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PARAGON 

GEOPHYSICAL SERVICFS. tNC 

June 8, 2015 

U.S. Department of Tra.nsportation 

Docket Operations 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Submission of Request for Authorization to Conduct Unmanned Aircraft 

System Operations Allowed by Section 333 of the FAA Modernization and Reform 

Act of 2012 Through the Eaemption Process Identified Under 14 C.F.R. Section 

11.81 

Dear Mr. Secretary, 

Pursuant to Section 3 ~ 3 of PL 112-95 commonly known as the "FAA Modernization and 

Reform Act of 2012" or "The Reform Act'', Paragon Geophysical Services, Inc. (Paragon) 

petitions for authorization to conduct commercial unmanned aerial system (UAS) operations for 

the oil and gas exploration industry, within the United States National Airspace System (NAS). 

These operations include but are not limited to, site survey, quality control data collection, 

volumetric, geo-location magnetic and gravity measurements, aerial photography, videography, 

agriculture, scientific studies, wildlife monitorin ~ and forestry. 

The narne and address of the applicant is: 

Paragon Geophysical Services, Inc. 

Attn: Jeffrey W. Loban, Vice President Operations 

3500 N. Rock Road, Building 800 Suite B 

Wichita, KS 67226 

Ph: 316-636-5552 

j eff(a~paragongeo.com 

Paragon petitions to be exempt from the followinor C.F.R.s in accordance with precedent 

set by the following approvals: Exemptions 11062 throu ~h 11067, 11080, 11109, 11110 and 

11213. 

Paragon also requests the secretary determine that ~ood cause exists for not publishing a 

summary of the petition in the Federal Register because the requested exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to the petitioner. 

3500 N. Rock Rd. Bldg 800, Suite B• Wichita, KS 67226 

(316) 636-5552 • FAX (316) 636-5572 
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GEOPF~ICAL S6=VICES, ItVC 

The regulations from which the exemption is requested are as follows: 

14 C.F.R. § 61.23 (a) and (c), 

14 C.F.R. S 61.101(e)(4) and (5), 61.113 (a) and (b), 61. 3 15(a); 

14 C.F.R. 5 91.7(a); 

14 C.F.R. 5 91.103; 

14 C.F.R. 5 91.109(a) 

14 C.F.R. § 91.119(c); 

14 C.F.R. 5 91.121 

14 C.F.R. § 91.151(a); 

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b) 

Appendix A discusses each rule listed above and explains why exemptions pursuant to the 

proposal set forth in this letter are appropriate, provide an equivalent level of safety,and are in 

the public interest. 

Paragon Geophysical Services, Inc. has been in operation for more than 30 years and is dedicated 

to helping companies discover oil, natural gas and geothermal reservoirs, while maintainin ~ the 

hi~hest safety a.nd quality standards. Based out of Wichita, Kansas, Paragon recruits highly 

experienced crew members a.nd utilizes the latest technolo ~y to deliver results and information 

quicker than our competitors. Paragon" s continual investment in people and technoloay results in 

a less environmentally invasive and less costly final product. Paragon's use of unmanned aerial 

systems will reduce the amount of surface traffic on native grasslands, pastures a.nd cultivated 

areas, which will in turn reduce possible surface dama ~e and compaction in environmentally 

sensitive areas, thus would be in the best "public interest'". 

Equivalent Level of Safety 

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at 

least an equivalent or even higher level of safety to operations under the current regulatory 

structure because the proposed operations represent a safety enhancement to operations that 

would be conducted with conventional aircraft. These conditions are drawn from Exemptions 

11062 through 11067, 11080, 11109, and 11110. 

Below are the limitations and conditions to which Paragon (or "operator") agrees to be bound 

when conductin ~ commercial operations under an FAA issued exemption: 

1. Operations will be limited to the Unmanned Aerial Systems (UAS) listed below with 

type, weight and airspeeds indicated. All UAS listed have a weight of less than 55 

pounds includina payload, and having a maximum airspeed of less than 87 knots (100 

3500 N. Rock Rd. Bldg 800, Suite B• Wichita, KS 67226 

(316) 636-5552 • FAX (316) 636-5572 
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miles per hour). Proposed operations of any other aircraft will require a new petition or a 

petition to amend this exemption. 

