To whom it may concern:

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

Act) and 14 C.F.R. Part 11, Women’s Investment Group, Inc, operator of Small 

Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography and 

videography, hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its sUASs, 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 333.1

As described more fully below, the requested exemption would permit the operation of 

small, unmanned and relatively inexpensive sUAS under controlled conditions in 

airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if 

granted, would allow Women’s Investment Group, Inc to conduct commercial operations 

of sUASs meeting or exceeding all of the operational and safety requirements Congress 

has set forth in Section 333.

Women’s Investment Group, Inc is a Real Estate company that operates in Medford,

Oregon. The purpose of this drone use would be to promote real estate properties in the 

Rogue Valley of Southern Oregon. ￼￼

Women’s Investment Group, Inc plans to use the capabilities of sUASs to offer a 

multitude of services, including:

- Real Estate Photography and presentation

- Aerial filmmaking and photography to benefit home buyers, sellers of homes and 

contractors involved in the construction and alterations of properties. 

- Construction site inspections and monitoring for the benefit of venders and contractors 

of Women’s Investment Group, Inc 

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft 

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil 

Unmanned Aircraft Systems (UAS) operations in the National Airspace System (“NAS”). 

Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems 

may operate safely in the national airspace system before completion of the 

(comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the 

guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it 

clear that Section 333 provides a mechanism for “expedited operation authorization” if 

several factors are met. Petitioner meets all requirements to permit FAA approval of 

commercial UAS operations.

The name and address of the applicant are:

Women’s Investment Group, Inc

Email: alicelema@johnlscott.com
Phone number: 541-301-7980

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

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

14 C.F.R. 91.119

14 C.F.R. 91.121Page 3

14 C.F.R. 91.151(a)

14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 - 91.417)

SUASs are often times seen as superior to helicopters due to the lesser cost of equipment, 

the reduction of personnel needed to operate equipment, reduced noise levels and zero 

emissions into the environment. In addition to providing cost savings and having little to 

no impact on the environment, sUASs provide enhanced safety. These factors are 

beneficial for, and in the best interest of, the public. Accordingly, the applicant 

respectfully requests that the FAA grant the requested exemption without delay.

Petitioner is requesting an exemption to enable Women’s Investment Group, Inc to 

operate a DJI Phantom 3 sUAS that is upgraded to latest version firmware. This sUAS 

has a built-in capability to limit 1) the height it flies above the ground and 2) the radius of 

the distance it flies from the operator. The DJI Phantom 3 also has the fail safe function 

of the 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. Please refer to Attachments 1-

3, the DJI Phantom 3 Instruction Manual, for the performance limitations and flight 

operations.

Aircraft weight is 1,216 grams, which is the total gross weight and includes the weight of 

the battery and camera.
A pre-flight inspection will be performed by the PIC in accordance with the factory

instruction manual, as well as redundant checks to include the Internal Measurement Unit 

(IMU) to make sure that the compass, gyro and acceleration values are within specs, 

positive GPS locks are secure, battery health in each individual LiPo cells are balanced, 

and radio signals are locked in.

The sUAS will be maintained in accordance with the manufacturer’s instruction manual 

and only manufacturer's authorized replacement parts will be used.

FCC Information

The DJI Phantom 3 transmitter used for controlling the sUAS complies with part 15 of 

the FCC rules. Operation is subject to the following two conditions: (1) This device may

not cause harmful interference, and (2) this device must accept any interference received, 

including interference that may cause undesired operation.

The DJI Phantom 3 radio transmitter used for controlling the sUAS is wireless 

technology, which has been tested and found to be compliant with the applicable 

regulations governing a radio transmitter in the 2.400 GHz-2.483 GHz frequency range.

Antenna Separation Distance

When operating the DJI Phantom 3, the PIC will maintain a separation distance of at least 

5 cm between his body (excluding fingers, hands, wrists, ankles and feet) and the antenna 

in order to meet RF exposure safety requirements as determined by FCC regulations.

Pilot in Command Qualifications and Duties

The PIC will maintain at least a Third Class Certificate and a current state-issued driver’s 

license, plus at least 2 hours flying time and 3 takeoffs and landings within 30 days in the 

type of UAS utilized in operations.

**The PIC will have at least 5 hours total time and at least 5 hours flying Radio 

Controlled Model Aircraft, of which, 10 hours will be flying sUASs.

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties 

include all pre-flight preparation and inspection, in-flight operation, post-flight 

requirements, and all procedures including but not limited to:

 Safe in-flight operations

 Risk evaluation
 Current weather conditions for safe flight

General Operating Standards

• Women’s Investment Group, Inc will only operate its sUAS in line of sight of a pilot.

