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 Thermographer

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 to 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 established 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 collection
Pacific	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;

Manuals 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: 

Phantom 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 guidelines, 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.
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Pacific Panel Cleaners agrees to be bound under 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. Pacific 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 Panel 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 certificate 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 will be terminated at 20% 

battery power reserve, should that occur prior to the 30 minute limit.

10. A mandatory briefing 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 upon 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 operated 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) and 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 Panel 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 emergencies.

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 practicable.

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 from 
Pacific	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 number assigned and to displaying it where practicable 

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 operator 

must also display on 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 Cleaners 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 UAS. Pacific Panel 

Cleaners will place the word “Experimental” on the UAS in compliance with §45.29(f) and in the largest 

practicable manner, which will provide an equivalent level of safety.

IV. 14 CFR 45.25: Location of Marks on Fixed-Wing Aircraft

Pacific Panel 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 largest 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 that the registration 

marks for rotorcraft must be at least 12 inches high. Due to its small size, the Phantom does not have a 
Pacific	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. Currently there are no standards for private or commercial UAS operations, and Pacific Panel 

Cleaners proposes using private pilots with a third class 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 Panel 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 safety 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 requirements, 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 crewmembers.

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 provided 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

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no closer than 500 feet to any person, vessel, vehicle, or structure. Pacific Panel Cleaners’ petition requests 

authority to operate at altitudes up to 400 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 appropriate 

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 the 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 battery 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 they 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 CFR 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.