Model Txpe Weight Speed 

Sensurion Magpie UAS Fixed-Wing <151bs <68mph 

DJI S-1000+ Multi-Rotor <261bs <60mph 

DJIlnspire Multi-Rotor <151bs <50mph 

DJI Phantom Multi-Rotor <151bs <50mph 

Additional Documentation: 

• Sensurion Magpie UAS Operations and Maintenance Manuals (PYopYietar°y - 

pYovided as secondar°y document upon request) 

• DJI S-1000+, Inspire and Phantom Operations/User and Maintenance Manuals 

(PYovided as secondaYy document upon request) 

2. The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour). In no 

case will the UAS be operated at airspeeds greater than the maximum UAS operatin ~ 

airspeed recommended by the aircraft ma.nufacturer. 

3. The UAS will be operated at an altitude of no more than 400 feet above ~round level 

(AGL). Altitude will be reported in feet AGL. 

4. The UAS must be operated within visual line of sight (VLOS) of the pilot-in-command 

(PIC) at all times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC's FAA-issued airman medical 

certificate or U.S. driver's license. 

5. All operations must utilize a visual observer (VO). The UAS must be operated within the 

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The 

VO and PIC must be able to communicate verbally at all times; electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before the 

fli<-Yht and cannot transfer his or her designation for the duration of the flight. The PIC 

must ensure that the VO can perform the duties required of the VO. 

6. A copy of the FAA approved exemption and all documents needed to operate the UAS 

and conduct its operations in accordance with the conditions and limitations stated in the 

ga.nt of exemption, wi11 be hereinafter referred to as the operating documents. The 

3500 N. Rock Rd. Bldg 800, Suite B• Wichita, KS 67226 

(316) 636-5552 • FAX (316) 636-5572 
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GEOPHYSiCAL SEFMCES, INC 

operating documents must be accessible durino ,UAS -operations and made available to 

the Administrator upon request. If a discrepancy exists between the conditions and 

limitations in the FAA approved exemption and the procedures outlined in the operating 

documents, the conditions and limitations in the FAA approved exemption take 

precedence and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operatinc ,documents. 

The operator may update or revise its operatin ~ documents. It is the operator's 

responsibility to track such revisions and present updated and revised documents to the 

Administrator or any law enforcement official upon request. The operator must also 

present updated and revised documents if it petitions for extension of or amendment to its 

FAA approved exemption. If the operator determines that any update or revision would 

affect the basis upon which the FAA ganted its exemption, then the operator must 

petition for an amendment to its grant of exemption. The FAA's UAS Integation Offfice 

(AFS - 80) may be contacted if questions arise regarding updates or revisions to the 

operating documents. 

7. Any UAS that has underaone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.cr., replacement of a flight critical component, must undergo a 

functional test flicrht prior to conducting further operations under this exemption. 

Functional test fli ~hts may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property. 

8. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in 

a condition for safe operation. 

9. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

is in a condition for safe fli ~ht. The pre-fli ~ht inspection must account for all potential 

discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals 

a condition that affects the safe operation of the UAS, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the UAS is found to 

be in a condition for safe fli ~ht. 

10. The operator will follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, a.nd life limit requirements for the aircraft and aircraft components. 

11.Each UAS operated under this petition will comply with all manufacturer safety bulletins. 

12.The PIC must hold either an airline transport, commercial, private, recreational, or sport 

pilot certificate. The PIC must also hold a current FAA airman medical certificate or a 

3500 N. Rock Rd. Bldg 800, Suite B+ Wichita, KS 67226 

(316) 636-5552 • FAX (316) 636-5572 
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valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a 

territory, a possession, or the Federal Government. The PIC must also meet the fli ~ht 

review requirements specified in 14 CFR 5 61.56 in an aircraft in which the PIC is rated 

on his or her pilot certificate. 

13. The operator may not permit any PIC to operate unless the PIC demonstrates the ability 

to safely operate the UAS in a manner consistent with how the UAS will be operated 

under this petition for exemption, includincy evasive and ememency ma.neuvers and 

maintainino,appropniate distances from persons, vessels, vehicles and structures. PIC 

qualification fli~ht hours and currency must be lo ~~ed in a manner consistent with 14 

CFR 5 61.51(b). 

Flights for the purposes of training the operator's PICs and VOs (training, proficiency, 

and experience-buildin ~) and determinin ~ the PIC's ability to safely operate the UAS in a 

manner consistent with how the UAS will be operated will adhere to the conditions and 

limitations specified within this petition for exemption. Traininc, operations may only be 

conducted durin~ dedicated training sessions. Durin ~ trainin~, proficiency, and 

experience-buildin~ fli~hts, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UAS with appropriate dista.nce from 

nonparticipants in accorda.nce with 14 CFR 5 91.119. 

14.UAS operations may not be conducted during night, as defined in 14 CFR S 1.1. All 

operations must be conducted under visual meteorolo ~ical conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

15. The UAS may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport's management is 

obtained or otherwise permitted by a COA issued to the exemption holder. The letter of 

agreement with the airport management must be made available to the Administrator or 

any law enforcement official upon request. 

