Engineers 

### + Surveyors 

### + Inspectors 

### + Construction Managers 

### + GIS 

# MERCADO

CONSULTANTS, INC. 

### April 27, 2Q15
Docket Operations, M-30 U.S. Department ofTransportation (DOT) 1200 New JerseyAvenue, SE Room W12-140, West Building Ground Floor Washington, DC 20590-0001 Reference: DJI PHANTOM II- VISION PLUS Serial Number: PH645277129 Petition for Exemption under Section 333 This letter is to request a Petition for an Exemption under Section 333 for the reference UAS. I have read all documents, regulations and applicable FAA laws associated with this petition and we will adhere to all current and future regulations as may be necessary to safely operate the referenced UAS. We at Mercado Consultants, Inc. understand the importance of following FAA regulations. To adhere to all FAA's regulation, we are submitting the following supporting documents: 1. Filed and received a ICAO registration:# 51570201 (see enclosed copy) 2. Develop a comprehensive UAS- System Safety Assessment (SSA) document identifying a complete description and purpose of the UAS use (see enclosed document) Should you have any questions or require addition information, please feel free to contact me.

Phone: (301) 260-0090 17830 New Hampshire Ave., Suite 200, Ashton, MD 20861 www.mercadoeng.com Fax: (301) 260-0018Engineers 

### + Surveyors 

### + Inspectors 

### + Construction Managers 

### + GIS 

# MERCADO

CONSULTANTS. INC. 

# UAS- System SafetyAssessment (SSA)

Version: 1.0.0 Updated: 12-24-14 Purpose: This system safety assessment has been developed to satisfy FAA regulatory requirements for use ofan unmanned aircraft system (UAS) for commercial purposes. This document describesthe operational scenarios in which the UAS will be operated, the general safety policies and proceduresto be used before flight, duringflight, and afterflight completion, the overall UAS design and operation focus of Mercado Consultants, Inc., training procedures for all UAS operators, and regular maintenance procedures.
UAS Description: Mercado Consultants, Inc. will be operatingthe DJI Phantom 2Vision+. This SSA is intended to be used with this UAS only, as specific safety system guidelines have been developed with the specific capabilities and control systems available on the DJI Phantom 2 Vision+. Company Description: Mercado Consultants, Inc. is a multi-disciplined engineering company providingtransportation infrastructure services to a variety of public and private clients. Services related to the use ofthe UAS include topographical survey and aerial imagery, construction management/observation, and bridge inspection. Please see www.mercadoeng.com for a more detailed list ofservices provided.
1.0Operational Scenario Description
1.1 Overview 1.1.1 Mercado Consultants, Inc. intendsto operatethe UAS in three different operational scenarios detailed in sections 1.2through 1.4. In all scenarios two criteria are always followed -the UAS is operated below a height of 400 feet and the UAS is always within visual sight ofthe operatorwhich shall not exceed a horizontal distance of400feetfrom the operator. 1.2 Scenario 1- General Site Survey 1.2.1 Description: This scenario is intended to be used with general site imageryfor use in aerial survey or construction management observation tasks. It is not meantto be used with detailed site photogrammetry. 1.2.2 Sample WorkTasks: Aerial photographs ofvarious stages ofa construction project, aerial video or photographs ofa general site for general use by engineers during design phase, aerial images of bridge or

Phone: (301) 260-0090 17830 New HampshireAve., Suite 200, Ashton, MD 20861 www.mercadoeng.com Fax: (30:1.) 260-00:1.8critical transportation infrastructure after hazardous event (i.e. flood, earthquake, etc.). 

### 1.2.3 Deliverables: High quality photos orvideostaken from UAS. 

### 1.2.4 Limitations: This scenario is not meantto provide precise photogrammetry or aerial imagery photosto be scaled, projected, or dimensioned for precise engineering. 

### 1.3 Scenario 

### 2- Bridge Inspection 

### 1.3.1 Description: Bridge girders, piers, and abutments may be in locations that are difficultto reach for bridge inspections and often require costly equipment. This scenario uses UAS to inspect portions ofbridges that are difficultto access. 

### 1.3.2 Sample WorkTasks: Image ofdeteriorated girderover

### 30feet above a stream crossing, images ofconcrete deterioration on bridge piers or abutments, emergency inspection ofcritical bridge components. 

### 1.3.3 Deliverable: High quality photos orvideostaken from UAS. 

### 1.3.4 Limitations: The UAS is notto be flown overvehiculartraffic. This scenario is for inspecting portions ofa bridgethat are not directly over traffic and typically includes components belowthe underside ofthe bridge. 

