## Cal Poly Pomona Foundation

Unmanned Aerial Systems (UAS) Operations Manual

December 1, 2015

## Table of Contents

1. Introduction Applicability Document Control Abbreviations and Definitions Description of UAS Operations Description of Roles and Responsibilities Area s of Operation Operating Limitations and Conditions Supervision of UAS Operations Flight Safety & Accident Prevention Qualification Requirements for Selected Roles Logs and Records 2. Operating Procedures Flight planning and preparati on Operating s ite and assessment Communications Pre
- notification of interested parties Weather Preparation and Serviceability of UAS 3. On
- site Procedures and Preflight Checks Site Survey Crew briefing Communications Weather Refueling / recharging Loading of equipment Preflight checks on UAS 4. Flight Procedures Start Take

- off In
- flight Landing Shutdown5. Emergency Procedures

Fire Accidents Lost communications or lost power procedures
6. Appendi x (A) FAA 333 Exemption (B) Letter of Agreement with Brackett Field ATC (C) MOU with Cal Poly Pomona (D) List of Approved UAS (E) Contact Information for Interested Parties (F) Google Maps of Operating Areas (G) Operating Manuals for all UAS

### Introduction

This UAS Operation Manual has been created to provide the framework for which UAS operations may be conducted on campus at Cal Poly Pomona through an approved FAA 333 Exemption for Cal Poly Pomona Foundation. This Manual is intended to address typical flight operations expected by Unmanned Aerial Systems (UAS) although it is not a substitute for using sound judgment toward ensuring the safe operation of any aircraft, and in all cases the safety of people and property must remain at the forefront of any decision related to any and all aircraft operations. The airspace in which these UAS operations will occur is within Class D Airspace and under the direct authority of air traffic control at LaVerne Airport (Brackett Field). Therefore, all UAS operations under the Foundation’s FAA 333 Exemption require direct involvement and advance a pproval by the authorities at Brackett Field. Applicability
. All procedures listed within this UAS Operations Manual apply to any person conducting UAS operation’s through Foundation’s FAA 333 Exemption. This UAS Operations Manual is required to be read b y the PIC and any other appropriate party prior to commencing UAS operations while using Foundation’s FAA 333 Exemption , and the guidelines herein are expected to be followed
.Document Control
.

All changes to this UAS Operations Manual will be tracked and recorded using numerical reference and date as indicated by the table below . A description of the changes are preferred but not required. Change # Effective Date Description of Changes N/A December 1, 2015 Newly Published ManualAbbreviations and D efinitions
.

The following abbreviations are used throughout this manual and have the indicated meaning
. AGL Above Ground Level ATC Air Traffic Control AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation IMC Instrument Meteorological Conditions LOA Letter of Agreement LOL Loss of Link MSL Mean Sea Level NAS National Airspace System NOAA National Oceanic and At mospheric Administration NOTAM Notice to Airmen PIC Pilot in Command Section 333 FAA Modernization and Reform Act of 2012, Section 333 UA V Unmanned Aircraft Vehicle UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Sight VMC Visual Meteorological Conditions VO Visual ObserverDescription of UAS Operations
.

1. The UAS operations required for coursework ARO 101 are intended to give the student enrolled in that course an opportunity to build a small UAV to be flown by a qualified PI C . This activity

is intended to expose students to aircraft structures, flight controls, flight testing, experimental procedures, and report writing based on measurements taken during flight
. The program is an intro ductory course and serves to illustrate the aeronautical concepts learned during class room instruction and related lab
. To that end, the specific UAS operations will allow the PI C to fl y the student(s) UAV within the respective Area of Operation , up to 200ft AGL, as further outlined and specific in the applicable LOA (see Appendix B). 2. The UAS operations required for coursework offered through C ontinuing Education University are intended to give the student enrolled in that course an opportunity to fly an off

