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 , S E 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 , referr ed to hereafter as the p etitioner , hereby apply, on behalf of Crozi er & H enderson 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 und er 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 purpose s 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 alt itude within
the United States National A irspace S ystem (NAS) , as co mpared to mannedaircraft

. 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,

o perations shall include aerial videography and photography for public and/or private use, in cluding 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 ensu re 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 , air ports, 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 s hall be a minimum of 15 0 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 15 0 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 1,0 00 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 permission s 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 F AA to “establish requirements for the safe operation of such aircraft systems in th e 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 com pact video /photo acquisition platform compared to manned aircraft. Based on UAS specifications, t he 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

c onfiguration with numerous safety features and weighs approximately 2.8 pounds (1280g) . It is designed primarily to carry aloft a high definition came ra. 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

u tilizes 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 t ime video and telemetry information is transmitted back

t o 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 fai lsafe 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 usua lly 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 w ind interference, can compensate for over ly 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 fl ies 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

- fly

zon e feature. This UAS also has the failsafe function of the Naza

- M autopilot system, which means when the communication between the m ain c ontroller 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 pre configured 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 UA S 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 individua ls 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 t o economic growth. Operations for this petition will allow the public to view geographic areas, properties and homes in a way that cannot be displayedthrough 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, am enities, and benefits of their
communities and properties . Aerial videography and photography a re valuable marketing tool s that can lead to increased commerce and e nhance 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 serv ices 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 Producti ons, Inc. 5151 Belt Line Rd, Suite 101 Dallas, TX 75254 (972) 661 1975