### 1.4 Scenario 

### 3- Aerial Mapping 

### 1.4.1 Description: Aerial photogrammetry or precise aerial mapping ofsite for detailed engineering use. It is expected that any photographstaken from this scenario would be post processed in awayto be used in geographical information system (GIS) or computer automated drafting and design (CADD) environments. 

### 1.4.2 Sample WorkTasks: Aerial photogrammetry ofsmall site for use ofdesign engineers. 

### 1.4.3 Deliverable: High quality photos. 

### 1.4.4 Limitations:This scenario is generallyto be used for small sites (several acres) and not intended for large area photogrammetry.
2.0General System Safety Information


### 2.1 Overview 

### 2.1.1 This section provides the general safety policies and procedures for operatingthe UAS in the scenarios outlined in section 

### 1. Detailed safety operationsfor specific scenarios that may occur during operation ofthe UAS are described in more detail in section 4. 

### 2.2 Pre-flight Safety Policies and Procedures 

### 2.2.1 System Calibration 

### 2.2.1.1 Compass 

### 2.2.1.1.1 Before each flight, the on-board compass must be calibrated beforethe UAS takes flight. This is particularly important afterthe UAS has been transported to the site in a motorized vehicle. Successful compass calibration will be evident by a

Page 2 of 10sequence ofcolored lights on the bottom ofthe UAS (see Phantom 2Vision+ user manual for more information) and by a message on the application screen. 

### 2.2.1.1.2 Ifthe compass cannot be calibrated due to a mechanical error or proximityto electrical current (i.e. powerlines), operation ofthe UAS is to cease immediately and the UAS returned back to the office. 

### 2.2.1.2 Gimbal, battery level, and internal controller 

### 2.2.1.2.1 Before each flight, ensure thatthere are no mechanical or software errors in the gimbal, batteries, or internal controllers. Any errors will be evident by a message on the application screen at startup. 

### 2.2.1.2.2 Ifmechanical orsoftware errors are present, operation ofthe UAS is to cease immediately and the UAS returned backto the office. 

### 2.2.2 InclementWeather 

### 2.2.2.1 Due to the lightweight and small nature ofthe Phantom 

### 2 Vision+, the UAS is onlyto be operated duringthe daytime in an area with adequate visibility. The UAS must be visible at all times during operation. 

### 2.2.2.2The UAS may not be operated duringsnow or rain or during high winds. 

### 2.2.3 Right-of-wayAccess 

### 2.2.3.1The UAS must only be operated in the Right-of-way airspace allowed bythe FAA. Any owners associated with the airspace that the UAS will be operated in must be contacted. 

### 2.2.4 Flight Plan 

### 2.2.4.1 Priorto commencing any operation ofthe UAS, aflight plan must be established forthe tasks to be accomplished. The flight plan must includethe goal ofthe UAS flight, any potential issues that may arise duringflight, and must go over any emergency landing procedures and areas forthe UAS. 

### 2.2.4.2The location ofany nearby airports must also be noted. As part of the GPS system built intothe Phantom 

### 2 Vision+, the onboard control system forthe UAS will not letthe UAS fly intothe airspace restricted by an airport. However, an inspection on a map shall be made priorto goingto the site to ensure thatthe flight will not occur in or near restricted airport airspace. 

### 2.2.5 Visual Site Survey 

### 2.2.5.1 Once atthe site, priorto operatingthe UAS, the overall surroundings must be inspected before launching. Items to pay particular attentionto are overhead branches or obstructions, utility lines, lowflying aircraft, and the potential for inclement weather. 

### 2.3 Flight Safety Policies and Procedures

Page 3 of 102.3.1 Flight Altitude and Horizontal Limits 2.3.1.1The UAS shall not be operated over an altitude of400 feet above the ground. 2.3.1.2The UAS shall not be operated horizontally beyond a distance of 400 feet ofthe operator. At all timesthe UAS shall be visible by the operator. 2.3.2 Operator and Assistant Operator 2.3.2.1The UAS shall always be operated with ateam oftwo individuals.

