Edge Runner Communications Inc.

September 25, 2015

Brett Sargent

480 Cledell St.

Oregon, WI 53575

brettsargent@icloud.com

Petition of Edge Runner Communications Inc.

For Exemption Pursuant to Section 333

Of the FAA Modernization and Reform Act of 2012

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 

14 CFR Part 11, Edge Runner Communications Inc. (ERC), hereby applies for an 

exemption from Federal Aviation Regulations (FARs) identified below, to allow 

commercial operations of small unmanned aerial systems (i.e., sUAS). unmanned aerial 

systems (i.e., sUAS).

This exemption is in accordance with protocols outlined in this petition for 

exemption, and any other requirements established by the FAA pursuant to Section 333 

of the Reform Act.

This exemption would permit commercial operation by ERC, which uses a DJI 

Phantom 3 sUAS to conduct:

• Aerial surveying

• Event Photography/Videography

• Agriculture purposes

• Real Estate Photography

• Aerial Filmmaking and Photography

• Construction Site Inspections and Monitoring, and

• News Gathering and First Responders.

ERC’s operation under the exemption will be subject to strict operating 

requirements and conditions to ensure an equivalent level of safety to currently 

authorized operations using manned aircraft and under conditions as may be modified 

by the FAA as required by Section 333.

ERC's sUAS will be operated under controlled VFR conditions at low altitudes. 

They will operate the sUAS’s with pilots who have comprehensive UAV / UAS / Drone 

flight training for competency and new FAA 333 and Part 107 commercial compliance 

requirements.
Finally, when required, the FAA ATC will approve the airspace in which the sUAS 

will operate in advance.

Edge Runner Communications Inc. respectfully submits this request for an 

exemption because it operates sUAS's. The FAA can have confidence that the 

operations will be conducted at an equivalent level of safety or greater. Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of Transportation’s 

(the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to 

“establish requirements for the safe operation of such aircraft systems in the national 

airspace system.”

For your convenience, ERC has organized this Exemption request as follows:

I. Petitioner's Description

II. Relevant Statutory Authority

III. Qualifications for Approval Under Section 333 of the Reform Act

IV. Description of Proposed Operations

V. Regulations From Which Exemptions Requested

VI. Public Interest

VII. Privacy

VIII. Federal Registry Summary 

IX. Conclusion

I. Petitioner's Description:

Edge Runner Communications Inc. headquartered in Oregon, WI, is a company 

that provides sUAS support to news and event videography, real estate and 

construction site photography, film and movie production, precision agricultural 

purposes, education, and demonstration flights in a compliant and safe environment. 

ERC plans on providing a wide range of services as the sUAS market expands. ERC's 

goal is to operate in an accident- free environment by:

• Demonstrating a commitment by management and all employees to operate in a 

compliant manner.

• Identifying hazard and risk while eliminating or controlling all these risks.

• Using steps to intervene and report when unsafe work practices appear to exist.

• Training all employees involved in flight operations to operate at the highest standard 

level.

The contact information for Petitioner is as follows:

Edge Runner Communications Inc.

Brett Sargent

480 Cledell St.

Oregon, WI 53575

brettsargent@icloud.com
II. Relevant Statutory Authority:

This petition for exemption is submitted to fulfill Congress' goal in passing 

Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace 

system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to 

consider whether certain unmanned aircraft systems may operate safely in the

National Airspace ("NAS") before completion of the formal UAS rule making, based on 

the following considerations:

 • The UAS's size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within the visual line of sight of the operator.

If the Secretary determines that such vehicles "may operate safely in the National 

Airspace system, the Secretary shall establish requirements for the safe operation of 

such aircraft in the National Airspace System”.

Additionally, the FAA Administrator has general authority to grant exemptions 

from its safety regulations and minimum standards, and has done so on numerous 

occasions, when the Administrator decides a requested exemption is in the public 

interest. A party requesting an exemption must explain the reasons why the exemption: 

(1) would benefit the public as a whole, and (2) would not adversely affect safety (or 

how it would provide a level of safety at least equal to the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as 

the term is defined under 40101 of the Act, from the requirement that all civil aircraft 

must have a current airworthiness certificate and those regulations requiring commercial 

pilots to operate aircraft in commercial service:

The Administrator may grant an exemption from a requirement of a 

regulation prescribed under subsection (a) or (b) of this section or any of 

sections.

III. Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for expedited 

approval under Section 333 of the Reform Act. Each of the statutory criteria and other 

relevant factors are satisfied. The proposed operations would permit ERC the use of 

small UAS under controlled conditions in airspace that is: (1) predetermined; (2) 

controlled as to access; and that (3) provides an increased level of safety beyond that 

existing when fixed or rotor wing aircraft are used to accomplish the same purpose.

ERC uses sUASs that are multi-rotor, weighing less than 50 pounds including 

payload. They operate, under normal conditions, at speeds not to exceed 40 mph and 
have the capability to fly, hover, and move in the vertical and horizontal plane. ERC’s 

sUAS’s will operate in line of sight, during daylight hours, and will only operate within a 

sterile area. ERC will operate at or below 400 feet AGL and will file a NOTAM for each 

flight operated in controlled airspace. All required permissions and permits would be 

obtained from territorial, state, county or city jurisdictions, including local law 

enforcement, fire, or other appropriate governmental agencies prior to operating a 

sUAS.

Given the small size of the sUAS’s involved and the restricted sterile environment 

within which they will operate, ERC’s exemption falls within the zone of safety and 

demonstrates an equivalent level of safety, in which Congress desired the FAA to permit 

commercial UAS operations by exemption pending completion of formal rule making. 

Also, due to the size of the sUAS’s and the confined area in which the sUAS’s will 

operate, approval of the application presents no hazard in the NAS. Considering the 

clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended, the equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, the grant of the requested exemptions is 

also in the public interest.

IV. Depiction of Proposed Operations

To assist the FAA in its safety assessment of ERC's proposed sUAS operations, 

below is a summary of operational limitations and conditions that will ensure an 

equivalent or higher level of safety to operations conducted under current regulatory 

guidelines:

1. The sUAS will weigh less than 50 pounds including payload.

2. Flights will be operated within line of sight of the PIC and observer.

3. Maximum total flight time for each operational flight will be limited to the amount of 

time the sUAS can be flown and still maintain a reserve battery power of no less 

than 25%. 

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Flights will be operated at a lateral distance of least 500 feet from any inhabited 

structures, buildings, vehicles, vessels, people not associated with the operation or 

who have not signed a waiver in advance of the operation.

6. Minimum crew for each operation will consist of the sUAS Pilot in Command and a 

Visual Observer.

7. The sUAS Pilot in Command will hold at least a sport pilot or recreational pilot 

certificate and a valid U.S. driver’s license.

8. ERC will designate a Pilot in Command (PIC) for each mission.

9. The sUAS will operate only within a confined "Sterile Area”.

10. Prior to the operations at a particular location, a site inspection will have been 

conducted. On the day of the mission the management person with operational 

control and the PIC will concur on dispatching of the mission.
11. A briefing will be conducted in regard to the planned sUAS operations prior to each 

day’s missions. It will be mandatory that all personnel who will be performing duties 

within the boundaries of the sterile area be present for this briefing.

12. ERC crew will use the checklist and callouts required in the Operations Manual.

13. All sUAS’s will be maintained in accordance with inspection program specified in the

 manufacturer’s guidelines.

14. In the event of an accident involving an ERC sUAS, they will cease operations and 

report the accident to the NTSB and AFS-80.

15. Pilot in Command and Visual Observer will at all times be able to communicate by 

voice.

16. Pilot in Command, Visual Observer, Camera Operator, and Operational Personnel 

will have been trained and tested in accordance to FAA, NTSB, and AFS-80 best 

practices.

17. All required permissions and permits would be obtained from territorial, state, county 

or city jurisdictions, including local law enforcement, fire or other appropriate 

governmental agencies.

18. ERC management will submit a written “Plan of Activities” to the local Flight 

Standards

 District Office (FSDO) having jurisdiction over the area of proposed filming three 

days in advance of operations during film or movie productions.

19. If the sUAS loses communications signal, the sUAS will have the capability to return 

to a pre-determined location within the Sterile Area and land.

20. Contingency plans will be in place to safely terminate flight if there is a loss of

communication between the pilot and the observer.

21. The sUAS PIC has the capability to abort a flight in case of unpredicted obstacles or 

 emergencies.

22. ERC, by following FAA, NTSB, and AFS-80 best practices, will assure no individuals’ 

 privacy is violated.

23. Procedures have been established in ERC’s Operations Manual to contact ATC prior 

to operating in airspace other than G.