• Before any operation of an sUAS within 1.2 NM of an airport with a control tower, the 

control tower will be called to gain permission to operate the sUAS. The PIC will give 

the position, altitude and the times the sUAS will be operated. The sUAS will not be 

operated at an altitude of over 200 feet AGL. Weather minimums will be 3 miles 

visibility and a 1,000 foot ceiling. Absolutely no flights will be operated within .6 miles 

of an airport with a control tower.

• Before an operation of a sUAS within 1.2 NM of a non-tower controlled, airport 

operators will be notified and the PIC will give the right of way to avoid flying in the 

proximity of full- scale aircraft. At no time will the sUAS be operated within the final 

approach course and the takeoff course of any runway. The sUAS will not be operated at 

an altitude of over 200 feet AGL. Weather minimums will be 3 miles visibility and a 

1,000 foot ceiling. Absolutely no flights will be operated within .6 miles of a non-tower 

controlled airport.

• Maximum flight time for each operational flight will be 18 minutes.

• Flights will be terminated at 30% battery power reserve should that occur prior to the 

18-minute limit.

• The sUAS will be programmed so that it can not exceed 400 feet AGL, and not more 

than 200 feet above an elevated platform from which filming is planned.

• Minimum crew for each operation will consist of the sUAS Pilot.

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload 

(i.e. camera, lens, and gimbals).

• The sUAS will operate at speeds of no more than 29 knots, can hover, and can 

simultaneously move vertically and horizontally.

• Given the small size of the sUAS and the restricted sterile environment within which 

they will operate, our sUAS operations adhere to the Reform Act's safety requirements.

• The sUAS, powered by batteries, is smaller, lighter and more maneuverable than larger 

aircraft running on combustible fuel. The sUAS operates at lower altitudes with no 

people on board and will thereby reduce current risk levels, enhance safety and diminish 

the likelihood of death or serious bodily injury. With a small payload and maximum 

flight time of only 20 minutes, this offers little or no risk to national security.
• Low level oblique photos and video from several angles are far more effective than 

ground based imagery for displaying the characteristics of large, complex properties with 

large trees. The benefits of reduced cost and improved quality of presentation from the 

sUAS over manned aircraft will be valuable to and benefit many buyers and sellers of 

real property.

• No flight will be made with a gross weight exceeding 55 pounds.

• All operations must occur in FAA Class G airspace at no more than 400 feet AGL, at an 

airspeed of no more than 25 knots and no further than 1,600 feet, or 0.263 NM from the 

PIC.

• Operations will be restricted to flights over private property with the permission of the 

property owner.

• All required permits will be obtained from state and local government prior to 

operation.

• Women’s Investment Group, Inc will not be operating over any open-air assembly of 

people.

• Women’s Investment Group, Inc will not be operating over heavily trafficked roads.

• Women’s Investment Group, Inc will not be operating at night.

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Women’s Investment Group, Inc requests an exemption from the following regulations as 

well as any additional regulations that may technically apply to the operation of the 

sUAV System:

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While 

the FAA continues to work to develop airworthiness standards for Unmanned Aerial 

Systems, we request an experimental certificate be issued for the DJI Phantom 3 under 

either or both of the following provisions:

21.191 Experimental certificates. Experimental certificates are issued for the following 

purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft 

equipment, new aircraft installations, new aircraft operating techniques, or new 

uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other 
operations to show compliance with the airworthiness regulations including 

flights to show compliance for issuance of type and supplemental type 

certificates, flights to substantiate major design changes, and flights to show 

compliance with the function and reliability requirements of the regulations. Since 

the experimental certificate can be used for commercial purposes such as market 

surveys, sales demonstrations, and customer crew training, we would expect that 

an experimental certificate would permit our commercial purpose as well. The 

aircraft will not carry persons or property, will not carry fuel, and will only fly

under strict operational requirements. Combined with the UAS's light weight, 

being constructed primarily of carbon fiber and plastic, we propose that the UAS 

will be at least as safe, if not safer, than a conventionally certificated aircraft 

performing the same mission. If an experimental airworthiness certificate is not 

appropriate for this application, then we request an exemption of 14 CFR Part 21, 

Subpart H, and the requirement for an airworthiness certificate in general, citing 

the equivalent level of safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 3 inches high. Additionally, the aircraft must display

the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the 

cabin, cockpit, or pilot station. The sUAS does not have an entrance in which the word 

"EXPERIMENTAL" can be placed, and may not have a registration number assigned to 

it by the FAA. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act as 

pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a 

private pilot to 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. Our proposed 

operations require that the PIC must hold at least a Private Pilot Certificate with a Class 

III Medical issued by the FAA and since the aircraft cannot carry passengers or property, 

we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this 

application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. We assume that the intent of this requirement is to ensure 

that flight manual information is available to the aircrew while operating the aircraft. We 
request an exemption to this requirement since the aircraft is not only too small to carry

documentation, the documentation would not be available to the crew during flight 

operations. To obtain an equivalent level of safety and meet the intent of 91.9, we 

propose that a current, approved sUAS Flight Manual must be available to the crew at the 

ground station anytime the aircraft is in, or preparing for, flight, and ready for 

presentation for any governing official upon request.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for 

flight instruction unless that aircraft has fully functioning dual controls.” 

