Manager, Flight Standards Service

Unmanned Aircraft Systems Integration Office

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, DC 20590

Green Giraffe Productions respectfully requests an exemption from several provisions of 

Title 14 of the Code of Federal Regulations (C.F.R.) to permit the use of small unmanned aerial 

systems (sUAS) to assist in the evaluation and inspection of Public Utility's, Infrastructure, 

Forest fire monitoring, Emergency Public Response, Commercial video production, Live 

Webcasting and Action Sport Videography. This request is motivated primarily by the desire to 

maximize safety during hazardous operations, as well as assisting with public emergencies and to 

mitigate any safety concerns associated with such operations. While an exemption would not 

eliminate the current need for in-person visual inspection and monitoring it would allow Green 

Giraffe Productions to evaluate assets and infrastructure with sUAS, resulting in a safer and 

more efficient valuation of public utility's and Infrastructure . 

Company Profile

Green Giraffe Productions was formulated out of the growing need of sUAS services for 

various industries. Our core of experience is generated from our extensive work with UAV's 

while deployed OCONUS, testing in NAS, and training. Our knowledge and expertise are what 

help us see the need and usefulness of a sUAS for other services while also providing those 

services safely within the NAS.

Green Giraffe Productions currently employees two operators, each with over 1000 hours 

of UAV operating experience. Owner operator Dustin LaGrone is a private instrument rated pilot 

and flight dispatcher. He has over a decade of aviation experience and has been an expert in the 

UAV industry for over six years. Pilot and Sensor operator Renee Wiltshire has over a decade of

aviation experience and also holds a flight dispatch certificate. She has deployed multiple times 

OCONUS to provide UAV support.

NOTE:
All information pertaining to this system can be found in Appendix A (OEM manual).

Green Giraffe Productions intends to use the DJI Spreading Wings S1000 plus (The OEM 

Manual of which is attached as Appendix A) in it's sUAS operations.

Green Giraffe Productions intends to adopt 

ASTM F2500-07 Standard Practice for Unmanned Aircraft System (UAS) Visual Range 

Flight Operations(Attached as Appendix B) 

ASTM F2909-14 Standard Practice for Maintenance and Continued Airworthiness of 

small Unmanned Aircraft Systems(Attached as Appendix C).

Regulatory Provisions from which Green Giraffe Productions seeks an Exemption

Green Giraffe Productions believes it may need an exemption from the following 

provisions to conduct the contemplated operations. In some instances, relief is needed because 

relief from another provision renders compliance with the regulation at hand infeasible.

14 C.F.R. §61.113(a) and (b)

14 C.F.R. §91.7(a)

14 C.F.R. §91.9(b)(2)

14 C.F.R. §91.109(a)

14 C.F.R. §91.119

14 C.F.R. §91.151

14 C.F.R. §91.203(a) and (b)

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)

14 C.F.R. §91.409(a)

Green Giraffe Productions believes an exemption is only needed from the above-listed 

regulatory provisions. To the extent that the FAA believes that additional relief is required for 

Green Giraffe Productions to conduct the operations described here, we request an exemption 

from any such regulatory provisions as well.

The Extent of Requested Relief and the Reasons Relief is Needed

14 C.F.R. §61.113(a) and (b)

§61.113 Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person

who holds a private pilot certificate may act as pilot in command of an aircraft

that is carrying passengers or property for compensation or hire; nor may that
person, for compensation or hire, act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command 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.

Green Giraffe Productions specially trained employees will conduct the sUAS operations. While 

these individuals will have private pilot licenses or a flight dispatch certificate, they will not hold 

commercial pilot licenses. Without an exemption, the pilot would be required to hold a 

commercial pilot certificate under §61.133. However, the risk associated with the contemplated 

operations is less than the risk posed by a traditional aircraft. The sUAS will fly at altitudes well 

below the permissible limits for other civil aircraft, eliminating the risk to other aircraft, and 

within a geographical envelope under the sole control of Green Giraffe Productions. 

Accordingly, the risk would be limited to Green Giraffe personnel, who will be appropriately 

outfitted in safety gear. Requiring a commercial pilot certificate would provide no appreciable 

safety benefit and would needlessly impose additional cost on Green Giraffe Productions. 

Because the contemplated operations would not comply with §61.113(b)(1) and none of the other 

exceptions to paragraph (a) apply, relief is needed from both paragraphs (a) and (b).

14 C.F.R. 91.7(a)

§91.7 Civil aircraft airworthiness.

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

(b) The pilot in command of a civil aircraft is responsible for determining

whether that aircraft is in condition for safe flight. The pilot in command shall 

discontinue the flight when un-airworthy mechanical, electrical, or structural

conditions occur.

There is no clear definition of “airworthy,” and the term has been defined in various ways

depending on the circumstances. In all instances, it appears that the concept includes a 

requirement that the airplane 1) conforms to the aircraft’s type design or its type certificate, as

modified by supplemental type certificates and airworthiness directives, and 2) be in condition

for safe operations. The sUAS will not have a type design or type certificate, as the FAA has not 

developed standards applicable to sUAS. As discussed later in this document, the types of

operations contemplated by Green Giraffe Productions will not qualify the sUAS for an 

experimental airworthiness certificate. Accordingly, relief from §91.7(a) is required. Should the 

FAA include airworthiness requirements as a condition of exercising the exemption, Green 

Giraffe Productions will assure the continued airworthiness of the sUAS. Regardless, Green 

Giraffe Productions believes that it can meet the requirements of §91.7(b) and is not requesting 

an exemption from that provision.