- the

- shelf ready

to fl y small UAV for a short period of time as an introduction to UAV flight while under the authority of an experienced PI C
. This activity

is intended to allow the students to gain exposure to flying UAV , aircraft structures, flight controls, flight testing, experimental procedures, report writing , and a basic understanding of videography from a UAV
. PI C will be an experienced pilot with the associated UAV and when an inexperienced pilot operates any UAV, it will only be permitted wh en an experienced PIC is directl y supervising and in within immediate proximity of the inexperienced PIC, and therefore the PI C will be capable of taking immediate control of the flight, if needed. Th is program serves to provide the student with basic ski lls in flying UAV while operating within and adhering to standard FAA restrictions applicable to all flight within controlled airspace
. Description of Roles and Responsibilities
. 1. PI C . The PIC is the pilot fully responsible for all UAS operations for the UAV under their control . The PIC is wholly and solel y responsible for knowing, understanding, and complying with any and all applicable FAA regulations, all conditions and restrictions found in the LOA and/or the MOU. The PI C must review this UAS Operations Manual in its entirety prior to any flight. The PI C must review the L OA and MOU prior to flight, and take any action necessary to ensure all conditions and restrictions have been met , prior to flight. Specific instructions by the PIC must be followed before commencing any flight, such as advance notification to Brackett Field for flight operations, as well as coordination with the appropriatecampus departments, such as University Police Department, Risk Management, Athletics

Department, and others who could be impacted by any flight operations. The PI C is responsible for ensuring the safety of their respective flight. This safety applies to any

person or any property which could be subject to injury by actions of the flight, whether accidental or otherwise. The PI C is the final decision maker on their flight, and solely responsible for a safe flight. It is important to know the PI C can be held legall y and financiall y responsible in the event of an accident while conducting any flight. The PI C shall communicate with Brackett Field immediately prior to commencement of flight operations on each day , and immediatel y after the cessation of flight operations for each day , and as otherwise directed within the L OA
. Brackett Field can be contacted at 909
- 593
- 1395. The PI C will ensure avoidance of all other aircraft, and will ensure their UAV remains at or below 200 AGL b y visual means, altimeter readings, or both. The PI C is responsible for ensuring instant commun ications with their VO (s) during each flight. The PI C will ensure all person s not directl y involved in the flight operations remain clear of the area of flight operations. The PI C must ensure all operations are conducted during published daylight hours (from an official government agency such as NOAA) , and only during VMC. Local weather can be obtained b y contacting Brackett Field at 909

- 593
- 1395, or recorded weather b y contacting one of the following airports: Ontario Airport at 909

- 937
- 2186 Chino Ai rport at 909
- 393
- 5823 Corona Airport at 951

- 340
- 4764 Fullerton Airport at 714

- 870
- 1372 2. VO . The VO is responsible to the PI C for ensuring the UAV is remaining within the parameters of the established flight plan. The VO will ensure pedestrians who may be nearby

remain safely

clear of the flight operations area at all times. In cases where persons or vehicles approach too close to theflight operations area to ensure safety , VO will immediately inform the PI C so the PI C can cease flight operations until i t is safe to resume operations. 3. Brackett Field . Brackett Field is the local FAA controlling agency of the airspace directly above the campus from the surface up to 2700ft MSL . As such, all flight operations must be approved by the tower at Brackett Field in advance of the flight operation. In its sole discretion, Brackett Field will determine if it is necessary to create and publish NOTAM’s, and will also determine when it i s necessary to advise other aircraft in the local area of UAV operations on campus. 4. Cal Poly

Pomona
. All UAV operations must be approved in advance b y the appropriate campus department s who have an interest in ensuring safety of all people on campus. C ommon departments include Campus Police Department, Risk Management, Academic Affairs, Administrative Affairs, and the Athletics department when ever using a space designed for their use. 5. Foundation . Foundation management must be notified at least 5 busin ess day s in advance of all planned flight operations. Since Foundation is the holder of the FAA 333 Exemption, the underlying responsibility for compliance with that FAA Exemption is within Foundation.
Area s of Operation
. 1. “Area 1” is the Kellogg Track & Field
. Due to its size and close proximity to other campus venues, Area 1 is primarily intended for use by

the Aeronautical Engineering students as part of their class project. Bordered on the east by trees, on the west by

the spectator stands, on the so uth by a parking lot, and on the north by trees which separate the Kellogg Track from the baseball field. 2. “Area 2” is the farming area adjacent to the Farm Store and related buildings
. Area 2 is intended for use b y the Aeronautical Engineering students or CEU class as part of their class project, or fly

day for CEU students. Bordered on the south and west by hill s , on the north by

a hill and by farm buildings, and on the east b y farm buildings. 3. “Area 3” is Spadra Ranch
. Area 3 is bordered on the north by buildings, on the east by a railroad track which separates Area 3 from Area 4 , bordered on the south by commercial buildings, and bordered on the west b y a public street. 4. “Area 4” is Campus South. The main portion of Area 4 is bordered on the west by the railroad tracks and then immediately by Area 3, on the north by

commercial buildings, on the east b y Freeway 57, and on the south by uninhabited residential property
.Operating Limitations and Conditions
.

