Pacific	Panel	Cleaners	LLC License	C34167

4348	Waialae	Avenue	#286	Honolulu	HI	96816	(808)	772
- 4705 Page 1 Section 333 Exemption Request April 8, 2016

Applicant Information: Pacific Panel Cleaners LLC License C34167 Attn: Fred Brooks 4348 Waialae Avenue #286 Honolulu HI 96816 Phone: (808) 772
-4705 Email: fred@pacificpanelcleaners.com Certifications: Member of ASES Member of Academy of Model Aeronautics Certified Energy Manager (CEM) #18577 Certified Energy Auditor (CEA) Certified Level 1 Thermographe r **Electronically submitted via regulations.gov** April 8, 2016 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Request Pursuant t o Section 333 of the FAA Reform Act of 2012 Dear Administrators, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, Pacific Panel Cleaners LLC, is seeking exemption to safely operate commercial unmanned aerial vehicles or UAS under the conditions of this petition or as establi shed by the FAA in order to allow commercial operation of its Small Unmanned Aircraft Systems (“sUAS’”). Pacific Panel Cleaners has been in business since 2009, and was the first company in Hawaii dedicated solely to the maintenance and cleaning of solar panels, servicing solar panels all over the islands . We hope to use the drone to improve the safety and longevity of solar panel systems here in Hawaii while promoting the growth of the renewable energy industry as a whole, and more specifically the operations, maintenance, and asset protection sector of the solar energy industry. Pacific Panel Cleaners seeks Section 333 exemption to provide the following services to our public and private clients. Pacific Panel Cleaners has developed safe operating practices to provide UAS inspection and data collectionPacific	Panel	Cleaners	LLC License	C34167

4348	Waialae	Avenue	#286	Honolulu	HI	96816	(808)	772
- 4705 Page 2 services for large scale solar utilities and solar farms, commercial and private solar arrays, residential solar arrays and construction industries and real estate properties including but not limited to:

 Remote sensing and measuring by an instrument(s);  Electronic and chemical measurement;  Aerial photography and videography for mapping;  Thermal imaging of solar arrays; **Manual s**  **and Safety Guidelines :**  Due to size of files please go to: http://www.dji.com/product/phantom

- 2
-vision to review the following DJI Phantom 2 vision Once website opens click on “Downloads”. Then under Documents and Manuals open the following PDF files to review: P hantom 2 Vision Release Notes 2015
-04
- 27 Phantom 2 Vision User Manual (EN) v1.8 2015
-01
- 30 Phantom 2 Vision User Manual (FR) v1.08 2014
-02
- 18 Phantom 2 Vision User Manual (DE) v1.08 2014
-02
- 18 Phantom 2 Vision Quick Start Guide (EN) v1.0 2013
- 10
- 30 Phantom 2 Vision Quick Start Guide (DE) v1.0 2013
- 10
- 30 Smart Flight Battery Safety Guidelines (EN, FR, DE and JP) 2014
- 10
- 15 Phantom 2 Vision Pilot Training Guide v1.0 2013
- 11 - 16 As detailed in this document and the referenced DJI manuals and guideline s, the requested exemption would allow the operation of sUAS under controlled conditions in airspace at the request of and with the authorization and permission of clients or their authorized agents, facilitating commerce and raising awareness of the beneficial uses of sUAS’s. Operation would be limited, predetermined, controlled to access and provide more cost -effective methods and safety enhancements to the already regulated safety practices presently followed by conventional manned aircraft as governed by the FAA . Approval of this exemption would thereby enhance public safety while fulfilling the FAA’s responsibilities to establish requirements for safe operation of such aircrafts in national airspace.Pacific	Panel	Cleaners	LLC License	C34167

4348	Waialae	Avenue	#286	Honolulu	HI	96816	(808)	772
- 4705 Page 3 Pacific Panel Cleaners agrees to be bound u nder these conditions and limitations when conducting sUAS operations which would provide equivalent or enhance public safety to current operations conducted by conventional manned aircraft: 1. Pacific Panel Cleaners’ UAS will weigh less than 55 pounds (25 kg). 2. P acific Panel Cleaners’ UAS will be operated at a speed of no more than 100 mph. 3. Flights will be operated within visual line of sight of a pilot. 4. UAS operations will occur during daylight hours only. 5. Minimum crew for each operation will consist of Pacific P anel Cleaner’s UAS Operator and a Visual Observer. 6. Pacific Panel Cleaners’ UAS Operator will be Pilot in Command (PIC) with an FAA sports pilot’s certi ficate or higher and shall have completed the required FAA training, UAS manufacturer training, and have a valid driver’s license. 7. The PIC will be trained in flight, operations, and safety procedures as detailed in the Flight Manual. 8. Pacific Panel Cleaners’ UAS will only operate within a confined controlled area of the flight operations area. 9. Maximum total flight time for each operational flight will be 30 minutes. Flights wi ll be terminated at 20% battery power reserve, should that occur prior to the 30 minute limit. 10. A mandatory briefin g will be conducted in regard to the planned UAS operations prior to each day’s activities. 11. The operator will obtain consent of all persons involved and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based upo n an equivalent level of safety determination. 12. PIC and VO will at all times be able to communicate by voice. 13. PIC will conduct preflight inspections to ensure Mesa’s UAS is safe for operation. 14. Flights will be operate d at an altitude less than 400 feet AGL. 15. Pacific Panel Cleaners’ UAS will only operate in Class G airspace. 16. Any site within 5 miles of an airport will not be flown without notification and approval of the local FAA Flight Standards District Office (FSDO) a nd airport controller. 17. All required permissions and permits will be obtained from relevant property owners, territorial, state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 18. If Pacific Pan el Cleaners’ UAS loses communication or GPS signal, it will have capability to return and land to a pre - determined location within the Security Perimeter. 19. Pacific Panel Cleaners’ UAS will be able to abort a flight in case of unpredicted obstacles or emerge ncies. 20. All Pacific Panel Cleaners’ aircraft will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N −Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicabl e. **Reference to similar Petitions:** AirShark LLC – Exemption No. 11651 Astreus Aerial, petition – Exemption Nos. 11062 Greenside Energy LLC – Exemption No. 12307 Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations fromPacific	Panel	Cleaners	LLC License	C34167

