Engineers + Surveyors + Inspectors + Construction Managers + GIS 

MERCADO 

CONSULTANTS, INC. 

April 27, 2Q15 

Docket Operations, M-30 

U.S. Department of Transportation (DOT) 

1200 New Jersey Avenue, 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) 260-0018 
Engineers + Surveyors + Inspectors + Construction Managers + GIS 

MERCADO 

CONSULTANTS. INC. 

UAS- System Safety Assessment (SSA) 

Version: 1.0.0 Updated: 12-24-14 

Purpose: This system safety assessment has been developed to satisfy FAA regulatory 

requirements for use of an unmanned aircraft system (UAS) for commercial purposes. This 

document describes the operational scenarios in which the UAS will be operated, the general 

safety policies and procedures to be used before flight, during flight, and after flight 

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 operating the DJI Phantom 2 Vision+. 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 

providing transportation infrastructure services to a variety of public and private clients. 

Services related to the use of the UAS include topographical survey and aerial imagery, 

construction management/observation, and bridge inspection. Please see 

www.mercadoeng.com for a more detailed list of services provided. 

1.0 Operational Scenario Description 

1.1 Overview 

1.1.1 Mercado Consultants, Inc. intends to operate the UAS in three different 

operational scenarios detailed in sections 1.2 through 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 of the operator which 

shall not exceed a horizontal distance of 400 feet from the operator. 

1.2 Scenario 1-General Site Survey 

1.2.1 Description: This scenario is intended to be used with general site 

imagery for use in aerial survey or construction management observation 

tasks. It is not meant to be used with detailed site photogrammetry. 

1.2.2 Sample Work Tasks: Aerial photographs of various stages of a 

construction project, aerial video or photographs of a general site for 

general use by engineers during design phase, aerial images of bridge or 

Phone: (301) 260-0090 17830 New Hampshire Ave., Suite 200, Ashton, MD 20861 

www.mercadoeng.com 

Fax: (30:1.) 260-00:1.8 
critical transportation infrastructure after hazardous event (i.e. flood, 

earthquake, etc.). 

1.2.3 Deliverables: High quality photos or videos taken from UAS. 

1.2.4 Limitations: This scenario is not meant to provide precise 

photogrammetry or aerial imagery photos to 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 difficult to reach for bridge inspections and often require costly 

equipment. This scenario uses UAS to inspect portions of bridges that are 

difficult to access. 

1.3.2 Sample Work Tasks: Image of deteriorated girder over 30 feet above a 

stream crossing, images of concrete deterioration on bridge piers or 

abutments, emergency inspection of critical bridge components. 

1.3.3 Deliverable: High quality photos or videos taken from UAS. 

1.3.4 Limitations: The UAS is not to be flown over vehicular traffic. This 

scenario is for inspecting portions of a bridge that are not directly over 

traffic and typically includes components below the underside of the 

bridge. 

1.4 Scenario 3-Aerial Mapping 

1.4.1 Description: Aerial photogrammetry or precise aerial mapping of site for 

detailed engineering use. It is expected that any photographs taken from 

this scenario would be post processed in a way to be used in geographical 

information system (GIS) or computer automated drafting and design 

(CADD) environments. 

1.4.2 Sample Work Tasks: Aerial photogrammetry of small site for use of design 

engineers. 

1.4.3 Deliverable: High quality photos. 

1.4.4 Limitations: This scenario is generally to be used for small sites (several 

acres) and not intended for large area photogrammetry. 

2.0 General System Safety Information 

2.1 Overview 

2.1.1 This section provides the general safety policies and procedures for 

operating the UAS in the scenarios outlined in section 1. Detailed safety 

operations for specific scenarios that may occur during operation of the 

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 before the UAS takes flight. This is 

particularly important after the UAS has been 

transported to the site in a motorized vehicle. 

Successful compass calibration will be evident by a 

Page 2 of 10 
sequence of colored lights on the bottom of the UAS 

(see Phantom 2 Vision+ user manual for more 

information) and by a message on the application 

screen. 

2.2.1.1.2 If the compass cannot be calibrated due to a 

mechanical error or proximity to electrical current (i.e. 

powerlines), operation of the 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 that there 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 If mechanical or software errors are present, operation 

of the UAS is to cease immediately and the UAS 

returned back to the office. 

2.2.2 Inclement Weather 

2.2.2.1 Due to the lightweight and small nature of the Phantom 2 Vision+, 

the UAS is only to be operated during the daytime in an area with 

adequate visibility. The UAS must be visible at all times during 

operation. 

2.2.2.2 The UAS may not be operated during snow or rain or during high 

winds. 

2.2.3 Right-of-way Access 

2.2.3.1 The UAS must only be operated in the Right-of-way airspace 

allowed by the 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 Prior to commencing any operation of the UAS, a flight plan must 

be established for the tasks to be accomplished. The flight plan 

must include the goal of the UAS flight, any potential issues that 

may arise during flight, and must go over any emergency landing 

procedures and areas for the UAS. 

2.2.4.2 The location of any nearby airports must also be noted. As part of 

the GPS system built into the Phantom 2 Vision+, the onboard 

control system for the UAS will not let the UAS fly into the 

airspace restricted by an airport. However, an inspection on a 

map shall be made prior to going to the site to ensure that the 

flight will not occur in or near restricted airport airspace. 

2.2.5 Visual Site Survey 

2.2.5.1 Once at the site, prior to operating the UAS, the overall 

surroundings must be inspected before launching. Items to pay 

particular attention to are overhead branches or obstructions, 

utility lines, low flying aircraft, and the potential for inclement 

weather. 