16. The UAS may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

17.If the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the private or controlled-access property. 

18.The PIC must abort the flight in the event of unpredicted obstacles or emercrencies. 

3500 N. Rock Rd. Bldg 800, Suite B• Wichita, KS 67226 

(316) 636-5552 • FAX (316) 636-5572 
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GEOPhIYSICAL SEFfiV10ES, INC 

19. The PIC is prohibited from be ~inning a fli~ht unless (considering wind and forecast 

weather conditions) there is enough available power for the UAS to conduct the intended 

operation and to operate after that for at least 5 minutes or with the reserve power 

recommended by the manufacturer if greater. 

20. Air Traffic Oroanization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. 

21. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, a.nd have identification (NNumber) markinas in accordance with 14 CFR part 45, Subpart C. Markinas must be as 

large as practicable. 

22. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR 5 91.9 and 91.203 must be available to the PIC at 

the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request. 

23. The UAS must remain clear a.nd give way to all manned aviation operations and activities 

at all times. 

24. The UAS may not be operated by the PIC from any movina device or vehicle. 

25. All Flight operations must be conducted at least 500 feet from all nonparticipatincl, 

persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UAS and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection a.nd are within 500 feet of 

the UAS, fliorht operations must cease immediately in a manner ensurine ,the 

safety of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures ha.s 0ranted permission 

for operatincr closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not present 

an undue hazard. The PIC, VO, operator trainees or essential persons are not 

considered nonparticipating persons under this exemption. 

26. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission 

3500 N. Rock Rd. Bldg 800, Suite B• Wichita, KS 67226 

(316) 636-5552 • FAX (316) 636-5572 
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GEOPHYSICAL_ SER/ICES, INC 

from property owner/controller or authorized representative will be obtained for each 

fli~ht to be conducted. 

27. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 

Unless otherwise specified in this petition for exemption, the UAS, the UAS PIC, and the UAS 

operations will comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 

47, 61, and 91. 

The operation of small UAS, weighing less than fifty pounds, conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein. These lightweiaht aircraft operate at relatively slow speeds, near the ground, 

and in areas that are under the control of the operator. As a result, they, are far safer than 

conventional operations conducted with manned aircraft operating in close proximity to the 

ground and people. 

Sincerely, 

Je/y/W/ .Lan 

Vice President Operations 

Para~on Geophysical Services, Inc. 

3500 N. Rock Rd. Bldg 800, Suite B• Wichita, KS 67226 

(316) 636-5552 • FAX (316) 636-5572 
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GEOPHYSICAL SHRVICES, INC 

APPENDEX A 

Re"Iations – Exemption Reguested 

• 14 C.F.R. § 61.23(a) and (c); 

• 14 C.F.R. § 61.101(e)(4) and (5), 61.113 (a) and (b), 61.315(a); 

• 14 C.F.R. § 91.7(a) 

• 14 C.F.R. § 91.103 

• 14 C.F.R. 5 91.109(a) 

• 14 C.F.R. 5 91.119(c) 

• 14 C.F.R. § 91.121 

• 14 C.F.R. § 91.151(a) 

• 14 C.F.R. 5 91.405(a), 5 91.407(a)(1), § 91.409(a)(2) and 5 91.417(a) &(b) 

Pursuant to 14 C.F.R. 5 11.81(e), Paragon Geophysical Services, Inc. seeks exemption from 

the below mentioned rec

::

,ulations and provides reason as to why the exemption should be 

approved based on the level of safety at least equal to that of which the rules require. 

14 C.F.R. § 61.23(a) and (c); 

~- States: (a) Operations r°equiring a medical certificate. Except as provided in 

paYagraphs (b) and (c) of this section, a person: ... 

and 

(c) OpeYations j°equiring eitheY a medical certificate or U.S. driver's license. 

As set forth within FAA granted Exemptions 11062 throuah 11067, 11080, 11109, 11110 

and 11213 and others, the minimum requirement to operate a UAS for commercial 

purposes is to hold at least a sport license and a valid driver's license. The gra.nted 

exemptions exempt the UAS PIC from this limitation to his or her license. Paragon 

petitions for the same exemption as approved within the previously listed exemptions. 

