February 25, 2016

William Clint Henderson, Owner

Crozier & Henderson Productions, Inc.

5151 Belt Line Rd, Suite 101

Dallas, TX 75254

(972) 661 1975

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140

Washington, DC 20590

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA), I, William Clint Henderson, referred to hereafter as the petitioner, hereby 

apply, on behalf of Crozier & Henderson Productions, Inc., operator of Unmanned 

Aircraft Systems (UAS), for an exemption from the listed Federal Aviation 

Administration Regulations (“FARs”) to allow commercial operation of its UAS in 

airspace regulated by the FAA, so long as such operations are conducted within 

and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333.

I hereby formally request exemption from the following sections of Title 14, Code 

of Federal Regulations (14 CFR).

Part 21, 45.23 (b), 61.113 (a) & (b), 91.7 (a), 91.9 (b) (2), 91.103 (b), 91.109, 

91.119, 91.121, 91.151 (a), 91.203 (a) & (b), 91.405 (a), 91.407 (a) (1), 91.409 (a) 

(2), 91.417 (a) & (b).

This proposed exemption would allow the operation of UAS for the purposes of

aerial videography, cinematography, photography, surveys of land, event 

documentation, and other flight operations that could be performed safely and 

more cost-effectively with the use of lightweight small UAS at low altitude within 

the United States National Airspace System (NAS), as compared to manned 
aircraft. The safe operation of the UAS will be the highest priority at all times 

during the pre-flight, flight, and post-flight operations. Operations will be 

performed only at the request of, and with the authorization and permission of 

representatives of Crozier & Henderson Productions, Inc. and associated clients, 

including their authorized agents. In addition to the activities mentioned above, 

operations shall include aerial videography and photography for public and/or 

private use, including real estate, architecture, land surveying, public and private 

events, news-gathering and other activities for both broadcast and non-broadcast 

applications.

Safety considerations

In order to ensure safe operations of the UAS, we will adhere to the following 

practices and protocols: the petitioner will only operate in strictly controlled 

environments that are monitored for safety throughout the operation. Operations 

shall be conducted in areas that are at a safe distance from power lines, airports,

elevated lights, and actively-populated areas. Operations shall always be 

conducted in a reasonable and responsible manner. Extensive pre-flight 

inspections will be conducted and protocols will be followed with safety being the 

primary concern. UAS will weigh less than 55 pounds. All UAS operations will be 

conducted at Visual Line Of Sight (VLOS) at no more than 400 feet altitude (AGL). 

No UAS operations will be conducted within 5 nautical miles (NM) of an airport.

All non-participating persons shall be a minimum of 150 feet from the UAS.

During operation, a warning sign shall be posted, reading “Attention: Aerial 

videography in progress. Remain back 150 feet.” If a non-participating person 

comes within 150 feet of the UAS, flight operations will cease immediately. All 

UAS operations shall take place during daylight hours under conditions equivalent 

to Visual Flight Rules (VFR) with the UAS no more than 1,000 feet from the Pilot In 

Charge (PIC) and UAS controller. All UAS operations will have a PIC and a Visual 

Observer (VO) present and all operations will be within line of sight (LOS) of the 

PIC and VO. The UAS will yield to all manned aircraft at all times. Flight time will 

be limited to 5-20 minutes per flight. All required permits and permissions will be 

obtained from local and state government should they be required. At no time 

shall the UAS be operated with missing or manufacturer-unapproved parts, or in 

any condition that could pose a hazard to any other aircraft or structure or person 

on the ground.

The following UAS shall be used in the operations of aerial videography and 

photography:
DJI Phantom 3 Professional four-rotor UAS and future versions

DJI Inspire 1 and future versions

3DR Solo and future versions

As the Reform Act allows the FAA to “establish requirements for the safe 

operation of such aircraft systems in the national airspace system”, the UAS

mentioned above will provide features that will enhance or provide an equivalent 

level of safety, and offer a lightweight, small and compact video/photo acquisition 

platform compared to manned aircraft. Based on UAS specifications, the DJI 

Phantom 3 Professional, DJI Inspire 1, and 3DR Solo offer significant safety, noise, 

emission, security and environmental benefits not available to larger manned 

aircraft.

