Thomas W. Copeland

Copeland Aerial Photography, LLC. 1029 Copper Palm Ct Henderson, NV 89002 (p) (702) 723

- 7425 (e) copeland. aerial.photography@gmail.com

January 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 FAA Reform Act and Title 14, Code of Federal Regulations (14CFR): §§ 21 subpart H; 45.23(b); 61.113 (a) and (b); 91.7(a); 91.9(b)(2); 91.103; 91.109; 91.119; 9 1.121; 91.151(b ); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)( 1) and (2); and 91.417(a) and (b).

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“the FMRA”) and 14 CFR Part 11
, Copeland Aerial Photog raphy, LLC. (referred to herein as “applicant”), operator of small Unmanned Aircraft Systems (sUAS), hereby applies for an exemption from the listed Federal Aviation Regulations to allow commercial operation of its sUAS, so long as such operations are cond ucted within and under the conditions stipulated herein or as may be established by the FAA as required by Section 333.

Commercial operation of sUAS, as described herein, which are equipped with cameras and sensors, would operate in the following manner:

Aerial photography and/or video for public and/or private use including real estate, architectu re, land surveying, agriculture, engineering, closed set television and motion picture filming, p ublic events
, residential/commercial structures
, and providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster.

As described below, the requested exemption would permit the operation of sUAS under controlled conditions in the NAS that would be a) limited b) co ntrolled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (t he FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.”The name, address, phone, and email of the applicant:

Thomas W. Copeland Copeland Aerial Photography
, LLC. 1029 Copper Palm Ct Henderson, NV 89002 (801) 913

- 8017 copeland.thomas@gmail.com

Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23(b) 14 CFR 61.113(a) 14 CFR 91.7 (a) 14 CFR 91.9(b)(2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151(b) 14 CFR 91.203(a) and (b) 14 CFR 91.405(a) 14 CFR 91.407(a)(1) 14 CFR 91.409(a)(1) and (2) 14 CFR 91.417(a) and (b)

The sUASs the applicant will be using are multi

- rotor craft weighing no more than 55 lbs including payload. Under normal conditions, they operate at speeds of no more than 45 mph or 39 knots and have the ability to hover and move along a vertical and horizontal plane simultaneously. They will be o perated in visual line of sight only and in accordance with all other local and federal laws.

Given the small size of the sUAS and the controlled environment provided, the proposed operations will adhere to the Reform Act’s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly, the applicant requests that the FAA grant the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft.These limitations and conditions to which the applicant agrees to adhere to when

conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1) The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeed s greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 2) The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 3) The UA must be operated within vis ual line of sight (VLOS) of the 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. 4) All operat ions must utilize a visual observer (VO). The UA 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 flight and cannot transfer his or her designation for the duration of the flight. The PIC mu st ensure that the VO can perform the duties required of the VO. 5) The exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in the grant of exemption, are hereinafter refer red to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the exemption and the procedures out lined in the operating documents, the conditions and limitations of the exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operati ng 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 petiti ons for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for an amendment to its grant of exemption. T he FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents. 6) Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., re placement of a flight critical component, must undergo a functional test flight prior to conducting further operations underthis exemption. Functional test flights may only be conducted by a PIC with a VO and

must remain at least 500 feet from other peopl e. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 7) The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 8) Prior t o each flight, the PIC must conduct a pre

-flight inspection and determine the UAS is in a condition for safe flight. The pre

