin H. Chentnik 

Aerial Operations Manual, Monthly Maintenance Log, 3D 

Robotics Solo Instruction Manual). 

Benjamin H. Chentnik seeks the requested relief because the 3D 

Robotics Solo UAS does not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, 

Benjamin H. Chentnik will ensure that the 3D Robotics Solo UAS 

is in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and 3D 

Robotics Solo Instruction Manual) prior to every flight, and 

further, determine that the aircraft are in condition for safe flight, 

as stated in the conditions and limitations below. 

3. Extent Of Relief Benjamin H. Chentnik Seeks And The 

Reason Benjamin H. Chentnik Seeks Relief From Section 

91.121. 
Relief from Section 91.121, entitled Altimeter settings, may be 

required to allow flight operations of the 3D Robotics Solo UAS, 

which utilize a barometric pressure sensor, GPS equipment, and a 

radio communications telemetry data link to downlink altitude 

information from the UA to the PIC at the ground control station 

(GCS). Since the FAA requires that any altitude information 

concerning UAS operations be reported to air traffic control (ATC) 

in feet above ground level (AGL), Benjamin H. Chentnik seeks the 

requested relief because the 3D Robotics Solo UAS’ altimeter may 

be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief 

from 14 CFR 91.121 is sought to the extent necessary to comply 

with the applicable conditions and limitations stated below. As 

more fully set forth herein, an equivalent level of safety will be 

maintained since the 3D Robotics Solo UAS is equipped with a 

barometric pressure sensor and GPS equipment, which 

automatically ensures that a g round level pressure setting will be 

established prior to each flight, and provides the PIC with altitude 

information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief Benjamin H. Chentnik Seeks And The 

Reason Benjamin H. Chentnik Seeks Relief From Section 

91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight 

in VFR conditions, is requested to the extent required to allow 

flights of the battery powered 3D Robotics Solo UAS during 

daylight hours in visual meteorological conditions (VMC), under 

visual flight rules (VFR), for a total duration of 15 minutes to the 

first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 5 minutes. Benjamin H. Chentnik 

seeks the requested relief because without an exemption from 

Section 91.151(b), the flight time duration of the battery powered 

3D Robotics Solo UAS will severely constrain the practicality of 
any aerial video or still photo flight operations that Benjamin H. 

Chentnik proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the 

3D Robotics Solo UAS, the 3D Robotics Solo UAS operating 

documents, and Benjamin H. Chentnik’s proposed operating 

limitations, ensure that Benjamin H. Chentnik will safely operate 

the battery powered 3D Robotics Solo UAS during daylight hours 

in visual meteorological conditions (VMC), under visual flight 

rules (VFR), with enough battery power to fly for a total duration 

of 15 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 5 minutes. 

5. Extent Of Relief Benjamin H. Chentnik Seeks And The 

Reason Benjamin H. Chentnik Seeks Relief From Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & 

(b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b) only apply to aircraft with an airworthiness 

certificate, Benjamin H. Chentnik requests relief from these 

Sections because the 3D Robotics Solo UAS does not require 

airworthiness certificates. As set forth more fully below, the 3D 

Robotics Solo UAS meets the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, 

Benjamin H. Chentnik will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS's 

using the methods, techniques, and practices prescribed in the UAS 

operating documents (i.e., the Benjamin H. Chentnik Aerial 

Operations Manual, Monthly Maintenance Log, and the 3D 

Robotics Solo Instruction Manual). Furthermore, Benjamin H. 

Chentnik will document and maintain all maintenance records for 

the 3D Robotics Solo UAS. 

D. The Reasons Why Granting Benjamin H. Chentnik Request 

Would Be In The Public Interest; That Is, How It Would 
Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by 

allowing Benjamin H. Chentnik to safely, efficiently, and 

economically perform aerial video and photography of 

construction sites, real estate, and landscape over certain areas of 

the United States. 

Additionally, use of the 3D Robotics Solo UAS will decrease 

congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. Notably, the benefits of Benjamin H. 

Chentnik’s proposed operation of the 3D Robotics Solo UAS will 

be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The 

NAS. 

The 3D Robotics Solo UAS is 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 3D Robotics Solo UAS would 

reduce the amount of manned 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 g round. 