UAV operations shall be conducted onl y during daylight hours and onl y when the local weather is VMC. Daylight hours are defined as the time between the published time of sunrise and sunset on a daily

basis. Supervision of UAS Operations All UAV operations will be supervised by the Dean of the college requesting to conduct flight operations. The Dean of the respective college may delegate this responsibility to faculty or other appropriate staff. Flight Safety

& Accident Prevention Flight safety is paramount for any flight o peration. While the PI C is responsible for ensuring safety of flight issues, the assigned supervisor (i.e.: Dean of the college) of the UAS operation shall also share in the overall responsibility of ensuring safe UAV operations. While one cannot possible foresee all possible safety issues, several key

issues and actions are presented below. The general safety precautions are highlighted:
a. The PI C shall ensure only those directl y involved in flight operations will be within 200 feet of the UAV operations. The PI C must ensure all other parties remain well clear of flight operations and in all cases shall be beyond 200ft from UAV operations
. b. When conducting UAV operations, at least one VO is required for UAV operations on campus. A VO will assist with keeping those people not directly involved in the UAV operations at a safe distance. c. An inexperienced pilot shall not operate a UAV unless under the direct guidance of an experienced pilot. d. O SHA rated Helmets should be considered when conducting UAV operations. The Academ y of Model Aeronautics has adopted a National Safety Code for radio controlled aircraft. This UAS Operations Manual has taken that code and modified it to fit our environment , as outlined below
. 1. UAV’s shall not be flown: (a) In a careless or reckless manner. (b) At a location where UAV operations have not been specifically authorized
. 2. UAV pilots (PI C) shall : (a) Yield the right of way to all human

- carrying aircraft. (b) See and avoid all aircraft and a VO’s must be used. (c) F ly no higher than 2 00 feet above ground level within three (3) miles of an airport. (d) Not interfere with operations and traffic patterns at any airport, heliport or seaplane base except where there is a mixed use agreement.(e) Not exceed a takeoff weight, including fuel
.

(f) Ensure the UAV is identified with the name and address of the owner on the inside or affixed to the outside of the model aircraft. (g) Not operate UAV’s with metal

- blade p ropellers or with gaseous boosts. (h) Not operate UAV’s while under the influence of alcohol or while using any drug that could adversely

affect the pilot’s ability

to safel y control the aircraft
. (i) Not operate UAV’s carrying py rotechnic devices that exp lode or burn, or any device which propels a projectile or drops any object that creates a hazard to persons or property. (j) Not operate a turbine

- powered aircraft
. (k) Retain VLOS with the UAV at all times without visual assistance (except prescription eyewear). 3. PI C’s shall avoid fl yi ng directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others. 4. A successful radio equipment ground

- range check in accordance with manufacturer’s recommendations will be completed before the first flight of a new or repaired aircraft. 5
. Safety s igns should be established in front of which all flying takes place. (a) Onl y personnel associated with flying the model aircraft are allowed at or in front of the safety signs
. (b ) An area away

from the safety signs must be maintained for spectators. ( c ) Intentional flying behind the safety signs is prohibited. 6
. UAV’s must use the radio

- control frequencies currentl y allowed b y the Federal C ommunications Commission (FCC). Only individuals properl y licensed by the FCC are authorized to operate equipment on Amateur Band frequencies. 7
. Under no circumstances may a pilot or other person touch a UAV in flight while it is still under power, except to divert it from striking an individual. 8
. The fl yi ng area must be clear of all utility wires or poles and a UAV will not be flown closer than 50 feet to any above

- ground electric utility lines. 10 . The fl yi ng area must be clear of all nonessential participants and spectators before the engine is started. The l aunch area must be clear of all individuals except mechanics, officials, and other fliers. 11 . The PI C shall m aintain control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses prescribed for the pilot.**General S**  **afety practices.**