4348	Waialae	Avenue	#286	Honolulu	HI	96816	(808)	772
- 4705 Page 4 14 CFR § 21 , Subpart H; 45.21; 45.23(b); 45.25; 45.27; 45.29; 61.113(a) and (b); 91.7(a); 91.9 (b) 91.103; 91.105; 91.109 ; 91.113 (a) and (b) ; 91.119; 91.121; 91.151(a); 91.203 (a) and (b) ; 91.405(a) and (d); 91.407(a)(1); 91.409(a)(2); and 417(a) and (b)

I. 14 CFR 21, Subpart H: Airworthiness Certificate Pacific Panel Cleaners requests an exemption from 14 CFR 21, Subpart H, which establishes the procedures for the issuance of an airworthiness certificate. Pacific Panel Cleaners requests an exemption because the Phantom meets an equivalent level of safety pursuant to Section 333 of the FMRA due to its small size, light weight, and remote, rural operating environment. II. 14 CFR 45.21: General Pacific Panel Cleaners requests an exemption from 14 CFR 45.21, which provides that except as provided in §45.22, no person may operate a U.S. registered aircraft unless that aircraft displays nationality and registration marks in accordance with the requirements of this section and §§45.23 through 45.33. Currently there are no procedures for obtaining a registration mark for the UAS by the FAA, but Pacific Panel Cleaners is agreeable to having a registration n umber assigned and to displaying it where practic able relative to §§45.23, 45.27, and 45.29. III. 14 CRF 45.23(b): Marking of the Aircraft Pacific Panel Cleaners requests an exemption from 14 CFR 45.23(b), which requires that “...the operato r must also display o n that aircraft near each entrance to the cabin, cockpit, or pilot station , in letters not less than 2 inches nor more than 6 inches high, the words ‘limited,’ ‘restricted,’ ‘light
- sport,’ ‘experimental,’ or ‘provisional,’ as applicable.” Pacific Panel Cle aners requests an exemption from this requirement since the Phantom does not have a cabin, cockpit, or pilot station entrance on or near which the required marks can be displayed. Also, two to six
- inch lettering is not practical due the small size of the U AS. Pacific Panel Cleaners will place the word “Experimental” on the UAS in compliance with §45.29(f) and in t he largest practicable manner, which will provide an equivalent level of safety. IV. 14 CFR 45.25: Location of Marks on Fixed
-Wing Aircraft Pacific P anel Cleaners requests an exemption from 14 CFR 45.25, which describes marking requirements on fixed wing aircraft. The Phantom is a multirotor quadcopter and not a fixed
-wing aircraft. Thus, 14 CFR 45.25 is not applicable. V. 14 CRF 45.27: Location of Marks on Nonfixed
-Wing Aircraft Pacific Panel Cleaners requests an exemption from 14 CFR 45.27, which provides that each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23. The Phantom is small and does not have cabin, fuselage, boom, or tail to display the marks required by §45.23. As such, the marking requirements of this section are not feasible, though the UAS will display the required marking in the l argest practicable manner in conspicuous locations. VI. 14 CFR 45.29: Size of Marks Pacific Panel Cleaners requests an exemption from 14 CFR 45.29, which provides tha t the registration marks for rotorcraft must be at least 12 inches high. Due to its small siz e, the Phantom does not have aPacific	Panel	Cleaners	LLC License	C34167