Furthermore, by reducing the number of manned aircraft operating 

in the NAS, congestion around airports caused by arriving and 

departing aircraft will be reduced. The 3D Robotics Solo UAS 

does not require an airport to takeoff or land. Likewise, a reduction 

of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air 

traffic control during the ground, takeoff, departure, arrival, and 

landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of 

The 3D Robotics Solo UAS.
Conducting aerial acquisitions with the 3D Robotics Solo UAS, 

instead of manned aircraft, will greatly benefit the public by 

drastically reducing the levels of air and noise pollution generated 

during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the 3D 

Robotics Solo UAS produces no air pollution, and is the most 

viable environmentally conscious alternative to the cabin class, six 

cylinder internal combustion engine aircraft that are typically 

utilized for aerial video and photography, while burning 

approximately 20-30 gallons per hour of leaded aviation fuel. The 

3D Robotics Solo UAS, while reducing the carbon footprint of 

aerial acquisitions, also eliminates noise pollution, as the UAs are 

propelled by battery powered electric motors, rather than an 

internal combustion engine. 

By using the 3D Robotics Solo UAS to perform aerial acquisitions,

the substantial risk to life and property in the air and on the ground, 

which is usually associated with traditional manned aircraft flight 

operations, will be substantially reduced or completely eliminated. 

Aside from the lack of flight crew members located onboard the 

aircraft, the 3D Robotics Solo UAS (weighing approximately 3

pounds 4, at the maximum gross weights with lengths of 18 inches, 

widths of 18 inches, and with no fuel on board), has less physical 

potential for collateral damage to life and property on the ground, 

and in the air, compared to the manned aircraft that typically 

conduct similar operations (weighing approximately 6,000 pounds 

with a wingspan of approximately 42 feet, a length of 34 feet, and 

a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With 

The 3D Robotics Solo UAS Will Benefit The Economy. 

In addition to being safe and efficient, the 3D Robotics Solo UAS 

is also an economical alternative to using manned aircraft to 

conduct similar aerial operations. As such, operation of the 3D 

Robotics Solo UAS will allow United States based companies, like 
Benjamin H. Chentnik and Lucid Prints Inc., to remain competitive 

and contribute to growth of the U.S. economy. Specifically, with 

the rising cost of aviation fuel and the Environmental Protection 

Agency (“EPA”) regulatory actions phasing out leaded aviation 

fuels, U.S. owned and operated companies must adopt new and 

alternative technology in order to remain competitive. Operating 

the battery powered 3D Robotics Solo UAS is one such technology 

that not only allows companies greater operational flexibility 

compared to manned aircraft, but provides such flexibility without 

the high operational cost of a traditional manned aircraft. 

By operating the 3D Robotics Solo UAS, companies such as Lucid 

Prints Inc. (Benjamin H. Chentnik), can remain competitive and 

profitable, and therefore, provide greater job stability to employees 

and contractors, which will ultimately contribute to growth of the 

U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of the 3D Robotics Solo UAS, 

provides a stable workforce that increases consumer spending; 

improves local, state, and federal tax revenues; and allows 

companies to invest in research and development in order to 

remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have 

been conducted for decades, Benjamin H. Chentnik’s proposed 

operation of the 3D Robotics Solo UAS will not implicate any 

privacy issues. Specifically, the 3D Robotics Solo UAS will be 

operated only in compliance with operating documents (i.e. 

Monthly Maintenance Log, and the 3D Robotics Solo Instruction 

Manual) which requires property owner involvement as well as 

local law enforcement notification, and in accordance with the 

Federal Aviation Regulations, including the minimum altitude 

requirements of 14 C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not 
Adversely Affect Safety, Or How The Exemption Would 

Provide A Level Of Safety At Least Equal To That Provided 

By The Rule From Which Benjamin H. Chentnik Seeks 

Exemption. 

1. Reasons Why The 3D Robotics Solo UAS Meet The 

Conditions Of The FAA Modernization and Reform Act of 

2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating 

area associated with the unmanned aircraft and its operation, 

Benjamin H. Chentnik’s operation of the 3D Robotics Solo UAS 

meets the regulation and conditions of FMRA Section 333, and 

will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without 

airworthiness certification and sets forth requirements for 

considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security. 