14 C.F.R. 91.9(b)(2)
§91.9 Civil aircraft flight manual, marking, and placard requirements.

***

(b) No person may operate a U.S.-registered civil aircraft --

***

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5

of this chapter unless there is available in the aircraft a current, approved manual

material, markings, and placards, or any combination thereof.

*****

The sUAS comes with access to online manuals that provide instructions for the safe

operation and maintenance of the aircraft. Compliance with this regulatory provision is not

possible because this information has not been, and cannot be, approved by the FAA since there 

are no applicable standards established by the FAA against which to evaluate it. Additionally, the 

sUAS is too small to carry a printed manual. Since, by definition, there will never be a person 

aboard the sUAS, Green Giraffe Productions submits that there is no need to require the manual 

to be placed on the sUAS and an exemption is appropriate. Safety will be maintained by keeping 

the flight manual at the ground control point where the PIC will have immediate access to it. 

Since the sUAS cannot be operated without the Ground Control Station containing the manuals, 

there is minimal risk that the manuals will become separated from the sUAS, and Green Giraffe 

Productions will be able to immediately locate the manuals to effectuate any needed repairs on 

the sUAS detailed in the flight manual.

14 C.F.R. 91.109

§91.109 Flight instruction; Simulated instrument flight and certain flight

tests.

(a) No person may operate a civil aircraft (except a manned free balloon) that is

being used for flight instruction unless that aircraft has fully functioning dual

controls....

Small UASs, by their design, do not have fully functional dual controls. Flight control is

accomplished through the use of a Ground Control Station that communicates with the aircraft 

via radio communications (C2 Link). Aircraft being considered for use by Green Giraffe 

Productions allows the sUAS Instructor to place the aircraft into ‘Loiter’ mode (fixed altitude 

and GPS stationary hold). In the event of the student losing control, the sUAS Instructor can 

quickly and via alternate equipment (equipment not in the hands of the student) place the aircraft 

into a mode that then allows the instructor to bring the aircraft back into control and back to the 

pre-determined and/or safe landing location.

14 C.F.R. 91.119
§91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft

below the following altitudes:

***

(c) Over other than congested areas. An altitude of 500 feet above the surface,

except over open water or sparsely populated areas. In those cases, the aircraft

may not be operated closer than 500 feet to any person, vessel, vehicle, or

structure.

*****

Green Giraffe Productions submits that the only relief it requires from §91.119 is from 

the minimum altitudes listed in paragraph (c). Relief is required from paragraph (c) for fixed 

wing operations because asset evaluation conducted at 500 feet or higher is insufficiently distinct 

to be meaningful. Since operations at this altitude also pose a heightened risk of collision with 

another aircraft, safety can only be assured through the grant of an exemption. The anticipated 

rotorcraft operations should be adequately addressed by paragraph (d) (1). Additionally, relief 

should not be needed from paragraph (a) because an emergency landing of the aircraft due to a 

power failure will not create an undue hazard to persons or property on the surface. As noted in 

the explanation of why an exemption will not adversely affect safety, 

Green Giraffe Productions will have exclusive use of the land over which the sUAS will 

be operated, and public access is restricted. Controlled access to public utility land, structures or 

emergency response area's assure that no individuals unassociated with the planned operations 

are within the affected area of operations. Controlled areas for Media and Sporting Events will 

be prior reserved and designated areas of operations will be clear of persons unless invloved in 

the production of the event. Green Giraffe Productions personnel are required to wear 

mandatory safety equipment, including hard hats and safety glasses whenever dispatched to a 

work site. As such, the risk of injury is minimal. Green Giraffe Productions does not contemplate 

conducting operations over congested areas, so relief is not requested from paragraph (b).

14 C.F.R. 91.151

§91.151 Fuel requirements for flight in VFR conditions.

(a) No person may begin a flight in an airplane 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 –

(1) During the day, to fly after that for at least 30 minutes.
(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.

Operating the sUAS in a pre-defined area with less than 30 minutes of reserve fuel does

not raise the type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in

the event it has to be flown to an alternate airport or circle the planned airport in the event of

unanticipated conditions. Green Giraffe Productions does not intend to use the sUAS for pointto-point flights and will not operate the sUAS beyond visual line of sight. Nor will the sUAS 

require an airport in order to land. Rather, Green Giraffe Productions will operate the sUAS 

using pre-planned flight paths (taking into account weather conditions) designed to allow the 

sUAS to fly to the point of intended landing. As such, there is no need for a time-based excess 

fuel requirement. Rather it should be sufficient to require only as much additional excess flight 

capacity as necessary to safely land the sUAS. We believe that a 20% energy reserve is more 

than sufficient to meet this objective.

