Greg Edwards 

Demented Dog Productions, LLC 7/16/15

6545 S Arbutus Cir. #1215

Littleton, CO 80127

info@dementeddogproductions.com

720-583-3886 – company line

Federal Aviation Administration: 

I, Greg Edwards, Managing Partner of Demented Dog Productions, LLC, 

(“DDP”), am writing pursuant to the FAA Modernization and Reform Act of 

2012 and the procedures contained within 14 C.F.R. 11, to request that I, 

Greg Edwards & DDP, an owner and operator of small unmanned aircraft, 

be exempted from the Federal Aviation Regulations (“FARs”) listed below 

so that I, Greg Edwards & DDP, may operate a small ultra light weight 

unmanned aircraft system (“UAS”) commercially in airspace regulated by 

the Federal Aviation Administration (“FAA”) in accordance with FAA UAS 

Regulations & Policies. 

I would like to formally submit DDP and its UAS pilots for an exemption 

from the following Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 

45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 

C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 

91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 

91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b). To operate DJI’s

following UAS: Phantom 3, and Inspire 1 along the guidelines of the 

accompanying DJI Inspire 1, and DJI Phantom 3 Operator’s manuals. These 

UAS will be equipped with detachable cameras and will be transported in 

proper storage. 

This proposed exemption would allow me operation of unmanned aircraft 

systems (UAS) for the purpose of aerial videography/ photography as a 

service to the public/ business interests. As found in exemption No. 11138 

(Trudeau), the FAA recently approved similar use of a DJI UAS. These 

devices were selected because they have proven reliable flying capabilities 

managed by gyro stabilized flight, ground detection (phantom 3 and inspire 

1) ,GPS aided navigation, a compass, blinking LEDs, failsafe mode for 

returning home and prop guards. 
This will act to further safety protocols exclusive to lightweight UAS’s 

specific to video and photography usage as I, Greg Edwards & DDP & DDP, 

record flight data and other information gained through permitted flight 

operations to share with the FAA through any required FAA reports to 

assists with future protocol and safety regulations. Specific section or 

sections of 14 CFR which I seek relief and the reason I seek relief: 14 C.F.R. 

Part 21: Airworthiness Certificates Given the size and limited operating area 

associated with the aircrafts to be utilized by I, Greg Edwards & DDP, an 

exemption from Part 21 meets the requirements of an equivalent level of 

safety under Part 11 and Section 333 of the reform Act. 

In all cases, an analysis of these criteria demonstrates that the UA operated 

without an airworthiness certificate, in the restricted environment and under 

the conditions proposed will be at least as safe, or safer, than conventional 

aircraft operating with an airworthiness certificate without restrictions and 

conditions proposed. 14 C.F.R. 45.23: Display of marks: general The UAs 

will not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which 

to mark certain words or phrases. Further, the two inch lettering is difficult 

to place on such a small aircraft with dimensions smaller than the minimal 

lettering requirement. 14 C.F.R. 61.113(a) & (b): Private pilot privileges and 

limitations: Pilot in command The FAA has previously declared that 

additional manned airship experience of a commercially certified pilot 

would not correlate to the airmanship skills necessary for similarly proposed 

operations in previously issued exemptions to this regulation through 

Exemption Nos. 11062 and 11138. 14 C.F.R 91.7: Civil aircraft 

airworthiness Currently, since there is no certificate applicable to the UAs in 

question, this regulation is inapplicable. 14 C.F.R. 91.9 (b)(2): Civil aircraft 

flight manual, marking, and placard requirements Requires an aircraft flight 

manual in the aircraft, however there are no pilots or passengers on board 

this aircraft and given its size, this regulation is inapplicable. An equivalent 

level of safety will be achieved by maintaining a safety/flight manual with 

the operator. 14 C.F.R. 91.119(c): Minimum safe altitudes I, Greg Edwards 

& DDP will ensure that UAS do not operate any higher than 400 feet at 

ground level. I will not fly over congested areas. I will plan operations 

before hand, for proper flight safety, and proper height analysis as to avoid 

collisions. 14 C.F.R. 91.121: Altimeter settings The UAS utilize electronic 

GPS with a barometric sensor. An equivalent level of safety will be achieved 

by using this. 14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR 

conditions The UAS that I will fly are powered by electricity, using lithium 

polymer batteries that currently have a flight limit of approximately no more 
than 20 minutes. Therefore, due to the limitations of the batteries, it is 