Specifically, FMRA Section 333 states the following, in part: 

(a) In General.­­Notwithstanding any other requirement of this 

subtitle, and not later than 180 days after the date of enactment of 

this Act, the Secretary of Transportation shall determine if certain 

unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking 

required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.­­In making the 

determination under subsection (a), the Secretary shall determine, 

at a minimum­­

(1) which types of unmanned aircraft systems, if any, as a result of 

their size, weight, speed, operational capability, proximity to 

airports and populated areas, and operation within visual line of 
sight do not create a hazard to users of the national airspace 

system or the public or pose a threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United 

States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1). 

(c) Requirements for Safe Operation.­­If the Secretary determines 

under this section that certain unmanned aircraft systems may 

operate safely in the national airspace system, the Secretary shall 

establish requirements for the safe operation of such aircraft 

systems in the national airspace system. 

In seeking this exemption, Benjamin H. Chentnik submits that the 

3D Robotics Solo UAS can operate safely in the NAS pursuant to 

FMRA Section 333, as demonstrated by: (a) the characteristics of 

the 3D Robotics Solo UAS; (b) the pilot certification requirement; 

and (c) the specific operating limitations. 

a. The Specifications Of The 3D Robotics Solo UAS

Demonstrate Its Safe Characteristics. 

The 3D Robotics Solo UAS do not create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security 

considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The 3D Robotics Solo UAS.

The technical specifications of the 3D Robotics Solo UAS is set 

forth by the 3D Robotics Solo Specifications and Data Sheet, 

included in the 3D Robotics Solo User Manual that has been 

submitted for reference. 

ii. The 3D Robotics Solo Autonomous Flight And Navigation 

Modes Enable The UAS's To Remain Within A Defined 

Operational Area. 
The 3D Robotics Solo UAS may be operated in both manual and 

fully autonomous flight modes. A complete description of the 

flight and navigational modes of the 3D Robotics Solo UAS is 

included in the 3D Robotics Solo User Manual that has been 

submitted for reference.

iii. The 3D Robotics Solo UAS Is Designed For Automatic 

Return To Home Point Or Hover In The Event Of Loss Of The

Control Link Or Navigation. 

When the Control Link is lost, the 3D Robotics Solo UAS will 

remain stationary, in flight, for 3 seconds or more. 

If, after 3 seconds, the 3D Robotics Solo UAS does not reacquire 

control link data from the GCS, the UAS will assume that the 

Control Link is lost and the UAS will return to the home position 

(i.e., failsafe mode) via GPS, and will descend to the takeoff 

position and shutdown. 

iv. The 3D Robotics Solo, GCS And Its Operation. 

A complete description of the operation and specifications of the 

3D Robotics Solo, GCS and flight control software is provided in 

the 3D Robotics Solo User that has been submitted for reference.

b. Flight Operations Of 3D Robotics Solo UAS Is Limited To 

The Line Of Sight Of A Certificated Pilot in Command With A 

Safety Observer. 

Benjamin H. Chentnik will only utilize certificated pilots who 

possess a current and valid airman medical certificate to act as a 

pilot in command (PIC) of the 3D Robotics Solo UAS. 

Additionally, a safety observer will assist all pilots during flight 

time. 

c. Flights Of 3D Robotics Solo UAS Will Be Conducted 

Pursuant To Specific Operating Limitations. 
In seeking this exemption, Benjamin H. Chentnik proposes to 

commercially operate 3D Robotics Solo UAS for the special 

purpose of conducting aerial video and photography over areas of 

United States that do not pose any safety discrepancies to civilians, 

pursuant to the following specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited 

to the following aircraft described in the operating documents, 

rotorcraft UAS's weighing less than 55 pounds maximum gross 

weight: 3D Robotics Solo, Unmanned Aircraft Systems. Proposed 

operations of any other aircraft will require a new petition or a 

petition to amend this grant. 

2. UAS operations under this exemption will be limited to 

conducting operations for the purpose of aerial video and 

photography. 

3. The UAs may not be flown by any at an indicated airspeed 

exceeding 47.8 knots. 

4. The UA must be operated at an altitude of no more than 500 feet 

above ground level (AGL), as indicated by the procedures 

specified in the operating documents unless a special request is 

made and approved by ATC. All altitudes reported to ATC must be 

in feet AGL. 