• Never attempt to retrieve a UAV from electric power lines. Contact the local power company
. • Refrain from using repaired propellers and rotor blades or those that are cracked, nicked, or unbalanced. • Stay clear of the propeller arc while starting or running any engine or motor. • Avoid stopping engines by throwing rags or other objects in the propeller. • Refrain from using a pointed spinner, propeller fasteners, or knife edge s on leading edges. • Paint tips of propellers a bright color to better define the arc of propeller rotation. • Check the propeller and spinner for tightness before each operation. • L earn and check for the proper grain patterns in wooden propellers to ensure strength in high

rpm operation. • Exercise extreme caution in adjusting needle valve settings on engines. Most adjustments should be performed from behind the model, thus avoiding reaching around a spinning propeller. • Ensure that ballast or heav y parts are not subject to loosening or jettisoning in flight. • For Radio Control, perform a range check before each fl yi ng session and a check of flight functions before each flight. • Carefull y read and use the manufacturer’s recommendations for its products. • All model liquid fuels need to be stored and handled properl y. In particular, gasoline should only be stored, transported, and dispensed from a specificall y designed and approved container. When handling fuels near model s, there should be no smoking. Avoid hooking up any starter, pump, or battery that may produce arcing in the immediate area where fuel is located. **Lithium Battery Fires** Lithium batteries have become extremely popular for powering control and power s ys tem s in models because of their high energy density (capacity/weight ratio) compared to Ni

- C a ds or other batteries. With high energy comes increased risk in their use. The principle risk is fire , which can result from improper charging, crash damage, or shorting the batteries. All Lithium

- battery

vendors warn customers of this danger and recommend extreme caution in their use. However, many fires have resulted from the misuse of Li

- Po batteries, leading to the loss of models and automobiles. Other property , s uch as homes, garages, and workshops, have also burned. A Lithium

- battery fire burns explosively

at several thousand degrees and is an excellent initiator for ancillary fires. Fire is caused by contact between Lithium and oxygen in the air. **It needs no other**  **source of ignition, or fuel, to start.** The following is recommended for Lithium batteries to preclude ancillary fires: • Store and charge in a fi reproof container

— never in your model. • Charge in a protected area that is devoid of combustibles. • Inthe event of damage from crashes, etc., carefully move the battery

pack to a safe place for at least a half hour to observe. Phy sically damaged cells can erupt into flames. After sufficient time to ensure safety, the cells should be discarded in accordance with the instructions that come with the batteries.**Never attempt to charge a cell with physical damage,**  regardless of how slight.

• Alway s use chargers designed for the **specific** purpose; it’s preferable to have a fixed setting for your particular p ack. Many fires occur while using selectable/adjustable chargers that are set improperly . Never attempt to charge Lithium cells with a charger that is not specificall y designed for Lithium cells! **Never use chargers that are specifically designed for Ni**  **- C**  **a d**  **batteries.** • It is strongl y recommended that you use charging s ys tems that monitor, control, and balance the charge state of each cell in the pack. Unbalanced cells can lead to disaster if the s ys tem permits a single cell in the pack to be overcharged. This means that the charging s ys tem must provide charge cessation as each cell reaches the proper voltage. If the batteries show **any sign of swelling,**  discontinue charging **and move them to a safe place**

**— outside.**  **They could erupt into flames.** 
• **Never plug in a battery and leave it to charge unattended;**  serious fires have resulted from this practice. • Do not attempt to make your own battery packs from individual cells. Use only professionally packaged and labeled units which contain safer charging features. Qualification Requirements for Selected Roles 1. PI C. The PIC must be experienced fl yi ng the specific ty pe of UAV under consideration for UAV operations. While there is no specific test or level of experience in which a PI C becomes “ fully qualified ” to fly a given UAV , generall y, a PIC will have adequate ability to control the flight with enough accuracy and skill to ensure safety of flight at all time, including during pre - flight, start - up, take

