918 NETWORKS, LLC., Tulsa, OK - Section 333 Exemption Petition

Dear Sir or Madam,

We, 918 NETWORKS, 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 NETWORKS, LLC., 

an owner and operator of small unmanned aircraft, be exempted from the

Federal Aviation Regulations (“FARs”) listed below so that We, 918 NETWORKS, 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 NETWORKS, 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 federal 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) Walkera X350 Pro 

Quadcopter, (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 provide 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 

before 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 plan or controls in place to prevent catastrophe. We, 918 

NETWORKS, 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 protocols exclusive to lightweight UAS's specific to real estate video and 

photography usage as We, 918 NETWORKS, LLC., record flight data and other information 

gained through permitted flight operations to share with the FAA through any required FAA 

reports to assist 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 system, but to “...establish requirements for the safe
918 NETWORKS, 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 We, 918 NETWORKS, LLC., will conduct our operations in compliance with 

the protocols described herein or as otherwise established by the FAA.

For the reasons stated below, We, 918 NETWORKS, LLC., respectfully request the grant of an

exemption allowing us to operate ultra light 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 NETWORKS, LLC.

Josh Basquez

3220 ELMO WAY

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 NETWORKS, LLC., Tulsa, OK - Section 333 Exemption Petition

III. The Extent of relief 918 NETWORKS, LLC. seeks and the Reason He Seeks Such

Relief:

We, 918 NETWORKS, 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 NETWORKS, 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 so. Our, 918 NETWORK’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. We would like to operate our light weight UAS prior to the time period by

which 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 uniformly 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

weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be

operated near airports or heavily populated areas; and, Whether 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 NETWORKS, 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 NETWORKS, LLC., considers safety a top 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). Built 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 NETWORKS, 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). 

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

zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's 

into the national airspace system. 918 NETWORKS, LLC.’s UAS, used in hobby flight, have a 
918 NETWORKS, LLC., Tulsa, OK - Section 333 Exemption Petition

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

security. 

IV. How 918 NETWORKS, LLC’s Request Will Benefit the Public As A Whole:

918 NETWORKS, LLC intends to provide a low-cost aerial photography commercial service to 

small and medium sized businesses that would otherwise be unable to afford 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 NETWORKS 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 NETWORKS is comprised of current and former 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. Reasons Why 918 NETWORKS, LLC’s Exemption Will Not Adversely Affect Safety

Or How The Exemption Will Provide a Level of Safety At 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 as 

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 are carefully planned to eliminate or reduce any risks to private property.

918 NETWORKS 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 scale 

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 NETWORKS, 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 enclosed operational area of our, 918 NETWORKS, 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 airworthiness 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,

maneuverability and proximity to areas such as airports and dense populations. Our,

918 NETWORKS, 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

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 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.

14 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 certifications and

registrations by us, 918 NETWORKS, 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 therefore 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, We 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 exemptions 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. We, 918 NETWORKS, LLC., can achieve an equivalent level of safety as achieved 

by
918 NETWORKS, LLC., Tulsa, OK - Section 333 Exemption Petition

current Regulations because our UAS does not carry any pilots or passengers. Further,

while helpful, our operators are required to hold this certification to pilot UAVs. The risks

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 NETWORKS, 

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 NETWORKS, LLC., will however operate our UAS in safe areas away from public and

traffic, providing 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 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. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not,

therefore, apply to our, 918 NETWORKS, 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 NETWORKS, 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

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,

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 inapplicable. 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 software

updates and curative measures for any damaged hardware. Therefore, an equivalent
918 NETWORKS, 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 

NETWORKS, small unmanned vehicle/lightweight unmanned aircraft vehicle for the purpose of 

aerial photography and videography. 

Posing potential risk to the public. Granting our, 918 NETWORKS, 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 maneuverable than conventional 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 risks 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 air fields. We, 918 NETWORKS, 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 Act 

of 2012. There are no personnel on board our UAS and therefore the likelihood of death or 

serious bodily injury is significantly diminished. Operation of our UAS, with low weight and lower 

speeds within limited areas will provide an equivalent level of safety as that achieved under 

current FARs. Accordingly We, 918 NETWORKS, LLC., respectfully request that the FAA grant 

our exemption request and are willing to cooperate in sharing information to benefit the FAA, 

safety of manned aircraft, and the general public at large.

Respectfully submitted,

918 NETWORKS, LLC.

Josh Basquez

3220 ELMO WAY

MOORE, OK 73160