-flight 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 flight. 9) The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 10) Each UAS operated under the exemption must comply with all manufacturer safety bulletins. 11) Under t he grant of exemption, a 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 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 flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 12) The operator may not permit any PIC to opera te unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicl es and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining t he PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption are p ermitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. D uring training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 13) UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 14) The UA may not operate with in 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, unl ess a letter of agreement with that airport’smanagement 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 offi cial upon request. 15) The UA 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. 16) For tethered UAS operations, the tether line must have colored pennants or streamers attached at not more than 50 foot intervals beginning at 150 feet above the surface of the earth and visible from at least one mile. This requirement for pennants or streamers is not applicable when operating exclusively below the top of and within 250 feet of any structure, so long as the UA operation does not obscure the lighting of the structure. 17) If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property. 18) The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 19) The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA 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 Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the enclosed COA. 21) All aircraft operated in accordance with the exemption must 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. 22) Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 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 UA must remain clear and give way to all mann ed aviation operations and activities at all times. 24) The UAS may not be operated by the PIC from any moving device or vehicle. 25) All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures u nless: a) Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 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 and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b) The owner/controller of any vessels, vehicles or structures h as granted permission for operating closer to those objects and the PIC has made a safetyassessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. c) The PIC, VO, operator trainees or essential pers ons 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 from property ow ner/controller or authorized representative will be obtained for each flight 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

. 28) For the purpose of closed

- set motion pictu re and television filming and production, the operator must have a motion picture and television operations manual (MPTOM) as documented in the grant of exemption. 29) At least 3 days before aerial filming, the operator of the UAS affected by the exemption mu st submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at l east the following: a) Dates and times for all flights; b) Name and phone number of the operator for the UAS aerial filming conducted under the grant of exemption; c) Name and phone number of the person responsible for the on

- scene operation of the UAS; d) Make, m odel, and serial or N −Number of UAS to be used; e) Name and certificate number of UAS PICs involved in the aerial filming; f) A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g) Signature of exemption holder or representative; and h) A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation. 30) Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in the grant of exemption, the UAS, the UAS PIC, and the UAS operations must comp ly with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

**14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR 91.203(a)(1)**Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements

for the issuance of airworthiness certificates as required by FAR 91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the applicant, an exemption from Part 21 Subpart H meets the requirement s of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U .S.C. 44701 (f)) and Section 33 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certi ficate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed

.
The sUAS to be operated here under is less than 55 pounds fully loaded, carries neither a pilot nor passenger, carries no explosive materials or fla mmable liqui d fuels, and operates exclusively within a secured and designated area. Unlike other civil ai rcraft, operations under this exemption will be tightly controlled and monito red by both the operator and und er the requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree of safety to the
pu blic and property owners than con ventional operations conducted with airworthiness certificates issu ed under 14 CFR Part 21, Subpart H. Lastly, applic ation of these same criteria demonstrates that there is no credible threat to national security posed by t he sUAS, due to its size, speed of operation, location of operation, lack of explosive
mat erials or flammable liquid fuels, and inability to carry a substantial external load.

**14 CFR 45.23 (b) Marking of the Aircraft**

The regulation requires: When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificat e d aircraft, the operator must also display on that aircraft near each en trance to the cabin, cockpit, or pilot station, in letters not less than 2 inches not more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.

Even though the sUAS will have no airworthine ss certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAS, two

- inch lettering will be impossible. All aircraft will have identification (N −Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

**14 CFR 61.113(a) Private Pilot Privileges and Limitations: Pilot in Command**Pursuant to 14 CFR 61.113(a), no person who holds a pri vate pilot certificate may act as

a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. Our sUASs do not carry any pilots or passengers nor property therefore the applicant seeks an exemption to 14 CFR 61.113( a). The risks attendant to the operation of sUAS is far less than the risk levels inherent in the commercial activit i es outlined in 14 CFR 61. I feel the operation and limitations sets forth in the FOM will equate to the safe operation of the sUAS.

**14 CFR 91.7(a) Civil Aircraft Airworthiness** 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be provided.

**14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in the Aircraft** 

Section 91.9(b)(2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by Section 21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it.

**14 CFR 91.103 Preflight Action**

This regulation requires each pilot in command to take certain actions before flight to ensure the safety of flight . As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The operator will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performan ce data before initiation of flight.

**14 CFR 91.109 Flight Instruction**

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. Small UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has a pproved exemptions for flight training wit h out fully functional dual controls for anumber of aircraft and for flight instruction in experimental aircraft . The equivalent level

of safety is provided by the fact that neither a pilot nor passengers will be c arried in the aircraft and by the size and speed of the aircraft.