V. Regulations From Which Exemption is Requested

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned 

Aircraft Systems”, provides a mechanism for seeking expedited FAA authorization of 

safe civil UAS operations in the NAS. Section 333(a) states that the FAA “shall 

determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the (comprehensive) plan and rule making 

required by section 332(b)(1) of this Act or the guidance required by section 334 of this 

Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a 

mechanism for “expedited operation authorization” if several factors are met. Petitioner 

meets all requirements to permit FAA approval of commercial UAS operations. The 

Petitioner Requests Relief From the Following:
A. 14 CFR § 91.103: Preflight Action

ERC requests an exemption from the preflight actions requirements of 14 CFR 

91.103 that prescribes the preflight actions under which aircraft may operate: Each pilot 

in command shall, before beginning a flight, become familiar with all available 

information concerning that flight.

a. Flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot 

be completed, and any known traffic delays of which the pilot in command 

has been advised by ATC;

b. For any flight, runway lengths at airports of intended use, and the following 

takeoff and landing distance information:

i. For civil aircraft for which an approved Airplane or Rotorcraft Flight 

Manual containing takeoff and landing distance data is required, the 

takeoff and landing distance data contained therein; and

ii. For civil aircraft other than those specified in paragraph (b)(1) of this 

section, other reliable information appropriate to the aircraft,

 relating to aircraft performance under expected values of airport 

elevation and runway slope, aircraft gross weight, and wind and 

temperature.

ERC will not operate sUAS’s under IFR conditions or when the ceilings are below 

1000 feet and the visibility is below 3 statute miles. ERC’s sUAS’s do not have a 

published approved Airplane or Rotorcraft Flight Manual containing takeoff and landing 

distance data.

Equivalent Level of Safety

In adherence to FAA, NTSB, and AFS-80 best practices, the PIC along with the 

person having operational control must follow regulations to assure that the weather will 

be adequate to complete the mission in VFR condition.

B. 14 CFR 91.113: Right-of-Way Rules

ERC requests an exemption from 14 CFR 91.113 Right-of-way rules, requiring 

vigilance by each person operating an aircraft so as to see and avoid other aircraft. 

When a rule of this section gives another aircraft the right-of-way, the pilot shall give 

way to that aircraft and may not pass over, under, or ahead of it unless well clear.

Edge Runner Communications Inc. operates small pilotless UAS’s and cannot 

comply with these rules as they have been written.

Equivalent Level of Safety
ERC operates sUAS’s at or below an altitude of 200 feet AGL, well below the 

normal operating altitude of other aircraft. ERC management requires that the Pilot in 

Command with experience oversee each mission and has knowledge of the see-andavoid rules. A Visual Observer will assist the PIC in looking for aircraft entering the 

operations area. It’s the responsibility of the PIC to cease operations and land the UAS 

immediately whenever an aircraft comes into the vicinity creating a potential threat. 

Operations will not recommence until the threat is clear.

C. 14 CFR. § 91.119: Minimum Safe Altitudes

ERC requests an exemption from the minimum safe altitude requirements of 14 

CFR 91.119 that prescribes the minimum safe altitudes under which aircraft may 

operate:

• Over any congested area of a city, town, or settlement, or over any open air assembly 

of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal 

radius of 2,000 feet of the aircraft.

• Over other than congested areas at an altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum 

altitudes when it can be operated "without hazard to persons or property on the 

surface," provided that "each person operating the helicopter complies with any routes 

or altitudes specifically prescribed for helicopters by the FAA.”

To provide the intended operations, the sUAS is normally operated below 500 

feet AGL. Additionally, due to the nature of the proposed operations, the sUAS will 

maintain a lateral distance of at least 100 feet from inhabited structures, buildings, 

vehicles, and vessels, and from people not associated with the operation.

Equivalent Level of Safety

Compared to normal aircraft, ERC’s multi-rotor aircraft weigh a maximum of 25 

pounds, and given the lack of flammable fuel, any risk associated with these operations 

is far less than those that presently exist with conventional aircraft. An equivalent level 

of safety will be achieved given the size, weight, and speed of the UAS, as well as the 

location where it is operated. As set forth in the FAA, NTSB, and AFS-80 best practices, 

the sUAS will be operated in a sterile area, where buildings and people will not be 

exposed to operations without their pre-obtained consent. Because of the advance 

notice to the property owners and participants, all affected individuals will be well aware 

of the planned flight operations prior to commencement of operations.
Furthermore, by operating at such lower altitudes, the sUAS will not interfere with 

aircraft that are subject to the minimum safe altitude regulations. Finally, the successful 

safety record of the Phantom 3 sUAS’s demonstrates that the sUAS can be safely used 

at these lower altitudes and closer operating environments.

