918 NETWO RKS, LLC., Tulsa, OK

- Section 333 Exemption Petition

Dear Sir or Madam,

We , 918 NETW ORKS, LLC., are writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that 918 NETWO RKS, LLC., an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that W e, 918 NETW ORKS, LLC., may operate our small ultra light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”)

.
As described herein, 918 NETWO RKS, LLC, member pilots are experienced in flying hobby aircraft for recreational purposes, and are former and current active duty military aircraft mechanics and technicians. Our sUAS operator roster includes civilian fede ral employees of the DoD, and active duty Navy mechanics, all familiar with detailed procedures for documenting thorough safety maintenance and operating procedures.

Our aircraft for which we are requesting exemption includes : (a) W alk era X350 Pro Quadco pter, (b) 1 meter Tarot Octocopter, (c) 250mm small Quadcopter, (d) 450mm DJI Flamewheel, and (e) 2 meter Styrofoam fixed wing craft (SkySurfer) with the intent to capture aerial videography/cinematography to augment real estate listing videos and to provi de training and demonstrations of sUAS capabilities for local emergency management to include support of the mission of the FEMA/state recognized emergency management groups Oklahoma Floodplain Managers Association (501c3), and associated Oklahoma Disaster Response Team.

Exemption request would Permit operation of ultra light weight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly controlled and limited airspace over predetermined areas away from general public, airports, heliports and vehicular traffic for videos, and within property boundaries for individual homeowner real estate listing videos/photos. Permit operation in support of Oklahoma’s Disaster Response Team, to include documentation bef ore and after disasters to assist emergency managers, FEMA, HUD, and other state and federal agencies in the assessment of damages caused by flooding.

Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety pl an or controls in place to prevent catastrophe. W e, 918 NETW ORKS, LLC. , have developed and implemented Standard Operating Procedures to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to further safety pr otoco ls exclusive to lightweight UAS's specific to real estate video and photography usage as We, 918 NETWO RKS, LLC., record flight data and other information gained through permitted flight operations to share with the FAA through any required FAA reports to a ssist with future protocol and safety regulation.

Granting our, 918 NETWORKS, LLC.'s, request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate UAS's into the national airspace syste m, but to “...establish requirements for the safe918 NETWO RKS, LLC., Tulsa, OK

- Section 333 Exemption Petition

operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor purposes. Further W e, 918 NETW ORKS, LL C., will conduct our operations in compliance with the protocols described herein or as otherwise established by the FAA. For the reasons stated below, W e, 918 NETW ORKS, LLC., respectfully request the grant of an exemption allowing us to operate ultra ligh t weight, remote controlled UAS’s for the commercial use to operate aerial photography for local businesses and for the commercial and volunteer purpose of assessing flood and other storm damages in Oklahoma and surrounding areas.

**I. Contact Information:** 918 NETWO RKS, LLC. Josh Basquez 3220 ELMO W AY Moore, OK 73160 Office: (918) 550

- 1534 Email: josh.basquez@okstate.edu

**II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which 918 NETWORKS, LLC., Requests Exemption are:**  14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).918 NETWO RKS, LLC., Tulsa, OK

- Section 333 Exemption Petition

**III. The Extent of relief 918 NETWORKS, LLC. seeks and t he Reason He Seeks Such**  **Relief:** We , 918 NETW ORKS, LLC., submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating to prevent we, 918 NETWO RKS, LLC. contemplated commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do s o. Our, 918 NETW ORK’s, ultra light weight UAS aircraft fleet meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of our ultra light weight UAS is expressly contemplated by the Reform Act. W e would like to operate our light weight UAS prior to the time period by wh ich the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniform ly to all real estate related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The

we ight, size, speed and overall capabilities of the UAS's; W hether the UAS will be operated near airports or heavily populated areas; and, W hether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for us, 918 NETW ORKS, LLC.

Our UAS are equipped with GPS and auto return safety technology, and weigh less than 20lbs. for all aircraft other than sUAS b (1m Tarot), and less than 40lbs. including camera with gimbal for the 1m Tarot.

918 NETWO RKS, LLC., considers safety a to p priority with each flight. Our multirotor unmanned aircraft are designed to hover in place via GPS and operate in less than a 13 knot (15 mph) wind. For safety, stability and fear of financial loss we will not fly in winds exceeding 13 knot (15 mph). Bui lt in safety systems include a GPS mode that allows our UAS to hover in place when radio controls are released, and to return to launch (RTL) when all communications with the Ground Control station is lost.

Our UAS are also equipped with emergency landing switches to order an immediate landing or shutoff as needed should we need to quickly bring the aircraft to land in place.

918 NETWO RKS, LLC. maintains high safety standards and will go to great lengths to protect the safety of all parties and properties within the immediate area of the flight path. We will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b).

G iven the small size and weight of our UAS it falls well within Congress’s contemplated safety

zo ne when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. 918 NETWORK S, LLC.’s UAS, used in hobby flight, have a918 NETWO RKS, LLC., Tulsa, OK

- Section 333 Exemption Petition

demonstrable safety record and does not pose any threat to the general public or national security.

**IV. Ho w 918 NETWORKS, LLC’s Request Will Benefit the Public A**  **s A Whole:**  918 NETWO RKS, LLC intends to provide a low

- cost aerial photography commercial service to small and medium sized businesses that would otherwise be unable to af ford aerial photography services from a fully manned aircraft.