2.3.3 GPS One individual shall be designated the operator and shall operate the remote control forthe UAS and always have avisual eye on the UAS. The second individual shall be the assistant operator and shall keep avisual eye on the UAS and the overall surroundings paying particular attention to hazards thatthe operator may not be able to see. 2.3.3.1 GPS shall tryto be established priorto liftoffofthe UAS. In many cases they may require waiting 15 to 30 minutesforthe GPS signal to be established. 2.3.3.2 In general, it is easierto obtain aGPS signal from a location without any vertical obstructions such as a parking lot oropen field. 2.3.3.3 Ifa GPS signal cannot be obtained, the UAS should liftoffto an elevation of200 feet above the ground and stay steady in the same location for several minutes. Typically duringthis maneuver, aGPS signal can be established. 2.3.4 Establishing a Home Point 2.3.4.1 When GPS signal is available, a home point shall be established. As afailsafe on the Phantom 2 Vision+, ifconnectivity is lost with the UAS, the UAS will elevate by 20 meters, hover overthe home point, and land. 2.3.4.2The location ofthe home point shall be one without any vertical obstructions. Particular attention should be paid to assessingthe vertical path the UAS would taketo get backtothe home point if signal is lost and ensuringthatthere is no obstructions in this path. 2.3.4.3 Duringthe course ofoperatingthe UAS, it may become necessary to change the home pointto the UAS's current location as it gets further awayfrom the location the initial home pointwas set at. Changingthe home point duringflight can be accomplished using the controller. At all times, the home point shall be chosen with the failsafe procedure in mind. 2.3.5 Lost Remote Control Signal 2.3.5.11n the eventthatthe remote control signal is lost, the UAS will initiate its failsafe procedure and return to the home point.

Page 4 of 102.3.5.2The UAS returns to the home point in avery slow manner. Often remote control signal can be reestablished by walkingtowards the UAS. 2.3.5.3 Within a horizontal distance of400feetfrom the UAS, losing remote control signal with the UAS is very rare. 2.3.6 Low Battery 2.3.6.11n the event ofa low battery, the UAS will proceed to fly backto the home point. A battery level indicatorwill appear on the application screen. Once the low battery message appears, the operator must startto move the UAS into a position where it can be landed. 2.3.6.2The UAS shall nottake offwith a batterythat has less than 25% of its full charge. 2.3.7 Emergency Landing Due to Mechanical orSoftware Failure 2.3.7.1 Priorto operatingthe UAS, aflight plan shall be established. As part ofthis plan, an area should be designated as an emergency landing area in the event ofa mechanical or softwarefailure. The emergency landing area should be in an open area without any overhead obstructions or hazards on the ground. 2.3.7.2Typical emergency landing areas include agrassy, open area or a paved area without any parked cars. 2.4 Post Flight Policies and Procedures 2.4.1 Mechanical Maintenance 2.4.1.11fthe UAS experiences a mechanical or software failure during flight, itshall be returned to the office immediately afterthe incidentto evaluate the damage to the UAS. The UAS shall never be operated ifthere is a mechanical or software failure ofone of its components. 2.4.1.2 The electrical motors, landing gear, propellers, camera, compass, and other mechanical components ofthe UAS shall be inspected atthe completion ofeach flight. Ifany damage is observed to any ofthe components, attention shall be brought immediatelytothe issue. 2.4.2 Storage

3.0 Design Focus
3.1 Overview 2.4.2.1The UAS shall be stored in the hard shell case when not in use. Duringtransportation to and from thejob site, the UAS shall always be in the hard shell case. 2.4.2.2 During longer periods when the UAS is not in use, the batteries shall be discharged to 50% before storingto prolongtheir usable life and abilityto hold charge.

3.1.1 This section describes the overall goals in designing and planningthe flight plan ofthe UAS for each worktask.

Page 5 of 103.2 Safety First 3.2.1 The focus ofplanning each flight shall always be the safety procedures outlined in section 2. Attention shall be madeto potential site hazards duringflight and landing. Since transportation projects are thefocus of the use ofthis UAS, for operational scenarios 1 and 3 (general site survey and aerial mappingL the UAS flight path shall tryto be limited as much as possibleto areas that are not above live traffic. For operational scenario 2 (bridge inspection) where the UAS will be operated below a bridge in limited clearance locations, the UAS shall notfly over live traffic. 3.3 Focus on Deliverable Type 3.3.1 Each flight plan shall clearly establish the goal oftheflight and the deliverabletype- photographs orvideo. All flight maneuvers shall be madeto position the UAS totake these photographs/videos. 3.4 Routine Maneuvers 3.4.1 Every effort shall be madeto have aflight path that has routine maneuvers, such as limited turns, limited changes in elevation, and ample horizontal and vertical clearance. 3.5 Site Selection for Emergency Procedures 3.5.1 In the flight plan, both the home point and emergency landing area shall be designated. 3.5.2 As stated in section 