14 C.F.R. 91.203(a) and (b)

§ 91.203 Civil Aircraft: Certifications required.

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it

has within it the following:

(1) An appropriate and current airworthiness certificate. ***

(2) An effective U.S. registration certificate issued to its owner or, for

operations within the United States, the second copy of the Aircraft

Registration Application as provided for in §47.31(c), or a registration

certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued

under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.

*****

The sUAS that Green Giraffe Productions intends to operate will not qualify for an airworthiness 

certificate unless the FAA chooses to issue them a restricted category certificate. This is because 

the sUAS does not meet the current conditions for either a standard airworthiness certificate or 

an experimental airworthiness certificate. Notably, under 14 C.F.R. §21.191,8 experimental 

airworthiness certificates are only available for research and development, showing compliance 

with regulations, crew training, exhibitions, air racing, market surveys, operating amateur-built 

aircraft, operating primary kit-built aircraft and operating light-sport aircraft. Until such time as 

the FAA develops airworthiness standards applicable to sUAS for non-recreational and 

nonexperimental use, Green Giraffe Productions submits that the FAA should consider 
exemptions to the requirements of §91.203(a). The absence of such exemptions hinders the 

development of sUAS and applicable uniform standards since it is only through the development 

of the aircraft that the FAA can reliably evaluate them and determine appropriate design 

standards.

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the

requirement for an airworthiness certificate based on a consideration of the size, weight, speed,

operational capability of the particular UAS, as well as its proximity to airports and populated

areas. An analysis of these criteria demonstrates that the sUAS operated without an airworthiness 

certificate in the areas and under the conditions contemplated by Green Giraffe Productions will 

be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with 

an airworthiness certificate without the conditions proposed in this request. The sUAS is less 

than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates exclusively within 

asecured area as set out in the sUAS Operating Manual (Appendix B). Unlike other civil 

aircraft, operations under this exemption will be tightly controlled and monitored by the operator 

and observer. Operations will be conducted in compliance with the FAA and with local public 

safety requirements to provide security for the area of operation. Lastly, application of these 

same criteria demonstrates that there is no credible threat to national security posed by the sUAS, 

due to its size, speed of operation, location of operation, lack of explosive materials and inability

to carry a substantial external load.

If the FAA waives the requirements of paragraph (a) (1), then it is technically impossible

to comply with paragraph (b), so an exemption is merited there as well.

14 C.F.R. 91.405(a), 91.407(a) (1) and 14 C.F.R. 91.409(a)

§91.405 Maintenance required.

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;

*****

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or

alteration.

(a) No person may operate any aircraft that has undergone maintenance,

rebuilding, or alteration unless –

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

 §43.7 of this chapter;

*****

§91.409 Inspections.

(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.

*****

Green Giraffe Productions believes that an exemption from these three maintenance 

requirements is appropriate because the FAA has not developed maintenance standards that 

would allow an operator to meet the part 91 maintenance requirements. In particular, there are no 

individuals authorized by the FAA to approve a sUAS for return to service under §91.407(a) or 

to conduct the initial airworthiness and annual return to service inspections required by

§91.409(a). Green Giraffe Productions will maintain the aircraft as instructed in the owner’s 

manual and S1000 User Manual v1.10 (Attached as Appendix C), where applicable, and will not 

operate the aircraft until it has reasonably determined that any needed repairs have been made. 

However, because of the technical impossibility of meeting the requirements of §§91.405(a), 

407(a) and 409(a), we believe an exemption from these provisions

is appropriate

Please do not hesitate to contact me at the phone number or via the e-mail address

provided above should you have any questions or concerns.

Respectfully,

Dustin B. LaGrone

Owner Operator 

Green Giraffe Productions

Cell 303.730.2557 

Email: dustin.lagrone@gmail.com
Summary for Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal

Register should the FAA determine that publication is needed.

Petitioner: Green Giraffe Productions

Sections of 14 C.F.R. Affected:

14 C.F.R. §61.113(a) and (b)

14 C.F.R. §91.7(a)

14 C.F.R. §91.9(b) (2)

14 C.F.R. §91.109(a)

14 C.F.R. §91.119

14 C.F.R. §91.151

14 C.F.R. §91.203(a) and (b)

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)

14 C.F.R. §91.409(a)

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §§45.29,

61.113(a)&(b), 91.7(a), 91.9(b)(2), 91.119, 91.121(a), 91.151, 91.203(a) &(b), 91.405(a),

91.407(a) and 91.409(a) to conduct sUAS operations over private and publicly owned or 

controlled land, solely during daylight hours, to assist in the safe evaluation and analysis of 

public utility's, infrastructure and other events. Also to provide media for action sporting events 

in briefed areas on predermined courses and routes free from congestion. In general, sUAS 

operations are intended to be conducted in areas remote from both congested areas and airports. 

The nature of operations anticipated by Green Giraffe Productions requires that the sUAS be 

flown at relatively low altitudes. Green Giraffe Productions expects that in most instances the 

sUAS will be flown less than 75 feet above the highest structure along the path of the sUAS and 

in no instances will be flown higher than 400 feet above the ground. Accordingly, the risk of 

interference with other aircraft is minimal.