5. The UAs must be operated within visual line of sight (VLOS) of 

the PIC at all times. This requires the PIC to be able to use human 

vision unaided by any device other than corrective lenses, as 

specified on the PIC’s FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer 

(SO) is not permitted. 

7. All operations must utilize a safety observer (SO). The SO may 

be used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. The SO and PIC must be able to 
communicate verbally at all times. Electronic messaging or texting 

is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that 

the SO can perform the functions prescribed in the operating 

documents. 

8. The SO must not perform any other duties beyond assisting the 

PIC with seeing and avoiding other air traffic and other ground 

based obstacles/obstructions and is not permitted to operate the 

camera or other instruments. 

9. The operating documents and the grant of exemption must be 

accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the 

conditions and limitations contained in the grant of exemption and 

the procedures outlined in the operating documents, the conditions 

and limitations contained in the grant of exemption take 

precedence and must be followed. Otherwise, the operator must 

follow the procedures as outlined in its operating documents. The 

operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present 

updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it 

petitions for extension or amendment to the grant of exemption. If 

the operator determines that any update or revision would affect 

the basis upon which the FAA granted the exemption, then the 

operator must petition for amendment to its grant of exemption. 

The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating 

documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure 

that it is in a condition for safe flight. If the inspection reveals 

a condition that affects the safe operation of the UAS, the 

aircraft is prohibited from operating until the necessary 
maintenance has been performed and the UAS is found to be 

in a condition for safe flight. The Ground Control Station 

must be included in the preflight inspection. All maintenance 

and alterations must be properly documented in the aircraft 

records. 

11. Any UAS that has undergone maintenance or alterations that 

affect the UAS operation or flight characteristics, e.g. 

replacement of a flight critical component, must undergo a 

functional test flight. The PIC who conducts the functional 

test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential 

discrepancies, e.g. inoperable components, items, or 

equipment, not already covered in the relevant sections of the 

operating documents. 

13. The operator must follow the UAS manufacturer’s 

aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and 

record keeping requirements, in accordance with the 

operating documents. Maintenance, inspection, alterations, 

and status of replacement/overhaul component parts must be 

noted in the aircraft records, including total time in service, 

description of work accomplished, and the signature of the 

authorized person returning the UAS to service. 

15. Each UAS operated under this exemption must comply with 

all manufacturer Safety Bulletins. 

16. The authorized person must make an entry in the aircraft 

record of the corrective action taken against discrepancies 

discovered between inspections. 
17. The PIC must possess at least a private pilot certificate and at 

least a current third- class medical certificate. 

18. The operator may not permit any PIC to operate unless the 

PIC meets the operator’s qualification criteria and 

demonstrates the ability to safely operate the UAS in a 

manner consistent with how the UAS will be operated under 

the exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be 

logged in a manner consistent with 14 C.F.R. § 61.51(b). 

Flights for the purposes of training the operator’s PICs are 

permitted under the terms of the exemption. However, 

training operations may only be conducted during dedicated 

training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight 

operations are considered non-participants, and the PIC must 

operate the UA with appropriate distance from 

nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as 

defined in 14 C.F.R. § 1.1. All operations must be conducted 

under visual meteorological conditions (VMC). If flight at 

night is required, a special request will be made at the FAA 

office closest to proposed area of operations. Flights under 

special visual flight rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport 

reference point as denoted on a current FAA-published 

aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the 

operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator 

upon request. 
21. The UA may not be operated less than 500 feet below or less 

than 2,000 feet horizontally from a cloud or when visibility is 

less than 3 statute miles from the PIC. 

22. If the UA loses communications or loses its GPS signal, it 

must return to a pre-determined location within the planned 

operating area and land or be recovered in accordance with 

the operating documents. 

23. The PIC must abort the flight in the event of unpredicted 

obstacles or emergencies in accordance with the operating 

documents. 

24. The PIC is prohibited from beginning a flight unless 

(considering wind and forecast weather conditions) there is 

enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 25% battery power 

remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) 

issued Certificate of Waiver or Authorization (COA) prior to 

conducting any operations under the grant of exemption. This 

COA will also require the operator to request a Notice to 

Airman (NOTAM) not more than 72 hours in advance, but 

not less than 48 hours prior to the operation. All operations 

shall be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude 

level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must 

be identified by serial number, registered in accordance with 

14 C.F.R. part 47, and have identification (N- Number) 

markings in accordance with 14 C.F.R. part 45, Subpart C. 

Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum 
used for operation and control of the UA must comply with 

the Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 

91.203 must be available to the PIC at the Ground Control 

Station of the UAS any time the UAS is operating. These 

documents must be made available to the Administrator or 

any law enforcement official upon request. 

29. The UA must remain clear and yield the right of way to all 

manned aviation operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving 

device or vehicle. 

31. Flight operations must be conducted at least 500 feet from all 

nonparticipating persons (persons other than the PIC, SO, 

operator trainees or essential persons), vessels, vehicles, and 

structures unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event of 

an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures 

where the owner/controller of such vessels, vehicles or structures 

has granted permission and the PIC has made a safety assessment 

of the risk of operating closer to those objects and determined that 

it does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential 

persons do not present an undue hazard to those persons per § 
91.119(a). 

32. All operations shall be conducted over private or 

controlled-access property with permission from the land 

owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will 

be obtained for each flight to be conducted. 

33. Any incident, accident, or flight operation that transgresses 

the lateral or vertical boundaries of the operational area as 

defined by the applicable COA must be reported to the FAA's 

UAS Integration Office (AFS-80) within 24 hours. Accidents 

must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of 

Section 61.113(a) And (b) Would Not Adversely Affect Safety. 

Benjamin H. Chentnik submits that the equivalent level of safety 

established by Section 61.113(a) and (b) will be maintained 

because no PIC will be allowed to operate the 3D Robotics Solo 

UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to 

safely operate the 3D Robotics Solo UAS in a manner consistent 

with the exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Considering Benjamin H. Chentnik’s proposed area of operations, 

and the operating limitations set forth-above; the parallel nature of 

private pilot aeronautical knowledge requirements to those of 

commercial pilot requirements (See Exemption No. 11062); and 

the airmanship skills necessary to safely operate the 3D Robotics 

Solo UAS, Benjamin H. Chentnik submits that the additional 

manned airmanship experience of a commercially certificated pilot 
would not correlate to the airmanship skills necessary for 

Benjamin H. Chentnik’s specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and 

(b) specific to UAS, in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 

11161). 

Benjamin H. Chentnik will not allow any PIC to operate the 3D 

Robotics Solo UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour requirements or the 3D Robotics Solo UAS 

training and currency requirements, that the PIC is able to safely 

operate the 3D Robotics Solo UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles 

and structures. 

Specifically, the PIC must have accumulated and logged, in a 

manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time 

as a UAS rotorcraft pilot (with a minimum of 5 hours of those 

hours as a UAS pilot operating the same make and model of UAS 

to be used for operations under the exemption). In addition to the 

hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented 

flight experience that was obtained in compliance with applicable 

regulations will ensure an equivalent level of safety during 

Benjamin H. Chentnik’s proposed operations. The Administrator 

has held that prior documented flight experience that was obtained 

in compliance with applicable regulations would ensure safe 

operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to 
conducting operations for the purpose of motion picture filming (or 

similar operations), the PIC must have accumulated and logged, in 

a manner consistent with 14 CFR 61.51(b), 25 hours of total time 

as a UAS rotorcraft pilot including at least 10 hours logged as a 

UAS pilot with a multi-rotor UAS. Prior to operations under 

Exemption No. 11062, the PIC must also have accumulated and 

logged a minimum of 5 hours as a UAS pilot operating the same 

make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum 

hour requirements to be inclusive rather than additive; i.e. 5 hours 

make and model time may be included in the 10 hours of 

multi-rotor time and the 10 hours may be included in the total 25 

hours of UAS rotorcraft time. In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 

90 days (for currency purposes). The FAA finds that at a 

minimum, the flight-hour requirements in Exemption No. 11062 

are appropriate to practice and build proficiency in the skills 

necessary to safely conduct the petitioner’s proposed operations. 

The FAA also finds that prior documented flight experience that 

was obtained in compliance with applicable regulations would 

satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under the grant 

of exemption to accomplish the required flight time. During 

training, proficiency, and experience-building flights the PIC is 

required to operate the UA with appropriate distances in 

accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. Accordingly, Benjamin H. 