### 2.3.4, the home point shall be selected as a location where GPS signal can be established. In addition the UAS must be able to return tothe home point during its failsafe procedure ifan emergency happens duringflight. It is imperativethatthe area between the UAS and the home point not have any obstructionsthroughoutthe operation of the UAS to allowforthe failsafe procedure. 3.5.2.1 Several home points may need to be specified during aflightto ensure thatthe UAS can return back safelytothe home point location ifthe fail safe procedure is activated. 3.5.3 As stated in section 

### 2.3.7, an emergency landing area shall be designated in case of a critical mechanical or software failure wherethe fail safe procedure cannot be activated. In this case the operatorshould use any control means necessaryto getthe UAS tothe emergency landing location. 3.5.4 

### Jt is essential thatat all times during operation,the operatorcan visually see the UAS. The UAS should not be operated in sites that are heavily wooded and have large visual obstructions.
4.0 Operation Focus
4.1 Overview 4.1.1 The section describes the overall goals when operatingthe UAS. In particular, details ofeach ofthe operational scenarios in section 1. 4.2 Scenario 1- General Site Survey 4.2.1 Vertical Clearance overObstructions

Page 6 of 10inspection, the operatorshall be as close as possible to the UAS and shall always have avisually eye on the UAS. 4.3.4 Operating over Bridge 4.3.4.1The UAS shall notoperate overtrafficthat is crossing the bridge. The onlytimethe UAS will be at an altitude above the top surface ofthe bridge would be to take an overall site photo orvideo of the bridge. This can be accomplished without havingto be over live traffic. 4.3.5 Operating above Live Traffic 4.3.5.1The UAS will never be operated over live traffic. This includes both trafficthat may be overthe bridge or passing underthe bridge. 4.3.6 Licensed Professional Engineer 4.3.6.1A licenses professional engineer must always be atthe site during this operational scenario. 4.4 Scenario 3- Aerial Mapping 4.4.1 Altitude 4.4.1.1 Aerial mapping/photogrammetry involvestaking high quality photographs at precise locations. It is anticipated that in orderto take these photos, the UAS will need to be near its upper altitude limit of400feet above the ground. At all timesthe UAS shall be operated above any obstruction (tree or building) provided itdoes not go higherthan an elevation of400feet above the ground. 4.4.2 Quality of Deliverables

5.0Training Focus
5.1 Overview 4.4.2.1Aerial mapping requires high quality photographsthat will be projected and post processed for use in applications. To ensure the quality ofthese photographs, the UAS should be operated a slow speed with as littleturning as possible. See section 3.4 for more information.

5.1.1 This section providesthetraining requirements and guidelines for providing individualsthe necessary experience to operatethe UAS in the operational scenarios described in section 1.0. 5.2 Hours of Experience Requirement 5.2.1 A minimum of25 hours ofoperation time experience must be accumulated before an individual can become an operator and pilotthe UAS in the operational scenarios described in section 1.0. Operation time experience must be attained underthe direct instruction ofanother individual in the companywho has obtained the 25 hours ofoperation time experience. 5.2.1.1 At least 15 hours ofexperience must be in general operation training, see section 5.3. 5.2.1.2 At least 10 hours ofexperience must be in bridge inspection training, see section 5.3.

Page 8 of 106.4.1 All control system software and firmware must be kept up to date.

6.5 Batteries Announcements on software and firmware updates forthe UAS are available on the UAS manufacturerwebsite and must be checked regularly.
6.5.1 UAS Batteries 6.5.1.1 The UAS uses lithium polymer {Lipo) batteries. These batteries must be checked regularly usingthe software application from DJS which checks the battery life. 6.5.1.2 Ifthe batterieswill be stored for prolonged periods oftime, they should be stored at 50% charged capacity. 6.5.2 Range Extender Charge 6.5.2.1The range extender must be charged before each flight. This is accomplished using astandard USB charger cable. 6.5.3 Remote Batteries 6.5.3.1 The batteries used in the remote control (AA) must be replaced periodically. 6.6 Compass 6.6.1 Priorto beginning each flight and immediately after each flight, the compass must be inspected for any damage. Ifdamage can be visibly seen or a hardware error message appears on the screen during compass calibration beforethe flight, the UAS must be brought intothe office immediately and the manufacturer contacted. Additional Information: This documentwas created by Mercado Consultants, Inc. to provide the system safety assessment required to operate the DJI Phantom 

### 2 Vision+ UAS for commercial applications. Ifadditional information is required, Mercado Consultants, Inc. can be contacted at: Mercado Consultants, Inc. 17830 New Hampshire Ave. Ashton, MD 20861 301-260-0090 

# (2i**~~-----?~ ~~** 

Page 10 of 10REGISTRATION NOT TRANSFERABLE

UNITED STATES OF AMERICA I This certificate

DEPARTMENT OF TRANSPORTATION- FEDERAL AVIATION ADMINISTRATION must be in the airCERTIFICATE OF AIRCRAFT REGISTRATION craft when operated.

