Cassie Elwonger

Realtor

3920 Rogers Ave

Fort Smith, AR 72903

479-651-5716

Docket ID: FAA-2014-0481

To whom it may concern at the FAA: 

My name is Cassie Elwonger. I am a 43 year old Realtor and a mother of three children. As a mother of 

two boys I have been given a lot of experience is flying UAS(s). As a Realtor I would like to offer a 

wonderful enhancement to my real estate clients by using a Parrot Bebop UAS for aerial videography 

and photography.

My petition is basically going to shadow that of Mr. Trudeau. After reading over his grant of exemption, 

he has described basically everything I wish to do. The Parrot Bebop user manual, a link to the UAS is 

attached. Thank you for considering my petition. 

To the Federal Aviation Authority (FAA), 

I hereby request exemption from part 21, subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 

91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 

91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). 

I support my request with the following information: 

I plan to operate a UAS, Parrot Bebop, which is comprised of an unmanned aircraft and a transportable 

ground station. The Parrot Bebop is referred to as a quad-copter with a maximum gross weight of about 

420 grams. It is equipped with four rotors that are driven by electric motors powered by a battery. The 

UAS at a maximum airspeed of 22 m/s. The Parrot Bebop has a built in high definition camera as well as 

2.0 onboard computer with a dual core CPU, and quad-core GPU. Making its connection and navigation 

system reliable. I plan to operate the UAS over various cities in Arkansas to enhance academic 

community awareness and augment real estate listing videos and photographs. I make the following 

representations of operational enhancements which I propose to abide by to ensure this exemption will 

provide a level of safety at least equal to existing rules: 

• I will only operate in reasonably safe environments that are controlled, are away from power lines, 

elevated lights, airports and actively populated areas; and I will conduct extensive preflight inspections 

and protocols, during which safety carries primary importance. 

I state that given the size, weight, speed, and limited operating area associated with the aircraft to be 

utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and 

(b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the 

requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 

(Section 333). 

I request an exemption from § 45.23 Marking of the aircraft because this UAS will not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, I state that two-inch 

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

requirement. The Parrot Bebop is bright blue and very recognizable while in flight.

I state that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) 

Maintenance inspections may be required and should be granted since they only apply to aircraft with 

an airworthiness certificate. However, I state that as a safety precaution I will perform a preflight 

inspection of this UAS before each flight as outlined in my operating documents. UAS Pilot in Command 

(PIC) I assert that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, and 
further indicate that the risks of operating a UAS are far less than the risk levels inherent in the 

commercial activities outlined in 14 CFR part 61, et seq., thus I request an exemption from § 61.113 

Private Pilot Privileges and Limitations: Pilot in command. 

Regarding UAS operational training, I have flown numerous practice flights in remote areas as a 

hobbyist and to get familiar with characteristics of my UAS’ performance. 

UAS Operating Parameters 

I will abide by the following additional operating conditions under this exemption: 

• operate my UAS below 200 feet and within a radius distance of 1000 feet from the controller to both 

aid in direct line of sight visual observation; 1 

• operate the UAS for 3-7 minutes per flight; 

• land my UAS prior to the manufacturer’s recommended minimum level of battery power; 

• operate my UAS only within visual line of sight (VLOS); 

• use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly 

lands if communication with the remote control pilot is lost; 

• conduct all operations under my own personal and flight safety protocols (including posting a warning 

sign reading: “Attention Aerial Photography in Progress – Remain Back 150 feet”) contained in the 

operating documents and will actively analyze flight data and other sources of information to constantly 

update and enhance my safety protocols; 

• always obtain all necessary permissions prior to operation; and 

• have procedures in place to abort flights in the event of safety breaches or potential danger. 

I state that § 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I assert 

that since there is currently no certificate applicable to my operation, this regulation is inapplicable. 

I state that § 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since there are no 

pilots or passengers on board his aircraft and given its size, this regulation is inapplicable. I further 

indicate an equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS 

ground station. I state that § 91.119 prescribes safe altitudes for the operation of civil aircraft, but that it 

allows helicopters to be operated at lower altitudes in certain conditions. I state that I will not operate

his UAS above the altitude of 200 feet above ground level (AGL) and will also only operate in safe areas 

away from the public and traffic, thus “providing a level of safety at least equivalent to or below those in 

relation to minimum safe altitudes. I assert that given the size, weight, maneuverability, and speed of 

my UAS, an equivalent or higher level of safety will be achieved. I am extremely cautious when 

operating my UAS as I do not want to be unsafe as well as I do not want to damage my UAS as it is 

expensive. 

I indicate that § 91.121 Altimeter settings is inapplicable since my UAS utilizes electronic GPS. 

Public Interest 

I state that aerial videography and photography for geographical awareness and for real estate 

marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for 

small real estate companies and average homeowners the expense has been cost-prohibitive. At this 

time only high end Realtors or luxury homeowners can afford to absorb such expense. Granting this 

exemption to me would allow me to provide this extra service to all homeowners and business owners 

who otherwise would not be able to afford such enhancements to their real estate marketing. 

Further, I would like to indicate my small UAS will pose no threat to the public given its small size and 

lack of combustible fuel when compared to larger manned aircraft. I would also like to state that the 

operation of my UAS will minimize ecological damage and promote economic growth by providing 

information to companies or individuals looking to relocate or build in Arkansas. 

Thank you for considering my request.
Cassie Elwonger
To the Federal Aviation Authority (FAA), 

I hereby request exemption from part 21, subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 

91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 

91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). 