D. 14 C.F.R. § 91.121: Altimeter Settings

ERC seeks an exemption from 14 CFR 91.121, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an 

altimeter that is set to the elevation of the departure airport or barometric pressure. An 

exemption is required because the sUAS does not have a barometric altimeter, but 

rather a GPS altitude read out.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set 

forth in the FAA, NTSB, and AFS-80 best practices. ERC will confirm the altitude of the 

launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use 

the GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring 

operation at safe altitudes.

E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

ERC requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for 

flight in VFR conditions. Section 91.151 states:

a. No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel

to fly to the first point of intended landing, and assuming normal cruising speed –

i. During the day, to fly after that for at least 25 minutes; or 

ii. At night, to fly after that for at least 45 minutes.

The batteries powering ERC’s Phantom 3 provide approximately 25-30 minutes 

of powered flight. To meet the 30 minutes reserve requirement in 14 CFR 91.151. Given 

the limitations on the sUAS's proposed flight area and the location of its proposed 

operations within a predetermined area, a safety margin based on a reserve amount of 

battery life is needed. ERC will not be conducting any sUAS flights at night.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be 

conducted on-site without significant transit time by the sUAS. All flights will be planned 

to terminate with no less than 25% reserve battery power still available. This restriction 

would be more than adequate to return the sUAS safely to its planned landing zone 

from anywhere in its confined area of operation even in the event of an unexpected 

occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel does not 
include the type of risks that Section 91.151(a) was intended to alleviate given the size 

and speed of the small UAS, and the proximity of the flight operation to the landing 

zone. Moreover, operation will be limited to controlled areas where only people and 

property owners, or official representatives who have signed waivers will be allowed.

F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections

ERC also seeks an exemption from the maintenance inspection requirements 

contained in 14 CFR 91.405(a), 91.407(a) (1), 91.409(a) (2), 91.417(a) and (b). These 

regulations specify maintenance and inspection standards in reference to 14 CFR Part 

43. 14 CFR 91.405(a) (stating that each owner or operator of an aircraft "shall have the 

aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). An 

exemption to these regulations is needed because Part 43 and these sections only 

apply to aircraft with an airworthiness certificate, which the sUAS will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and 

inspections will be performed in accordance with FAA, NTSB, and AFS-80 best 

practices. 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. 

The operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety.

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact 

that flight operations will only take place in restricted areas for limited periods of time 

during daylight hours, creates less risk than that associated with conventional rotorcraft 

or fixed wing aircraft performing the same operation.

VI. PUBLIC INTEREST

Granting Edge Runner Communications Inc. an exemption furthers the public interest in 

and around the states of Wisconsin, Illinois, Minnesota and Iowa. National policy set by 

Congress favors early integration of sUAS into the national airspace in controlled, safe 

working environments such as those propose in this petition. ERC would like to help 

facilitate safe integration of sUAS’s into mainstream USA in the following areas:

Aerial Surveying; As with construction imaging, aerial imaging flights will be used to 

capture aerial photos for the purpose of creating image maps. The image maps will be 

used to compute volume, create 3D models, DSM’s, DTM’s, profile and contour lines.

Movies and Event Photography; Whether the shot requires unique views and 

expansive panning or altitude with unique views, the sUAS is designed to hold up under 
demanding conditions. Because of the autopilot feature with pre-designed mission 

management and R/C control interrupt, the pilot and camera operator can easily create 

the ultimate shot with HD video or HD still photos. When working close in on a closed 

set the hazards to the actors are substantially reduced due to the size of the sUAS.

Precision Agriculture; This technology, which uses a variety of spectral data, has 

potential for several agricultural uses, including: early-generation crop breeding line 

evaluations, quick and wide-scale scouting of croplands for crop conditions and weed 

densities, grassland conditions and production evaluation, detection of noxious weeds 

and detection of blue green algae blooms in ponds and reservoirs. In addition, the 

technology allows the monitoring of water use and will allow the land owner to directly 

control the quantity of water use.

News Gatherings; Similar to movies and event photography, each news assignment 

may require a completely different shot or view of a scene. With budgets for traditional 

helicopter use being greatly reduced, the sUAS is the perfect solution to allow for easy 

news gathering for a fraction of the cost. The sUAS can and will be operated in a sterile 

area away from the public, while the traditional helicopter must hover over persons and 

property increasing the danger to individuals.