- off, enroute flight, return to landing , and shut down, without the need of assistance. 2. The PI C must have a basic understanding of FAA airspace and be familiar with common FAA regulations related to piloting aircraft. 3. The PI C must know the difference between IMC and VMC, and be able to apply VFR during VMC. 4. Valid Bronco ID card or valid California driver’s license is required to be a PI C or VO while on campus. 5. VO. The VO must be able to see the UAV and have instant communications with the PI C during the full time the UAV is airborne. 6. The VO shall n ot be engaged in any other tasks while operating as the VO.Lo gs and Records

1. Each UAV shall have a flight log book. All UAV flights operating under the Foundation’s FAA 333 Exemption shall be logged in its respective UAV flight log book. The information contained in the UAV flight log book shall include the printed name of the PI C, the printed name of all VO’s for a given flight , the starting time and ending time of each flight, the date of the flight, and the printed name of the supervisor re sponsible for oversight of the flight operations. 2. The UAV flight log book shall be available on

- site during any flight. UAV operations are not permitted unless the PI C has the UAV flight log book in their possession during the flight operations. 3. All records related to the UAV flight shall be maintained and made available to appropriate authorities upon request. Common records could include maintenance or repair records.Flight planning and preparation

All UAV flight operations require advance planning and adequate preparation. Common planning tasks include: a. obtaining an aviation weather forecast for the flight day from the local airport b. ascertaining the times for sunrise and sunset c. coordinating with appropriate campus departments prior to flight day to ensure there are no scheduling conflicts for use of airspace , and to ensure all concerned parties are aware of flight operations (such as Campus Police, Risk Management, etc.) d. contacting air traffic control at Brackett Field at least 5 bu siness days prior to any planned flight, and before UAV operations commence on the day of flight, and again after flight operations conclude for the day e. reviewing the NOTAM’s at Brackett Field to ensure no civilian air traffic is planned to be in the assigned UAV flight operations Area. f. briefing the VO’s to ensure they understand their role g. obtaining the necessary Safety Signs h. other tasks not specific ally identified Operating site and assessment

a. identify one or more take

- off and landing zones on

- site that are safe for use b. scan the operating site for obstacle s that would cause unsafe flight operations , and remove obstacles, or fly at another site c. ensure the site selected (i.e.: Area 1 , 2, 3, or 4 ) is not in use by others Communications C ontact air traffic control at Brackett Field at least 5 business days prior to any planned flight, and before UAV operations commence on the day of flight, and again after flight operations conclude for the day
. Additionally:

a. verify frequency checks with Brackett Field (as required) b. establish and verify communications with Brackett Field (as required) c. test communications with VO’s while on

- sitePre
- notification of interested parties

Coordinate with appropriate campus departments prior to flight day to ensure there are no scheduling conflicts for use of airspace, and to ensure all concerned parties are aware of flight operations (such as Campus Police, Risk Management, etc.) C ontact air traffic control at Brackett Field at least 5 business days prior to any planned flight, and before UAV operations commence on the day of flight, and again after flight operations conclude for the day . Ensure Brackett Field has posted the necessary NOTAM regarding UAV operations. Weather Contact the weather service a t one of the local airports and obtain an aviation weather forecast prior to commencing flight operations. Obtaining a weather forecast 24 hours prior to the planned flight operation is usually acceptable when including an update on the day of flight oper ations. Preparation and Serviceability of UAS Following the UAV operating manual to determine the required preparation of the UAV and radio controls prior to flight. Conduct a pre

- flight inspection of the UAV per the respective operating manual prior to conducting flight operations. Flight Procedures The below flight procedures are intended to provide a framework for which to operate. Deviations to these procedures may be permitted by an experienced PIC.

a. Start. Starting the UAV per the operating manual with a special emphasis on safety. Whether the UAV is a fixed wing or rotorcraft, blades can cause substantial injury to the human body, and can even cause death. Care must be taken when starting any UAV to ensure safety of the PIC and anyone else who is nearby. b. Take

- off. Generally, fixed

- wing UAV’s will take off into the wind while rotorcraft may have other options for take

- off . Specific take

- off procedures may b e found in the related UAV operators manual. Before initiating tak e - off, ensure the full range of the take

- off area is clear of all obstructions.5. In
- flight . In
- flight operations involve controlling the UAV to an expected flight pattern.