**14 CFR 91.119 Minimum Safe Altitudes**

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows helicopters to be operated at less than the minimu ms prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 feet AGL, an exemption may be needed to allow such operations. As set forth herein , the sUAS will never operate at higher than 400 feet AGL with out a COA specifically authorizing an altitude above 400 feet AGL. The equivalent level of safety will be achieved given the size, weight and speed of the sUAS as well as the location where it is operated. In addition, the low

- altitude operations of the sUAS will ensure separation between these sUAS operations and the ope rations of conventional aircraft that must comply with Section 91.119.

**14 CFR 91.121 Altimeter Settings**

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before each flight.

**14 CFR 91.151 (b)**  **Fuel Requirements for Flight in VFR Conditions**

Section 91.1 51(b) requires rotorcraft pilots to plan at least a 20 minute fuel reserve. The battery powering the sUAS provides approximately 20 to 23 minutes of flight. To meet the reserve requirement in 14 CFR 91.151(b), sUAS flights would be limited to less than 3 minutes. Given the limitations on the sUAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in VFR conditions is reasonable. The applicant believes that an exemption from 14 CFR 91.151(b) falls within the scope of prior exemptions. Operating the sUAS in a tightly controlled area with less than 20 minutes of reserve fuel does not engender the type of risks that Section 91.151(b) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights to 3 mintues would geatly reduce the utility for which the exemption will be granted. The applicant believes that an equivalent level of safety can be achieved by prohibiting the PIC from beginning a fli ght unless (considering wind and forecast weather conditions) there is enough available power forthe sUAS 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 great er.
**14 CFR 91.203(a) and (b) Carrying Civil Aircraft Certification and Registration**

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operated a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or

crew.

The sUAS fully loaded weighs no more than 55 pounds and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS wil l have immediate access to them, to the extent they are applicable to the sUAS.

**14 CFR 91.405(a) ; 407(a)(1); 409(a)(2); 417(a) and (b) Maintenance Inspections** 

These regulations require that an aircraft operator or owner “shall have that 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...,” and others shall inspect or maintain the aircraft in compliance with Par 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because these sUASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise, the sUAS can land i mmediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is t he person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the sUAS Manufacturer’s Manual, as referenced in the Aircraft Operations Manual (AOM). As provided in the FOM, the operator will ens u rethat the sUAS is in working order prior to initiating flight and perform re q ui red

maintenance needed.

**Small UAS information**

sUAS’s to be used are as follows but not limited to providing they are within the scope of the exemption granted by the FAA:

1. DJI Phantom 3 Advanced (P3A) https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Advanced_User_Manual __V1.6.pdf

2. DJI Phantom 3 Pro (P3P) https: //dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manu al__V1.6.pdf

3. DJI Phantom 3 4K https://dl.djicdn.com/downloads/phantom_3_4k/en/Phantom_3_4K_User_Manual_V1. 0_en.pdf

4. DJI Inspire 1 https://dl.djicdn.com/downloads/inspire_1/en/Inspi re_1_User_Manual_en_v2.0_1218. pdf

5. DJI Inspire 1 Pro/Raw http://dl.djicdn.com/downloads/inspire_1_pro/en/Inspire_1_Pro_User_Manual_en_v1. 0_1201.pdf

6. DJI Spreading Wings S1000+ http://dl.djicdn.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf

7. DJI Spreading Wings S900 http://dl.djicdn.com/downloads/s900/en/S900_User_Manual_v1.2_en.pdf

8. DJI Matrice 100 http://download.dji

innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.4__en.pdf

9. 3DR SOLO https://3drobotics.com/wp

- content/uploads/2015/11/v8_11_20_15.pdf

10. 3DR IRIS https://3drobotics.com/wp

- content/uploads/2014/04/IRI S

- Operation

- Manual

-v6.pdf11. 3DR X8

- M

https://3drobotics.com/wp

- content/uploads/2014/10/X8M

- Operation

- Manual

-v1.pdf