Construction and First Responders; Low level oblique photos and video from several 

angles are far more effective than ground based imagery for displaying the 

characteristics of large, complex properties with several buildings and large trees. The 

applicants in the past have chartered 2-seat full-sized helicopters for this purpose, 

which has proven more costly than many potential clients have been able to afford. The 

benefits of reduced cost and improved quality of presentation from the UA will be 

valuable to and benefit many buyers and sellers of real property. Additionally, we 

request that we be allowed to use our system to benefit first responders nearby who 

might require assistance, including fire fighters, the police, the sheriff, et al., while 

remaining subject to all limitations cited in this application.

Real Estate; The sUAS can be used in all areas of real estate, including commercial, 

residential and industrial properties. Using a sUAS, real estate professionals can create 

promotional videos, photos and unique shots that normal camera aspects cannot 

capture. ERC’s easy-to-use video and photo platforms enable properties to stand out, 

providing dazzling views that are typically shown via expensive computer animation or 

costly helicopter rentals. Imagine shooting a view from a high-rise condo in stunning 

high definition that shows your potential customer the actual view from the residence. 

The remote platform is great for new planning, zoning and large developments. Simple 

and easy-to-use video and photos allow for multiple height pictures and elevation views.

VII. Privacy

Edge Runner Communications Inc is deeply committed to protecting public privacy. 

ERC knows that many individuals have concerns about privacy from the operations of 

sUAS’s. ERC has created a privacy notice that informs residents, commercial property 
owners, churches, schools, and governmental organizations of our intent to conduct 

commercial drone operations in proximity to their property.

VIII. Federal Registry Summary

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:

Edge Runner Communications Inc., seeks an exemption from the following rules:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121 (Page 3) 14 C.F.R. 91.151(a)

14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 - 91.417)

Approval of this exemption request allows ERC to conduct commercial operations with 

small and lightweight unmanned aerial systems. ERC’s singular vision is to enhance 

safety of sUAS operations in the NAS while reducing risk to the general public and 

property owners.

The Phantom 3 sUAS, weighing less than 30 pounds and powered by batteries, 

eliminates virtually all of that risk given the reduced mass and absence of combustible 

fuel carried on board. The sUAS is transported to the designated mission area and set 

up there. The sUAS will carry no passengers or crew and, therefore, will not expose 

them to the risks associated with manned aircraft flights.

The operation of this small UAS will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein, including exempting the applicant from the 

requirements of several regulations and allowing commercial operations. These 

lightweight sUAS’s operate at slow speeds, close to the ground, and in a sterile 

environment. As a result, they are far safer than conventional aerial survey and 

inspection operations conducted with fixed wing aircraft or helicopters.

If additional information is required, or if you have any questions regarding this Petition 

for Exemption, please contact the undersigned.
IX. Conclusion

The petitioner is requesting this exemption for the purposes of aerial surveying, 

precision agriculture, real estate photography, aerial filmmaking and photography, 

construction site inspections and monitoring, news gatherings and other flight 

operations. The reason for such a general and broad based request is that the petitioner 

wishes to utilize a business strategy of horizontal integration and maximize economies 

of scope in order to capitalize on opportunities as they may arise in the future without 

the long turnaround time associated with additional exemptions. The petitioner's 

business model is based on the idea of offering ad hoc small UAS services to 

individuals or companies who wish to employ these services as a safe, effective, and 

legal option to enhance their business or hobby. The petitioner’s own market research 

shows pent up demand for these services currently exists in the real estate market, 

construction, movie- making, and other markets are just beginning to emerge. The 

petitioner has identified Universities and other agencies that could benefit from the 

operation requested in this application. A quick internet search will show that many are 

currently operating similar UAS in exactly this fashion without, it is assumed, FAA 

authorization. The petitioner has refrained from engaging in commercial use of the UAS. 

The primary purpose of seeking this exemption is to obtain the capability to offer those 

services while remaining in compliance. The petitioner has 15years of experience in 

marketing/communications, 8 years video editing and filming and is a rated helicopter 

pilot with extensive knowledge relative to the industries and conditions that petitioner 

intends to service.

Best Regards,

Brett Sargent 

Edge Runner Communications 

(608) 217-4076

Supporting Documents: Operational/Users Manual