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 Sy stems (“sUASs”) equipped to conduct aerial photography and videograph y, hereb y applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow comm ercial operation of its s UASs, so long as such operations are conducted within and under the conditions outlined herein or as ma y be established by

the FAA as required by

Section 333.1 As described more full y 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) pred etermined 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 compan y 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 capa bilities of sUASs to offer a multitude of services, including:

- Real Estate Photography and presentation

- Aerial filmmaking and photograph y to benefit home buy ers , sellers of homes and contractors involved in the construction and alterations of propertie s.

- Construction site inspections and monitoring for the benefit of venders and contractors of Women’s Investment Group, Inc Statutory Authorit y Section 333, titled “Special Rules for Certain Unmanned Aircraft Sy stems”, provides a mechanism for seeking expedited FAA authorization of safe civil Unmanned Aircraft Sy stems (UAS) operations in the National Airspace S ys tem (“NAS”). Section 333(a) states that the FAA “shall determine if certain unmanned aircraft s ys tems may operate safel y in the national airspa ce s ys tem before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required b y section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for “e xpedited 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.comPhone 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. 91.121 Page 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)

S UASs 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 safet y. These factors are beneficial for, and in the best interest of, the public. Accordingl y, the applicant respectfull y 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 DJ I Phantom 3 sUAS that is upgra ded 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 DJ I Phantom 3 al so has the fail safe function of the autopilot sy stem, which means, wh en 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 sy stem will automatically

trigger Return to Home and will land safel y. Please refer to At tachments 1

- 3, the DJ I 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 b y 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, gy ro and acceleration values are within specs, positive GPS locks are secure, battery health in each individual L iPo 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 DJ I 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 devi ce may not cause harmful interference, and (2) this device must accept an y interference received, including interference that may cause undesired operation. The DJ I 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 operati ng the DJ I Phantom 3 , the PI C will maintain a separation distance of at least 5 cm between his bod y (excluding fingers, hands, wrists, ankles and feet) and the antenna in order to meet RF exposure safety requirements as det ermined b y FCC regulations.

**Pilot in Command Qualifications and Duties** The PI C will maint ain at least a Third Class Certificate and a current state

- issued driver ’ s license, plus at least 2 hours fly ing time and 3 takeoffs and landings within 30 day s in the ty pe of UAS utilized in operations. **The PI C will have at least 5 hours total time and at least 5 hours fl yi ng Radio Controlled Model Aircraft, of which, 10 hours will be fly ing sUASs. The PI C is responsible for the safe and efficient operation of the aircraft. Specific duties include all pre

- flight preparation and inspection, in

- flight operation, pos t

- flight requirements, and all procedures including but not limited to: S a f e i n - flight operations R i s k e v a l u at i o nC ur r e n t w e ath e r c o n d i t i o n s f

o r s a f e f l i g h t

**General Operating Standards**

• Women’s Investment Group, Inc will only operate its sUAS in li ne 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 ope rated. The sUAS will not be ope rated at an altitude of over 200 feet AGL. Weather minimums will be 3 miles visibility and a 1 , 000 foot ceiling. Absolutel y no flights will be operated within .6 miles of an airport with a control tower.

• Before an operati on of a sUAS within 1.2 NM of a non

- tower controlled, airport operators will be notified and the PI C will give the right of way to avoid fl ying in the proximity of full

- scale aircraft. At no time will the sUAS be operated within the final approach course and the takeof f course of any

runway . The sUAS will not be ope rated 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 n ot 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 b y the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbals). • The sUAS will oper ate 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 w hich they will operate, our sUAS operations adhere to the Reform Act's safet y requirements.

• The sUAS, powered b y batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel. The sUAS operates at lower altitudes with no people o n board and will thereb y reduce current risk levels, enhance safet y and diminish the likelihood of death or serious bodily injury . With a small pay load and maximum flight time of onl y 20 minutes, this offers little or no risk to national security.• Lo w le vel oblique photos and video from several angles are far more effective than

ground based imagery

for display ing the characteristics of large, complex properties with large trees . The benefits of reduced cost and improved quality of presentation from the s UAS over manned aircraft will be valuable to and benefit man y bu ye rs and sellers of real propert y .