currently impossible to comply with part 91.151. 14 C.F.R. 91.203(a) and 

(b): Civil aircraft: Certifications required Currently, there are no procedures 

for providing airworthiness certificates for the mentioned UAS. 

I, Greg Edwards & DDP, however will always fly safely while having the 

manuals of the DJI Phantom 2, DJI Inspire 1, and the DJI Phantom 3. 14 

C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(1): Operation 

after maintenance, preventive maintenance, rebuilding, or alteration, 14 

C.F.R. 91.409(a)(1) and (2): Inspections & 14 C.F.R. 91.417 (a) and (b): 

Maintenance records Maintenance inspections may be required and should 

be granted since they only apply to aircraft with an airworthiness certificate. 

However I, Greg Edwards & DDP, will perform preflight inspections of the 

UAS before each flight as outlined in the operating documents. I, Greg

Edwards & DDP, will also follow manufacturer recommendations from said 

operating documents. Public Interest Aerial photography and videography as 

an available service to the public allows for a cheaper method to capturing 

imagery than its alternative. The alternatives are aircraft and helicopters. 

They are expensive, create lots of noise, and are much more threatening due 

to size and combustible fuel. I, Greg Edwards & DDP, would gladly offer 

my services upon request and with proper coordination to any official search 

and rescue or emergency services organization to benefit the public. Also as 

mentioned in the Trudeau exemption, exemption No.11138: ““Manned 

aircraft conducting aerial filming and photography can weigh 5,000 lbs. or 

more, are operated by an onboard pilot and may carry other onboard 

crewmembers, as well as 100 gallons or more of fuel. The petitioner’s 

[sUAS] weighs less than 3 lbs. The pilot and crew will be remotely located 

from the aircraft. The limited weight reduces the potential for harm to 

persons or damage to property in the event of an incident or accident. The 

risk of an onboard pilot and crew during an incident or accident is eliminated 

with the use of a [sUAS] for the proposed operation.” 

I, Greg Edwards & DDP, am seeking exemption from the following rules: 

14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 

91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 

C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 

C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) 

and (b) With the exemptions of the mentioned rules I, Greg Edwards & 

DDP, will be seeking to make drone photography/videography services 

available to the public. 
Alternatively the public had looked to use helicopters and aircraft to achieve 

what I can offer in a safer, more cost efficient manner. By not using 

combustible fuel, flying at safe heights and strictly following the usage 

recommendations from DJI. These include but are not limited to: ● Flying 

the following UAS Safely ○ DJI Inspire 1 ○ DJI Phantom 3 ● Flying below 

400 feet ● Proper visual inspection of UAS before flights ● Keeping 

mentioned UAS in visual sight at all times when in operation ● Using an 

observer to assist if needed ● Remain well clear of and do not interfere with 

manned aircraft operations, and avoid other aircraft and obstacles at all times 

● Not intentionally fly over unprotected persons or moving vehicles ●

Contact the airport or control tower before flying within 5 miles of an airport 

● Not flying in adverse weather conditions such as high winds or reduced 

visibility ● Not flying under the influence of alcohol or drugs ● Ensure the 

operating environment is safe ● Not flying over sensitive infrastructure or 

property such as power stations, water treatment facilities, correctional 

facilities, etc. ● Check and follow all local laws and ordinances before flying 

over private property ● Do not conduct surveillance or photograph persons 

in areas where there is an expectation of privacy without the individual's 

permission.

Kind regards,

Greg Edwards 

Demented Dog Productions, LLC 

6545 S Arbutus Cir. #1215

Littleton, CO 80127

info@dementeddogproductions.com

720-583-3886 – company line