4348	Waialae	Avenue	#286	Honolulu	HI	96816	(808)	772
- 4705 Page 5 surface area large enough to display marks at least 12 inches high. The UAS will display the required marking in the largest practicable manner in conspicuous locations. VII. 14 CFR 61.113(a) and (b): Private Pilot Privileges and Limitations; PIC Pacific Panel Cleaners requests an exemption from 14 CFR 61.113 (a) and (b), which restricts private pilots from flying aircraft for compensation or acting as PIC unless the flight is only incidental to that business or employment. Curren tly there are no standards for private or commercial UAS operations, and Pacific Panel Cleaners proposes using private pilots with a third clas s medical in support of its own operations. Because of the Phantom’s size, weight, speed, and limited area where it would be operated by Pacific Panel Cleaners, a PIC with a private pilot’s license and the above described training and logged hours would ensure public safety and prevent any hazards to the NAS. VIII. 14 CFR 91.7(a): Civil Aircraft Airworthiness Pacific Pane l Cleaners requests an exemption from 14 CFR 91.7(a), which provides that no person may operate a civil aircraft unless it is in airworthy condition. If an exemption from 14 CFR 21, Subpart H is granted, no airworthiness certificate will be required. Thus, this requirement may be inapplicable, assuming that airworthy condition means having an airworthiness certificate. Pacific Panel Cleaners will, however, ensure that maintenance requirements are met, all preflight checks are completed, and an equivalent level of safety will be provided. IX. 14 CFR 91.9 (b) (2) Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry flight manual. A equivalent level of s afety will be maintained by keeping the flight manual at ground control point where the pilot wil) have immediate access to it. X. 14 CFR 91.103: Preflight Action Pacific Panel Cleaners requests an exemption from 14 CFR 91.103, which requires the PIC to perform certain preflight inspections before flight. The PIC will take actions before initiation of any flight to ensure the safety of the same, including performing the Phantom preflight check and reviewing weather reports, forecasts, flight battery requireme nts, takeoff and landing distances, and aircraft performance data. XI. 14 CFR 91.105: Flight Crewmembers at Stations Pacific Panel Cleaners requests an exemption from 14 CFR 91.105 as this section is not applicable due to the Phantom carrying no flight crewme mbers. XII. 14 CFR 91.109 UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraft via radio communications. The equivalent level of safety pro vided because neither a pilot nor passenger will be carried in the aircraft, and by the speed and size of the aircraft. XIII. 14 CFR 91.113 (a) and (b) I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not carry pilot nor passenger. While helpful, a pilots' license will not ensure remote control piloting skills. XIV. 14 CFR 91.119(c): Minimum Safe Altitudes Pacific Panel Cleaners requests an exemption from 14 CFR 91.119(c), which prohibits operating an aircraft at an altitude of less than 500 feet except over open water or sparely populated areas, and in those cases,Pacific	Panel	Cleaners	LLC License	C34167

4348	Waialae	Avenue	#286	Honolulu	HI	96816	(808)	772
- 4705 Page 6 no closer than 500 feet to any person, vessel, vehicle, or structure. Pacific Panel Cleaners’ petition requests authority to operate at altitudes up to 40 0 feet above the surface. Because of the remote location of the UAS’s operation and its size, weight, and limited speed, and the consent of the property owner, the equivalent level of safety will be achieved. There will be no increased hazard to the public or users of the NAS. XV. 14 CFR 91.121: Altimeter Settings Pacific Panel Cleaners requests an exemption from 14 CFR 91.121, which requires an aircraft to be operated by reference to an altimeter that is set to the elevation of the departure airport or an app ropriate altimeter setting available before departure. The Phantom will not have a barometric altimeter, but instead a GPS altitude read out. Therefore, an exemption is requested. An equivalent level of safety will be achieved by the operator confirming th e altitude of the launch site as shown on the GPS prior to takeoff. The operator will also monitor the UAS and control its maximum height. XVI. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions Pacific Panel Cleaners requests an exemption from 14 CFR 91.151(a), which prohibits a person from beginning a flight in an airplane under VFR conditions unless there is enough fuel to fly to the first point of intended landing and then, during the day, for at least 30 minutes. Pacific Panel Cleaners will operate the Phantom with an equivalent level of safety by terminating the flight after 25 minutes or at a 25% battery power level (whichever occurs first). The UAS also features an aircraft battery monitoring system, and it will alert the operator of low b attery voltage and return the aircraft to its take off location before battery capacity is depleted. Pacific Panel Cleaners will not operate the Phantom at night. XVII. 14 CFR 91.203 (a) and (b) Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry certificate and registration documents on the aircraft. There is no room, capacity, or pilot on board to adequately such documents. An equivalent level of safety wili be achieved by keeping these documents, to the extent th ey are applicable to the UAS, at the ground control point where pilot has immediate access to them. XVIII. 14 CFR 91.405(a) and (d); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b): Maintenance Inspections Pacific Panel Cleaners requests an exemption from 14 C FR 91.405 (a) and (d); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b), which specify maintenance and inspection standards. These sections and Part 43 only apply to aircraft with an airworthiness certificate, so they are inapplicable to Pacific Panel Cleaners . Instead, Pacific Panel Cleaners will perform maintenance in accordance with DJI’s Phantom User Manual and Phantom Pilot Training Guide, keeping a log of any maintenance performed. It will also inspect the UAS and ensure it is in a condition safe for flight before initiating any flight. An equivalent level of safety will be achieved because the Phantom is small in size and operates in a limited area for limited periods of time.