Women’s Investment Group, Inc will be operating with a single remote controller.

91.119 Minimum safe altitudes:

General. The regulation states that over sparsely populated areas the aircraft cannot be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical 

mission of the sUAS would be photography or survey of properties and or structures it 

would be necessary to operate closer than 500 feet to the items listed. Operations will 

only be flown over property or persons where permission has been obtained and careful 

pre-planned flight path has been performed. The aircraft will be operated at a low altitude 

allowing, if a power unit fails, an emergency landing without undue hazard to persons or 

property on the surface. Therefore we maintain that due to the small size of the UAS, the 

hazard to persons, vehicles and structures is minimal compared to manned aircraft, which 

should be considered in granting the exemption.

CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. The sUAS will always fly 

below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent 

conflict with other aircraft. An Above Ground Level altimeter measurement above the 

takeoff point is transmitted via radio from the sUAS on-board computer to the display

screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to 

fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide 

an energy reserve as a safety buffer for delays to landing. The sUAV is battery operated 

and the maximum duration of flight from a single battery charge is 18 minutes with a 

20% reserve. Since the aircraft will never fly more than 0.263 NM from the point of 

intended landing, a full battery charge at launch will ensure that we meet the reserve 

energy requirement of this paragraph. We request an exemption to the word "fuel" and 

ask for an equivalent interpretation with the word "energy".
14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum 

gross weight of 1216 grams or about 2lbs, 11oz, the sUAS is too small to carry

documentation, does not have an entrance, and is not capable of carrying passengers or 

crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose 

that documents deemed appropriate for this aircraft by the FAA will be with the crew at 

the ground control station and available for inspection upon request. 

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 

91.407 and 91.409 require that the aircraft be "approved for return to service by a person 

authorized under 43.7" after maintenance and inspection. It is our intention that the PIC 

perform maintenance and inspection of the aircraft and "be authorized to approve the 

aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy 

condition prior to every flight and in addition conduct detailed inspections after every

two hours of flight. Maintenance performed by the PIC is limited to repairing small 

cracks, replacing a propeller, checking electrical connections and updating software and 

firmware for the on-board computer. All other maintenance will be performed by the 

manufacturer or their designated repair facility. The PIC will document work performed 

in accordance with 91.417. We feel that due to the size, construction, and simplicity of 

the aircraft, the PIC can ensure an equivalent level of safety.

Safety and Benefits of the UAS

Women’s Investment Group, Inc will be using the UAS in a variety of applications that 

generally require expensive full-size manned aircraft to complete. Small, light, unmanned 

aerial vehicles offer more efficient and safer benefits over the use of full-sized manned 

aircraft for aerial photography and real estate marketing.

Replacing significantly larger manned aircraft carrying crew and flammable fuel with 

small UAS carrying no passengers or crew creates a much greater margin of safety for 

the pilots and crew. By Women’s Investment Group, Inc requested exemptions, the FAA 

will help drive development of safe and successful commercial UAS operations and will 

advance the public knowledge base for such operations. 

Conclusion

As pointed out in this application, the DJI Phantom 3, which our company would use, 

under authorization by the US DOT-FAA, is a small, light-weight device operated within 

the line of sight of the Pilot-in-Command (PIC), less than 400 feet above the ground and 

outside 1.2 miles from any airport, heliport, seaplane base, spaceport, or other location 

with aviation activities, unless the air traffic control authorities (ATC) have been notified 
and have authorized each flight within a radius of this distance.

The DJI Phantom 3 has been proven capable for controlled flight. It is a UAS offered for 

general sale on the market around the world and have often been used as Model Aircraft 

in the USA. We are certain that the studies conducted until now by the FAA, about 

Section 332, Public Law 112-95, 2014, have already provided you with the assurances on 

the airworthiness of sUAS such as ours.

For the foregoing reasons, the exemptions requested herein should be granted and 

Women’s Investment Group, Inc should be permitted to conduct small UAS operations in 

accordance with its manuals and all other operating parameters deemed necessary and 

appropriate by the FAA.

The submission of this application and its contents is the best demonstration that indeed it 

is possible to pursue the authorization process so that some SUAs may be used for 

legitimate commercial activities and under reasonably safe conditions.

Signed