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

• All operations must occur in FAA Clas s G airspace at no more than 400 f ee t AGL, at an air speed of no more than 25 knots and no further than 1 , 600 f ee t, or 0.263 NM from the PI C.

• Operations will be restricted to flights over private propert y with the p ermission of the propert y owner.

• All required permits will be obtained from state and loca l government prior to operation

.

• Women’s Investment Group , Inc will not be operating over an y open - air assembly of people.

• Women’s Investment Group , Inc will not be operatin g over heavil y 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 an y additional regulations that may technically

appl y to the operation of the sUAV Sy stem: 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 Sy stems, we request an exp erimental certificat e be issued for the DJ I 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 de sign 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 otheroperations to show compliance with the airworthiness regulations including flights to show compliance for issuance of t yp e and supplemental ty pe 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 survey s, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not c arr y persons or propert y, will not carry fuel, and will onl y fly under strict operational requirements. Combin ed 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. I f 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 airw orthiness 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 "EXPERI MENTAL" 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 Comm and 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 employ ment 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 operation s require that the PI C must hold at least a Private Pilot Certificate with a Class III Medical issued b y 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 thi s 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 Ci vil 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 flig ht manual information is available to the aircrew while operating the aircraft. Werequest 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 safet y 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 an yt ime the aircraft is in, or preparing for, flight, and ready for presentation for an y 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 full y 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 sparsel y populated areas the aircraft cannot be o perated closer than 500 feet to an y person, vessel, vehicle, or structure. Since the t ypical mission of the sUAS would be photograph y or surv ey 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 propert y 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 alway s fl y 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 b y the PI C, 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 fl y to the first point of intended landing and to fl y 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 delay s to landing. The sUAV is battery operated and the maximum duration of flight fr om a single battery charge is 18 minut es with a 20% reserve. Since the aircraft will never fl y 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 re gistration certificate must be aboard the aircraft. Additionally , subparagraph (b) provides that the airworthiness certificate be "display ed at the cabin or cockpit entrance so that it is legible to passengers or crew." A t a maximum gross weight of 1216 gr ams or about 2lbs, 11oz , the sUAS is too small to carry documentation, does not have an entrance, and is not capable of carry ing passengers or crew. To obtain an equivalent level of safet y and meet the intent of 91.203, we propose that documents deemed app ropriate 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 airworth y 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" afte r maintenance and inspection. I t is our intention that the PI C 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 airworth y condition prior to every

flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed b y the PI C 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 PI C will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircr aft, the PIC can ensure an equivalent level of safet y. Safety and Benefits of the UAS Women’s Investment Group, Inc will be using the UAS in a variet y of applications that generall y 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 photo graphy and real estate marketing

. Replacing significantly

larger manned aircraft carry ing crew and flammable fuel with small UAS car

ry ing no passengers or crew creates a much greater margin of safe ty 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 pu

blic knowledge base for such operations. Conclusion As pointed out in th is application, the DJ I Phantom 3, which our compan y would use, under authorization by

the US DOT

- FAA, is a small, light

- weight device operated within the line of sight of the Pilot

- i n - Command (PI C), less than 400 fee t 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 notifiedand have author ized each flight within a radius of this distance.

The DJ I 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 L aw 112

- 95, 2014, have already provided y ou with the assurances on the airworthiness of sUAS such as ours. For the foregoing reasons, the exemptions requested herein should b e granted and Women’s Investment Group, Inc should be permitted to conduct sm all UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate b y the FAA. The submission of this application and its contents is the best demonstration that indeed it is possible to pursue the authori zation process so that some SUAs may be used for legitimate commercial activities and under reasonably safe conditions. Signed