• 14 C.F.R. § 61.101(e)(4) and (5), 61.113 (a) &(b), 61.315(a); 

61.101(e)(4) and (5); 

States: (4) Except as provided in paragraphs (d) and (i) of this section, a 

recreational pilot may not act as pilot in comnZand of an aif°cYaft3500 N. Rock Rd. Bldg 800, Suite B• Wichita, KS 67226 

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(4) Fof° compensation oY hij°e; 

(S) In fuYtherance of a business; 

:- 61.113 (a)and (b); 

States: (a) Except as provided in paYagraphs (b) through (g) of this sect.ion, no 

person who holds a pYivate pilot cef^tificate may act as pilot in command of an 

aiYcYaft that is carryZng passengef°s or pYopeYty foJ° compensation or hiYe; noY 

may that person, for compensation or hif°e, act as pilot in conzmand of an aif^craft. 

(b) A private pilot may, foY compensation oY hir°e, act as pilot in command of an 

aircf°aft in connection with any business or employment if.- 

y 61.315(a); 

States: (a) If you hold a spoYt pilot certifzcate you may act as pilot in command of 

a light-sport aircj^aft, except as specified in paf°agraph (c) of this section. 

(c)(2) For compensation or hire; 

(c) (3) In fuYtherance of a business; 

Under the current limitations of a private, recreational, or sport pilot license, a pilot 

holding a valid private, recreational or sport license cannot operate for compensation or 

hire or in the furtherance of a business. As set forth within FAA ganted Exemptions 

11062 through 11067, 11080, 11109, 11110 and 11213 and others, the minimum 

requirement to operate a UAS for commercial purposes is to hold at least a sport license 

a.nd a valid driver's license. The granted exemptions exempt the UAS PIC from this 

limitation to his or her license. Paragon petitions for the saame exemption as approved 

within the previously listed exemptions. 

• 14 C.F.R. § 91.7(a) 

i- States: No peYson may operate a civil aircYaft uYiless it is in an airworthy 

condition. 

Currently, there are no airworthiness certificates for the proposed UAS. Pre- and postflicrht inspections will be accomplished in accordance with manufacture's maintenance 

manual(s) and guidance. Durina flight, the PIC will adhere to C.F.R. § 91.7(b) and abort 

air operations immediately upon identification of an in-fli(Tht emer(yency. By applyincr 

the prescribed operations, inspection and maintenance procedures within the limitations 

and conditions of Paracron's petition for exemption, an equivalent level of safety will be 

achieved. 

3500 N. Rock Rd. Bldg 800, Suite B• Wichita, KS 67226 

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• 14 C.F.R. § 91.103 

:- States: Each pilot in command shall, before beginning a flight, become familiaY 

with all available information concerning that flight. This information must 

include- (paragraphs a, b, I and 2) 

A pre-flight mission brief will be attended by all crew members. This "PMB" will 

contain weather and all flight information includin ~ emer~ency and abort procedures. A 

signature will be required by all crew members indicating they have received the PMB 

and have read any NOTAMs or other procedural updates which may have impact to 

standard operatinb procedures. In addition, the PIC will verify the UAS is readv for flight 

by conductinor a pre-flight inspection. 

The exemption requested for this section is specifically addressed toward the 

requirements which do not apply to UAS operations such as runways and air traffic 

control integration. 

• 14 C.F.R. § 91.109(a) 

:- States: No person may opeYate a civil aircraft (except a manned fi-ee balloon) 

that is being used foY flight instt-uction unless that ail°cr°aft has fully functioning 

dual controls. 

The majority of UAS by design are developed with single operational control through 

the use of pre-determined GPS enabled waypoints pro ~rammed before or durin ~ fli~ht 

and/or the use of a sinale hand held transmitter or control station controlled by the PIC. 

This design does not allow for dual controls during flight training and therefore the 

exemption is requested. To assist in miti ~atin~ this limitation, all training will be 

conducted throuorh the use of a"buddy box" where the PIC/Trainer can regain control of 

the UAS at any time at their discretion. 

• 14 C.F.R. § 91.119 (c) 

i States: Except when necessaj-y for takeoff or landingg, no person may operate an 

aiYcraft below t.he following altitudes: (c) OveY other than conaested areas. An 

altitude of 500 feet above the suYface, except oveY open wat.eY or sparsely 

populated areas. In those cases, the air°craft may not be operated closer than 500 

feet to any peYson, vessel, vehicle, oY structuYe. 

Paragon operations will normally be conducted at or below 200 feet AGL in accordance 

with the automatically issued "blanket'' COA (as per the recently announced Section 333 

exemption streamlining - https://www.faa.gov/news/updates/?newsId=82245 )and in 

primarily Class G and E airspace. When operations require a hi ~her ceilin~ and/or are 

3500 N. Rock Rd. B(dg 800, Suite B• Wichita, KS 67226 

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within Class C and D airspace, Paragon will submit a request and operate under an 

approved COA. 