The PIC shall av oid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others. c. Landing . As with the take

- off phase of flight, landing for fixed

- wing UAV should normally occur when the UAV is facin g into the wind , where landing for rotorcraft may have other options
. d. Shutdown . Shutdown procedures may be found in the related UAV operators manual , and typically occur immediately upon touchdown
. Emergency Procedures
**a.** Fire. Whenever conducting UAV flig ht operations it is recommended to have standard and readily available fire suppressant equipment on

- site, such as a fire extinguisher. **Lithium Battery Fires . These fires are extremely difficult to extinguish and fire**  **extinguishers for these fires are not commonly available. Therefore, taking**  **precautions to avoid such a fire is the best measure. However, if your UAV catches fire and the fire is associated with a Lithium battery, CONTACT THE FIRE DEPARTMENT**  **IMMEDIATELY .**  All Lithium

- battery vendors war n customers of this danger and recommend extreme caution in their use. However, many fires have resulted from the misuse of Li

- Po batteries, leading to the loss of UAVs . A Lithium

- battery fire burns explosively at several thousand degrees and is an excelle nt initiator for ancillary fires. Fire is caused by contact between Lithium and oxygen in the air. **It needs no other source of ignition, or fuel, to start.** b. The following is recommended for Lithium batteries to preclude ancillary fires: • Store and charge in a fireproof container
— never in your UAV
. • Charge in a protected area that is devoid of combustibles. • In the event of damage from crashes, etc., carefully move the battery pack to a safe place for at least a half hour to observe. Ph ysically damaged cells can erupt into flames. After sufficient time to ensure safety, the cells should be discarded in accordance with the instructions that come with the batteries. **Never attempt to charge a cell with physical damage,** regardless of how s light. • Always use chargers designed for the **specific** purpose; it’s preferable to have a fixed setting for your particular pack. Many fires occur while using selectable/adjustable chargers that are set improperly. Never attempt to charge Lithium cells wi th a charger that is not specifically designed for Lithium cells!**Never use chargers that are specifically designed for Ni -**  **Cad batteries.**

• It is strongly recommended that you use charging systems that monitor, control, and balance the charge state of ea ch cell in the pack. Unbalanced cells can lead to disaster if the system permits a single cell in the pack to be overcharged. This means that the charging system must provide charge cessation as each cell reaches the proper voltage. If the batteries show **a ny sign of swelling,**  discontinue charging **and move them to a safe place**  **- outside. They could erupt into flames.** 
• **Never plug in a battery and leave it to charge unattended;** serious fires have resulted from this practice. • Do not attempt to make your own battery packs from individual cells. Use only professionally packaged and labeled units which contain safer charging features.

c. Fires which are not related to batteries. Use the standard fire extinguisher to douse the fire. Contact the fire department as needed. d. Report the fire to the campus police department, the Risk Management Office, and to the UAV Operations Coordinator at Foundation. Accidents While minor accidents that involve only the UAV do not need to be reported, any accident whe re any person sustains an injury, or where any damage to property occurs, is required to be reported to the appropriate parties on campus, such as Risk Management, campus police, the UAV Operations Coordinator at Foundation, and air traffic control at Bra ckett Field. A report shall be submitted no later than 24 hours from the time of the incident with all of the known details, such as the name of the PIC, the parties injured, the disposition of injuries, etc.

Lost link procedures Procedures for what actions the UAV will take during a lost link situation will usually be found in the UAV operators manual. However, in the absence of a specific protocol in such manual, all UAS configurations shall be programmed to require the UAV to r eturn to the starting point of the flight in the event of a lost link, or lost power.Appendi x

(A) FAA 333 Exemption (B) Letter of Agreement with Brackett Field ATC (C) MOU with Cal Poly Pomona (D) List of Approved UAS (E) Contact Information for Interested Parties (F) Google Maps of 4 Operating Areas (G) Operating Manuals for all UA SAppendix D List of Approved UAS DJI Phantom II / III 3DR X8+ Sig Kadet Senior
Appendix E Contact Information for Interested Parties Ontario Airport at 909

- 937
- 2186 Chino Airport at 909
- 393
- 5823 Corona Airport at 951

- 340
- 4764 Fullerton Airport at 714

- 870
- 1372 Campus Police / Fire 909

- 869
- 3070 Foundation 909

- 869
- 2958