The UAS

The DJI Phantom 3 Professional is a small rotorcraft in the quadcopter 

configuration with numerous safety features and weighs approximately 2.8 

pounds (1280g). It is designed primarily to carry aloft a high definition camera. It 

has an advertised maximum speed of less than 32 knots (16m/s) and a maximum 

climb rate of less than 1000 feet per minute (5 m/s). It is powered by four electric 

motors with a distance between motors of less than 12 inches (289.5mm). It 

utilizes an internal inertial measuring unit (IMU) with integrated barometric

sensor augmented with global positioning system (GPS) to maintain its geospatial

orientation and position. It is controlled primarily through an FCC certified radio 

control (RC) unit. Real time video and telemetry information is transmitted back 

to a ground control station allowing the operator and/or PIC to monitor battery 

level, GPS signal strength, altitude (AGL), and distance from PIC, camera imagery, 

and control camera angle. It has failsafe modes of operation for either loss of RC 

or GPS signal. The onboard flight controller can limit altitude and maximum 

altitude can be preprogrammed by the PIC. Battery life limits flight times to 

approximately 23 minutes. The onboard flight controller will warn the pilot via 

telemetry and external lighting cues before reaching a low battery state. An 

automatic termination of flight and landing will be initiated when the battery 

reaches a predetermined low state. It is anticipated that flights will usually last

less than 10 minutes. More information is available at

http://www.dji.com/product/phantom-3-pro.
The DJI Inspire 1 relies on a GPS-based stabilization system that – thanks to spatial 

awareness – is able to hold a position even when experiencing wind interference, 

can compensate for overly aggressive pilot inputs to help avoid stalling, 

automatically brings the aircraft home in the event of signal loss or at the press of 

a button, and makes possible a number of semi-automated flight modes that can 

be enabled through the controller app. This UAS has a built-in capability to limit 

the height it flies above the ground, to limit the radius of the distance it flies from 

the operator and to exclude it from Class B, C and D airspace, including a no-flyzone feature. This UAS also has the failsafe function of the Naza-M autopilot 

system, which means when the communication between the main controller and 

the transmitter is disconnected, the outputs of all command sticks from controller 

will go to the center position. If the GPS signal is good enough, the system will

automatically trigger Return to Home and will land safely. More information is

available at http://www.dji.com/product/inspire-1.

The 3DR Solo offers unique safety features such as a pause button on the 

controller, an adjustable preconfigured flight ceiling, in-app flight zone 

information and alerts, and “safety net” which allow users to fly with confidence. 

The 3DR Solo also has an emergency brake button on the controller, which 

can freeze the UAS in its flight until the pilot is ready to begin flying the UAS again.

The dual built-in computers constantly monitor your flight with 500 parameters of 

flight data, 20 times a second. More information is available at 

https://3dr.com/solo-drone/.

Operations utilizing the DJI Phantom 3 Professional, DJI Inspire 1, and 3DR Solo

will provide a benefit to the general public and serve the public interest by 

providing the services of aerial videography and photography to numerous 

businesses and individuals for considerably less expense, and at an equivalent or 

enhanced level of safety as compared to the only option previously available of 

utilizing manned aircraft.

Benefits for Public interest

Use of the UAS, as opposed a manned aircraft, would enhance safety and reduce 

the environmental impact as compared to similar operations conducted with 

manned aircraft of greater proportions, carrying a crew and flammable fuel. 

Additionally, use of the UAS in order to facilitate commerce could lead to 

economic growth. Operations for this petition will allow the public to view 

geographic areas, properties and homes in a way that cannot be displayed 
through ground level videography or photography. It will also enable service for 

property owners or their designees seeking an enhanced perspective for 

displaying and showcasing characteristics, amenities, and benefits of their 

communities and properties. Aerial videography and photography are valuable 

marketing tools that can lead to increased commerce and enhance personal visual 

presentations. Aerial surveying and inspections can help to increase work site

efficiency and reduce risks. 

Conclusion

The petitioner is requesting this exemption for the purposes of aerial 

videography, cinematography, photography, surveys of land, and other flight 

operations that could be performed safely and more cost-effectively with the use 

of small UAS at low altitude within the United States national airspace system, as 

compared to manned aircraft. We would like to offer services to the public that 

allow an affordable option for aerial representation of communities, properties, 

public and private events, and other materials in a visual experience that was 

previously only available through the prohibitively costly use of manned aircraft. 

We would also like to provide a service that could not be achieved through the 

use of large manned aircraft. Small UAS offer the ability to provide otherwise 

unavailable aerial views of a subject in small spaces with less than adequate 

clearance. Thank you for your consideration. I look forward to hearing from you. 

Please let me know if I can provide any additional information to aid in your 

consideration of this petition.

Sincerely,

William Clint Henderson, Owner

Crozier & Henderson Productions, Inc.

5151 Belt Line Rd, Suite 101

Dallas, TX 75254

(972) 661 1975