Chentnik will ensure safe operations by not allowing any PIC to 

operate the 3D Robotics Solo UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the DJI 

Phantom 2 Vision+, DJI Inspire 1+, or DJI Spreading Wings S800, 

UAS in a manner consistent with the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances 
from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of 

Section 91.7(a) Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will 

be maintained because prior to every flight, Benjamin H. Chentnik 

will ensure that the 3D Robotics Solo UAS is in an airworthy 

condition based upon the UAS’s compliance with its operating 

documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 

91.7(a) specific to UAS, in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

4. Reasons Why An Exemption From The Requirements Of 

Section 91.121 Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will 

be maintained because the altitude information of the 3D Robotics 

Solo UAS will be provided to the PIC via GPS equipment and a 

radio communications telemetry data link, which downlinks from 

the UA to the GCS for active monitoring of the flight path and 

altitude. This altitude information, combined with Benjamin H. 

Chentnik’s operation of the 3D Robotics Solo UAS within visual 

line of sight, at or below 500 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. The altitude information will 

be generated by GPS equipment installed onboard the aircraft. 

Prior to each flight, a zero altitude initiation point is automatically 

established by the UAS's at ground level. 

The FAA has previously granted relief from Section 91.121 

specific to UAS, in circumstances similar, in all material respects, 

to those presented herein (e.g. Exemption Nos. 11062, 11063, 
11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of 

Section 91.151(b) Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of 

safety established by 14 C.F.R. Section 91.151(b) as a result of (1) 

the technical specifications of the 3D Robotics Solo UAS; (2) the 

limitations on the proposed flight operations; and (3) the location 

of the proposed flight operations. Accordingly, Benjamin H. 

Chentnik will ensure that it will safely operate the battery powered 

3D Robotics Solo UAS during daylight hours in VFR conditions, 

with enough battery power to fly for a total duration of 13.5 

minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of 

the 3D Robotics Solo UAS; the limitations on the proposed flight 

operations; and the location of the proposed operations, will ensure 

an equivalent level of safety established by 14 C.F.R. Section 

91.151(b). Furthermore, safety will be ensured as the 3D Robotics 

Solo UAS provides audible and visual warnings to the PIC at the 

GCS when the UAs experiences low battery voltage, the first 

warning occurring at approximately 30% remaining battery power, 

and again at approximately 10% remaining battery power. At the 

critically low battery level of 5%, the 3D Robotics Solo UAS will 

descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning 

Section 91.151 establish that safety is not adversely affected when 

the technical characteristics and operating limitations of the UAS 

are considered. Relief has been granted for manned aircraft to 

operate at less than the minimums prescribed in Section 91.151, 

including Exemption Nos. 2689, 5745, and 10650. Moreover, the 

FAA has previously granted relief from Section 91.151 specific to 
UAS, in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 

11062, 11063, 11064, 11065, 11066, 11067, 11080). 

6. Reasons Why An Exemption From The Requirements Of 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 

91.417(a) & (b) Would Not Adversely Affect Safety. 

In seeking this exemption, Benjamin H. Chentnik submits that the 

equivalent level of safety with regard to the regulatory 

maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

will be met because Benjamin H. Chentnik will use trained 

technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS's using the methods, techniques, and 

practices prescribed in the operating documents (i.e., the Benjamin 

H. Chentnik Aerial Operations Manual, Monthly Maintenance 

Log, and 3D Robotics Solo Instruction Manual). Furthermore, 

Benjamin H. Chentnik will document and maintain all 

maintenance records for the 3D Robotics Solo UAS. 

Since the 3D Robotics Solo UAS will be inspected as prescribed 

by the operating documents, Benjamin H. Chentnik will maintain 

the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). 

Likewise, the exemption sought will not adversely affect safety 

because Benjamin H. Chentnik will use trained technicians to 

perform maintenance, alterations or preventive maintenance on the 

UAS using the methods, techniques, and practices prescribed by 

the operating documents. 

Furthermore, the exemption sought would maintain an equivalent 

level of safety established by Sections 91.407, 91.417(a) and 

91.417(b), because all maintenance of the DJI Phantom 2 Vision+, 

DJI Inspire 1+, and DJI Spreading Wings S800 UAS's will be 
performed by trained technicians. Maintenance will be documented 

and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b) establish that safety is not adversely affected when 

the technical characteristics and operating limitations of the UAS 

are considered. 