I support my request with the following information: 

I plan to operate a UAS, the DJI Inspire 1, which is comprised of an unmanned aircraft and a 

transportable ground station. The Inspire 1 is referred to as a quad-copter with a maximum gross weight 

of about 3 kilograms. It is equipped with four rotors that are driven by electric motors powered by a 

battery. The UA has a maximum airspeed of 22 m/s. The quad has a built in high definition camera. I 

plan to operate the UA over various areas near Great Mills, Maryland to enhance academic community 

awareness and augment real estate listing videos and photographs. I make the following 

representations of operational enhancements which I propose to abide by to ensure this exemption will 

provide a level of safety at least equal to existing rules: 

• I will only operate in reasonably safe environments that are strictly controlled, are away from power 

lines, elevated lights, airports and actively populated areas; and 

• I will conduct extensive preflight inspections and protocols, during which safety carries primary 

importance. 

I state that given the size, weight, speed, and limited operating area associated with the aircraft to be 

utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and 

(b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the 

requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 

(Section 333). 

I request an exemption from § 45.23 Marking of the aircraft because his UA will not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, I state that two-inch 

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

requirement. Regardless of this, I state that I will mark his UAS in the largest possible lettering by placing 

the word “Experimental” on its fuselage as required by § 45.29(f) so that he or anyone assisting him as a 

spotter will see the markings. 

I state that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) 

Maintenance inspections may be required and should be granted since they only apply to aircraft with 

an airworthiness certificate. However, I state that as a safety precaution I will perform a preflight 

inspection of his UAS before each flight as outlined in my operating documents. 
UAS Pilot in Command (PIC) 

I assert that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, however 

I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not 

carry any pilots or passengers. Further, I state that, while helpful, a pilot license will not ensure remote 

control piloting skills. I further indicate that the risks of operating a UAS are far less than the risk levels 

inherent in the commercial activities outlined in 14 CFR part 61, et seq., thus I request an exemption 

from § 61.113 Private Pilot Privileges and Limitations: Pilot in command. 

Regarding UAS operational training, I state I have flown numerous practice flights in remote areas as a 

hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of 

his UAS’ performance under different temperature and weather conditions. I further state that he 

practices computerized simulated flights to maintain adequate skills and response reflex time. 

In a supplemental request to the FAA, I request consideration of a 120 day temporary airman certificate 

in accordance with § 63.13, to allow time to obtain a private pilot certificate or to allow the FAA time to 

establish minimum UAS airman certification standards. 

UAS Operating Parameters 

I will abide by the following additional operating conditions under this exemption: 

• operate my UAS below 300 feet and within a radius distance of 1000 feet from the controller to both 

aid in direct line of sight visual observation; 1 

• operate the UAS for 3-7 minutes per flight; 

• land my UAS prior to the manufacturer’s recommended minimum level of battery power; 

• operate my UAS only within visual line of sight (VLOS); 

• use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly 

lands if communication with the remote control pilot is lost; 

• conduct all operations under my own personal and flight safety protocols (including posting a warning 

sign reading: “Attention Aerial Photography in Progress – Remain Back 150 feet”) contained in the 

operating documents and will actively analyze flight data and other sources of information to constantly 

update and enhance my safety protocols; 

• contact respective airports if operations will be within 5 miles to advise them of my estimated flight 

time, flight duration, elevation of flight and other pertinent information; 

• always obtain all necessary permissions prior to operation; and 

• have procedures in place to abort flights in the event of safety breaches or potential danger. 
I state that § 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I assert 

that since there is currently no certificate applicable to my operation, this regulation is inapplicable. 

I state that § 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since there are no 

pilots or passengers on board his aircraft and given its size, this regulation is inapplicable. I further 

indicate an equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS 

ground station. 

I state that § 91.119 prescribes safe altitudes for the operation of civil aircraft, but that it allows 

helicopters to be operated at lower altitudes in certain conditions. I state that I will not operate his UAS 

above the altitude of 300 feet above ground level (AGL) and will also only operate in safe areas away 

from the public and traffic, thus “providing a level of safety at least equivalent to or below those in 

relation to minimum safe altitudes. I assert that given the size, weight, maneuverability, and speed of 

my UAS, an equivalent or higher level of safety will be achieved. 

I indicate that § 91.121 Altimeter settings is inapplicable since my UAS utilizes electronic GPS with a 

barometric sensor. 

Public Interest 

I state that aerial videography and photography for geographical awareness and for real estate 

marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for 

small business owners, its expense has been cost-prohibitive. Granting this exemption to myself would 

allow me to provide this service at a much lower cost. 

Further, I would like to indicate my small UAS will pose no threat to the public given its small size and 

lack of combustible fuel when compared to larger manned aircraft. I would also like to state that the 

operation of my UAS will minimize ecological damage and promote economic growth by providing 

information to companies or individuals looking to relocate or build in the Southern Maryland region. 

(end of petition) 

I would like to conclude by saying thank you for your consideration and time reading this over. This has 

been a dream of mine since quadcopters became available to the public. I have only flown as a hobby to 

not break any laws until with hopes to become commercial. I see nothing but positive coming from it 

from top to bottom. The state of Maryland makes money from the sale of real estate. The realtor would 

have an advantage because of a much clearer view of properties. The consumer gets a better look at 

things. I get to pursue hopefully a career and be a pioneer in a virtually new field of photography. All 

along, the way the federal government collects taxes from all of us. The economy benefits with very 

little risk of accidents and/or damages from flying over the usually vacant areas of real estate. Thank you 

again. 

Very respectfully, 

Bryan W. Swann