As UAS are inherently safer than traditional aircraft due to their small size, light weight, 

battery operation versus fuel and have no humans on-board; Paragon will not operate 

within 500 feet of any vehicles, persons or structures other than those part of the flight 

operation being conducted. In addition, objects and hazards identified and geo-located 

prior to flight operations will be utilized within the flight plannina stages to ensure this 

obj ective is met. 

14 C.F.R. § 91.121 

> States: Each person opeYating an aircYaft shall maintain the cf°uising altitude or 

f ight level of that aiYcraft, as the case may be, by YefeT°ence to an altimeteY that is 

set, when oper°ating... 

UAS are equipped with Global Positionin ~ System (GPS) which provide altitude and 

~eo-location data to the operator versus utilizing an altimeter. Due to this fact, an 

exemption is required for this system to be utilized in fli ~ht. GPS are precise within a few 

feet vertically and therefore meet a safety level equal to if not higher than regulatory 

~ uida.nce. 

As described in the limitations and conditions section of Paragon's petition for 

exemption; in the event the UAS loses GPS signal, automated landing will immediately 

commence. The flight plan is built in such a way that hazards are identified prior to 

launch and an immediate landincr within the fliaht plan will ensure all hazards are 

avoided. 

• 14 C.F.R. § 91.151(a) 

y- States: No peYson may begin a flight in an airplane under VFR conditions unless 

(consideringg wind and foYecast weather conditions) there is enough fuel to fly to 

the fiYst point of intended landing and., assuming normal cr°uising speed— (1) 

DuYing the day, to fly afteY that for at least 30 minutes; 

This regulation is based on the capabilities of a traditional aircraft which have flight times 

of several hours or greater; therefore, with the majority of UAS, which have flicrht times 

of an hour or less, this regulation would effectively deny the ability of the UAS to 

operate. 

Drawing from previously approved Exemptions the PIC is will not begin a flight unless 

(considerin ~ wind and forecast weather conditions) there is enou ~h available power for 

the UAS to conduct the intended operation and to operate after that for at least 5 minutes 

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thereafter or with the reserve power recommended by the manufacturer if greater. The 

ability to quickly and safely land UAS in non-traditional environments ensures at least a.n 

equal level of safety. 

• 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) &(b) 

y 91.405(a) States: Each owneY or operator of an aircraft=(a) Shall have that 

aircYaft inspected as prescribed in subpart E of this paYt and shall between 

Yequired inspections, except as p°ovided in paYagraph (c) of t.his section, have 

discf°epancies Yepaif°ed as pr°escribed in paYt 43 of this chapter 

y- 91.407(a)(1) States: (a) No person may operate any aircraft that has undefbone 

maintenance, preventive maintenance, rebuilding, or alteration unless—(1) It has 

been app°oved for YetuYn to service by a person authorized undej° § 43.7 of this 

chaptef° 

i 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no 

person may opeYate an aircYaft unless, within the p^eceding 12 calendaY months, 

it has had—(2) An inspection for the issuance of an aif°worthiness ces°tificate in 

accoYdance with paYt. 21 of this chapter. No inspection pe ~ formed undeY 

paYagraph (b) of this section may be substituted foj° any inspection required by 

this paragraph unless it is performed by a peYson authoYi::ed to peYform annual 

inspections and is enteYed as an "annual " inspection in t.he requif^ed 

maintenance recoYds. 

y- 91.417(a) &(b) States: (a) Except foY woYk perfoYmed in accoYdance with §§ 

91.411 and 91.413, each registered ownej° or operatof° shall keep the following 

Yecof°ds for the peYiods specied in paYagraph (b) of this section: (paYagr aphs I(i 

– iii), 2(i – vi)); (b) The owner oY opeYator shall retain the following, records foY 

the periods prescribed.• (paf°agra.phs I– 3) 

Due to the fact the proposed UAS presently do not have airworthiness certificates, these 

regulations do not apply and therefore an exemption is required. Pre/Post flight and 

routine inspections and maintenance will be conducted in accordance with the 

manufacturer's auidance as stated in the user/maintenance manuals. Paragon will 

maintain logs of pre- and post-flight inspections. In the event maintena.nce is required, the 

PIC will verify the UAS is in an airworthy status prior to operational use. 

All inspection a.nd maintenance will be documented and maintained in-house. These 

actions will meet the intent of the reaulation exemption is beine ,requested and lead to the 

equivalent level of safety. 

3500 N. Rock Rd. Bldg 800, Suite B• Wichita, KS 67226 

(316) 636-5552 • FAX (316) 636-5572