In consideration of Benjamin H. Chentnik’s proposed operating 

limitations, the operating documents, and the technical aspects of 

the 3D Robotics Solo UAS, Benjamin H. Chentnik submits that 

safety will not be adversely affected by granting exemption from 

14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 

91.409(a)(2), and 91.417(a) and (b). The FAA has previously 

granted relief specific to UAS in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153). 

7. The FAA May Prescribe Any Other Conditions For Safe 

Operation. 

In accordance with Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled 

Special Conditions, Benjamin H. Chentnik requests that the FAA 

prescribe special conditions for the intended operation of the 3D 

Robotics Solo UAS which contain such safety standards that the 

Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 

14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b). Such special conditions will permit safe operation of the UAs 

for the limited purpose of conducting aerial video and photography 

over certain areas of the United States for compensation or hire. 

FMRA Section 333 sets forth the requirements for considering 
whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security; and further, 

provides the authority for such UAS to operate without 

airworthiness certification in accordance with any requirements 

that must be established for the safe operation of the UAS in the 

NAS. 

Likewise, the Administrator may prescribe special conditions 

pursuant to 14 C.F.R. 

§ 21.16, for operation of the DJI Phantom 2 Vision+, DJI Inspire 

1+, and DJI Spreading Wings S800 UAS's, since the airworthiness 

regulations of 14 C.F.R. Part 21 do not c o n t a i n a d e q u a t e o 

r a p p r o p r i a t e s a f e t y s t a n d a r d s , d u e t o t h e n o v e l 

o r u n u s u a l d e s i g n features of the aircraft. Section 21.16, 

entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this 

subchapter do not contain adequate or appropriate safety standards 

for an aircraft, aircraft engine, or propeller because of a novel or 

unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the 

product. The special conditions are issued in accordance with Part 

11 of this chapter and contain such safety standards for the aircraft, 

aircraft engine or propeller as the FAA finds necessary to establish 

a level of safety equivalent to that established in the regulations. 

See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA 

Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special 

conditions for Peak Performance’s intended operation of the 3D 

Robotics Solo UAS, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 

14 C.F.R 

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 
91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

∙

A Summary That Can Be Published In The Federal Register, 

stating: The Rules From Which Benjamin H. Chentnik Seeks 

Exemption: 

Benjamin H. Chentnik seeks exemption from the requirements of 

14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b). 

A Brief Description Of The Nature Of The Exemption 

Benjamin H. Chentnik Seeks: 

This exemption will permit Benjamin H. Chentnik to commercially 

operate an Unmanned Aircraft System (UAS) for the purpose of 

conducting aerial video and photography over certain areas of the 

United States. 

Any Additional Information, Views, Or Arguments Available 

To Support Benjamin H. Chentnik’s Request. 

This Petition is made pursuant to the FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333, which directs the 

Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, Benjamin H. Chentnik’s 

request for exemption may be granted pursuant to the authority of 

FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security; and further, 

provides the authority for such UAS to operate without 

airworthiness certification. 

As discussed in detail above, Benjamin H. Chentnik will operate 
the 3D Robotics Solo UAS safely in the NAS, without creating a 

hazard to users of the NAS, or the public, or otherwise pose a 

threat to national security. 

CONCLUSION 

As set forth herein, Benjamin H. Chentnik seeks an exemption 

pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA), which will 

permit safe operation of the 3D Robotics Solo UAS commercially, 

without an airworthiness certificate, for the limited purpose of 

conducting aerial video and photography over certain areas of the 

United States. By granting this Petition, the FAA Administrator 

will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the 

interests of the public, by allowing Benjamin H. Chentnik to 

safely, efficiently, and economically operate the 3D Robotics Solo 

UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation 

Regulations and the FAA Modernization and Reform Act of 2012, 

Section 333, Benjamin H. Chentnik respectfully requests that the 

Administrator grant this Petition for an exemption from the 

requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b), and permit Peak Perspective to operate the 

3D Robotics Solo UAS commercially for the purpose of 

conducting aerial video and photography over certain areas of the 

United States. 

Dated: July 16, 2015 

Respectfully submitted, Benjamin H. Chentnik 
Benjamin H. Chentnik

1460 Via De Pepi

Boynton Beach, FL 33426

315-225-4032

ben@lucidprints.biz

www.lpwebdesign.net