NATIONALITY AND I AIRCRAFT SERIAL NO.
REGISTRATION MARKS N 546ZM PH645277129 MANUFACTURER AND MANUFACTURER'S DESIGNATION OF AIRCRAFT

DJI PHANTOM 2 VISION +

ICAO Aircraft Address Code: 51570201

This certificate is

issued for

I MERCADO CONSULTANTS INC registration purposes

s 17830 NEW HAMPSHIRE AVE STE 200 only and is not a

s ASHTON MD 20861-3643 certificate of title.

u The Federal Aviation

E Administration does

D not determine rights

of ownership as

T between private

0 persons.

Corporation 0

It is certified that the above described aircraft has been entered on the register of the Federal

Aviation Administration, United States of America, in accordance with the Convention on

International Civil Aviation dated December 7, 1944, and with Title 49, United States Code, U.S. Department

and regulations issued thereunder. April 17, 201 S

**~~~/** of Transportation

DATE OF ISSUE 2:::861 **::lf~e!i!).!.!lttion**

EXPIRATION DATE April 30, 2018 ADMINISTRATOR Administration

AC Form 8050-3 (1012010) Supersedes previous editions **·"'"'~#ill~'!tllt,.,.., t:i~fr.J_~~-~2rt'~)1?-:tiJf.l**  **~r::~!1'}~·--~t~}~{-** ::?::tr)·

w

z :J **~** 0

z 0

!:;

g. **·2::tA~~~~** $00.48° 000200 75i 8 APR 21 **20~.** I'JIAU..ED FROM ZIP CODE 7 31

Official Business

Penalty for Private Use $300

AC Form 8050-3 (10/2010) Supersedes previous edition

TO: MERCADO CONSULTANTS INC 17830 NEW HAMPSHIRE AVE STE 200

ASHTON MD 20861-3643 'liJ•JiflsllpllfgJJ1tJ11 1 JIJ•IJjl•jh;,l;I 11 1 1 1,1,1JriJJJfl••n• 546ZMEFFECT OF REGISTRATION

Title

49 U. S. C. 441 03(c)(2) provides: "A certificate of registration issued under this section is not evidence

of

ownership of aircraft in a proceeding in which ownership is, or may be, in issue." THIS CERTIFICATE

MUST

BE SIGNED AND RETURNED BY THE REGISTERED OWNER WITHIN 21 DAYS WHEN IT IS

NO LONGER IN EFFECT FOR ANY REASON UNDER 14 C.F.R. 47.41(a)(1) through (7).

a. D Registration is cancelled at the **req~est**

of the owner. (Also check
and/or

complete Block b, c, d,

e,

or f).

b. D The aircraft is totally destroyed

or

scrapped.

c. D United States citizenship has

been

lost, or the owner's status as

a

resident alien has changed (unless

changed to that of a U.S. citizen).

d. D Thirty days have elapsed since the

death

of the registered owner (estate

representative should sign). (SIGNATURE) e. D The aircraft is to be registered
under

the laws of a foreign country: (NAME OF FOREIGN COUNTRY)

f. D The ownership of the aircraft is transferred

to: (NAME) (ADDRESS) (CITY, STATE, ZIP) (TITLE) (DATE)

This certificate must be returned to:

AIRCRAFT

REGISTRATION BRANCH, P.O. BOX 25504, OKLAHOMA CITY, OKLAHOMA 73125-0504 RETAIN THIS INFORMATION

FOR FUTURE REFERENCE CHANGE OF ADDRESS

Federal Aviation Regulations require that the registered owner of the

aircraft

shall report in writing within 30 days any change in permanent

mailing

address. A revised Certificate of Registration will be issued

without

charge. The Application for Registration AC Form 8050-1 may

be used to report a change of address. REPLACEMENT OF CERTIFICATE

If this certificate is lost, destroyed, or mutilated, a replacement may

be

obtained at the written request of the holder. Send your request

and $2.00 (check or money order made payable to the Federal Aviation Administration)

to: Aircraft Registration Branch
P.O.

Box 25504 Oklahoma

City, Oklahoma 73125-0504

NOTE: All correspondence should include the registration "N" number, **m~nufacturer,**

model, and serial number of the aircraft.

To offer your feedback regarding the aircraft registration process, please

visit our website at http://registry.faa.gov/arcertl