We will use electric battery powered aircraft that have no CO2 emissions, and will be working to demonstrate the capabilities of these systems to local emergency managers at no cost.

918 NETW ORKS also intends to provide volunteer service to state and federal emergency agencies for the purpose of documenting disaster damages to aid in the assessment and application for federal disaster relief funds.

918 NETWO RKS is comprised of current a nd f ormer federal employees that intend to coordinate with FEMA, HUD, and other federal agencies to provide sUAS services in the realm of disaster assessment via aerial photography and videography performed by our multirotors and fixed

- wing aircraft.

**V. R easons Why**  **918 NETWORKS, LLC’s Exemption Will Not A** **dversely A**  **ffect Safety Or How The Exemption Will Provide a Level of Safety**  **A t Least Equal To Existing**  **Rule:**

Our, 918 NETWORKS, exemption will not adversely affect safety.

We always research local airports and control towers, ensuring we are operating outside of a 5 mile radius or have previously contacted the airport to coordinate safe operating procedures. We maintain multiple layers of radio control, including radio modem based control, as well a s radio control (RC) link control. We include failsafe conditions in the logic of the main flight controller, which dictates the behavior of the aircraft upon loss of signal from the ground control station.

Our, 918 NETWORKS, safety record is clean, with no incidents of damage to property or physical injuries after hundreds of hours of private, non

- commercial flight time logged between our current team of 3 pilots. Our aicraft undergo exentesive testing and pre

- flight safety checks, and our flight paths a re carefully planned to eliminate or reduce any risks to private property.

918 NETWO RKS operates sUAS that are small and lightweight, and do not carry combustible fuels that would pose a greater safety risk if similar operations were performed by full sca le manned aircraft. We are confident that the operations we are performing are much safer because they are done via such small and lightweight unmanned aircraft.918 NETWO RKS, LLC., Tulsa, OK

- Section 333 Exemption Petition

VI. A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91 : Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclos ed operational area of our, 918 NETW ORKS, LLC.’s, UAS permits exemption from Part 21 because our UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthines s certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed,

ma neuverability and proximity to areas such as airports and dense populations. Our, 918 NETWO RKS, LLC.’s , current and projected UAS's meet or exceed each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certi ficate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. 10 The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our UAS utilizes electronic global positioning systems with a barometric sensor. 1 4 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifi cations and registrations by us, 918 NETW ORKS, LLC. B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. Our UAS are, by definition, unmanned. They ther efore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, W e will mark our UAS in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that we the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has previously issued exempt ions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. C. 14 C.F.R. § 61.133: Commercial Pilot Privileges and Limitations: PIC. Pursuant to14 C.F.R. § 61.133 (a

- i, ii), Commercial pilots are not limited to commercial operations. W e, 918 NETW ORKS, LLC., can achieve an equivalent level of safety as achieved by918 NETWO RKS, LLC., Tulsa, OK

- Section 333 Exemption Petition

current Regulations because our UAS does not carry any pilots or passengers. Further, wh ile helpful, our operators are required to hold this certification to pilot UAVs. The ri sks attended to the operation of our UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing us, 918 NETWO RKS, LLC., to operate our UAS and meet or exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Our UAS will never operate at an altitude greater than 300 AGL; safely below the standard of 400 AGL. We
, 918 NETW ORKS, LLC. , will however operate our UAS in safe areas away from public and traffic, pr oviding a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of our UAS, an equivalent or higher level of safety will be achieved. E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 10 Appendix F

- Safety Procedures The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part an d shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . .” These Regulations only apply to aircraft with an airworthiness certificate. They will no t, therefore, apply to our, 918 NETW ORKS, LLC.’s UAS. However, as a safety precaution we inspect our UAS before and after each flight as well as maintaining a maintanance log. A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C. F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of our UAS permits exemption from Part 21 because our, 918 NETWO RKS, LLC. ’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certi ficate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Our UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) 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 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inappli cable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular softwa re updates and curative measures for any damaged hardware. Therefore, an equivalent918 NETWO RKS, LLC., Tulsa, OK

- Section 333 Exemption Petition

level of safety will be achieved.

In summary, 918 NETWORKS, LLC. seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 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)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate our, 918 NETW ORKS , small unmanned vehicle/lightweig ht unmanned aircraft vehicle for the purpose of aerial photography and videography.

Pos ing potential risk to the public. Granting our, 918 NETWO RKS, LLC’s , request for exemption will reduce current risk levels and thereby enhance safety. Our UAS craft do not contain potentially explosive fuel, is smaller, lighter and more mane uverable than c onventional aircraft, without the extra risks posed by flying over residential and other areas between local airports and the area to be filmed. By using aircraft that can takeoff and land from nearby the areas to be filmed or photographed, we reduce the r isks posed not only to the pilot and crew, but to the properties and areas that must be flown over by conventional manned aircraft.

We operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established a ir fields. We
, 918 NETW ORKS, LLC., document any incidents of mishaps

or near
- mishaps . Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Ac t of 2012. There are no personnel on board our UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. O peration of our UAS, with low weight and lower speeds within limited areas will provide an equivalent level of s afety as that achieved under current FARs. Accordingly W e, 918 NETW ORKS, LLC. , respectfully request that the FAA grant our exemption request and are willing to cooperate in sharing information to benefit the FAA, saf ety of manned aircraft, and the general public at large.

Respectfully submitted, 918 NETWO RKS, LLC. Josh Basquez 3220 ELMO W AY MO ORE, OK 73160