2.3 Flight Safety Policies and Procedures 

Page 3 of 10 
2.3.1 Flight Altitude and Horizontal Limits 

2.3.1.1 The UAS shall not be operated over an altitude of 400 feet above 

the ground. 

2.3.1.2 The UAS shall not be operated horizontally beyond a distance of 

400 feet of the operator. At all times the UAS shall be visible by 

the operator. 

2.3.2 Operator and Assistant Operator 

2.3.2.1 The UAS shall always be operated with a team of two individuals. 

2.3.3 GPS 

One individual shall be designated the operator and shall operate 

the remote control for the UAS and always have a visual eye on 

the UAS. The second individual shall be the assistant operator and 

shall keep a visual eye on the UAS and the overall surroundings 

paying particular attention to hazards that the operator may not 

be able to see. 

2.3.3.1 GPS shall try to be established prior to liftoff of the UAS. In many 

cases they may require waiting 15 to 30 minutes for the GPS 

signal to be established. 

2.3.3.2 In general, it is easier to obtain a GPS signal from a location 

without any vertical obstructions such as a parking lot or open 

field. 

2.3.3.3 If a GPS signal cannot be obtained, the UAS should lift off to an 

elevation of 200 feet above the ground and stay steady in the 

same location for several minutes. Typically during this maneuver, 

a GPS 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 a failsafe on the Phantom 2 Vision+, if connectivity is lost with 

the UAS, the UAS will elevate by 20 meters, hover over the home 

point, and land. 

2.3.4.2 The location of the home point shall be one without any vertical 

obstructions. Particular attention should be paid to assessing the 

vertical path the UAS would take to get back to the home point if 

signal is lost and ensuring that there is no obstructions in this 

path. 

2.3.4.3 During the course of operating the UAS, it may become necessary 

to change the home point to the UAS's current location as it gets 

further away from the location the initial home point was set at. 

Changing the home point during flight 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 event that the remote control signal is lost, the UAS will 

initiate its failsafe procedure and return to the home point. 

Page 4 of 10 
2.3.5.2 The UAS returns to the home point in a very slow manner. Often 

remote control signal can be reestablished by walking towards the 

UAS. 

2.3.5.3 Within a horizontal distance of 400 feet from the UAS, losing 

remote control signal with the UAS is very rare. 

2.3.6 Low Battery 

2.3.6.11n the event of a low battery, the UAS will proceed to fly back to 

the home point. A battery level indicator will appear on the 

application screen. Once the low battery message appears, the 

operator must start to move the UAS into a position where it can 

be landed. 

2.3.6.2 The UAS shall not take off with a battery that has less than 25% of 

its full charge. 

2.3.7 Emergency Landing Due to Mechanical or Software Failure 

2.3.7.1 Prior to operating the UAS, a flight plan shall be established. As 

part of this plan, an area should be designated as an emergency 

landing area in the event of a mechanical or software failure. The 

emergency landing area should be in an open area without any 

overhead obstructions or hazards on the ground. 

2.3.7.2 Typical emergency landing areas include a grassy, 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, it shall be returned to the office immediately after the 

incident to evaluate the damage to the UAS. The UAS shall never 

be operated if there is a mechanical or software failure of one of 

its components. 

2.4.1.2 The electrical motors, landing gear, propellers, camera, compass, 

and other mechanical components of the UAS shall be inspected 

at the completion of each flight. If any damage is observed to any 

of the components, attention shall be brought immediately to the 

issue. 

2.4.2 Storage 

3.0 Design Focus 

3.1 Overview 

2.4.2.1 The UAS shall be stored in the hard shell case when not in use. 

During transportation to and from the job 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 storing to prolong their usable 

life and ability to hold charge. 

3.1.1 This section describes the overall goals in designing and planning the 

flight plan of the UAS for each work task. 

Page 5 of 10 
3.2 Safety First 

3.2.1 The focus of planning each flight shall always be the safety procedures 

outlined in section 2. Attention shall be made to potential site hazards 

during flight and landing. Since transportation projects are the focus of 

the use of this UAS, for operational scenarios 1 and 3 (general site survey 

and aerial mappingL the UAS flight path shall try to be limited as much as 

possible to 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 not fly over live traffic. 

3.3 Focus on Deliverable Type 

3.3.1 Each flight plan shall clearly establish the goal of the flight and the 

deliverable type- photographs or video. All flight maneuvers shall be 

made to position the UAS to take these photographs/videos. 

3.4 Routine Maneuvers 

3.4.1 Every effort shall be made to have a flight 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 to the home point during its failsafe procedure if an emergency 

happens during flight. It is imperative that the area between the UAS and 

the home point not have any obstructions throughout the operation of 

the UAS to allow for the failsafe procedure. 

3.5.2.1 Several home points may need to be specified during a flight to 

ensure that the UAS can return back safely to the home point 

location if the 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 where the fail safe 

procedure cannot be activated. In this case the operator should use any 

control means necessary to get the UAS to the emergency landing 

location. 

3.5.4 Jt is essential that at all times during operation, the operator can 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 operating the UAS. In 

particular, details of each of the operational scenarios in section 1. 

4.2 Scenario 1-General Site Survey 

4.2.1 Vertical Clearance over Obstructions 

Page 6 of 10 
inspection, the operator shall be as close as possible to the UAS 

and shall always have a visually eye on the UAS. 

4.3.4 Operating over Bridge 

4.3.4.1 The UAS shall not operate over traffic that is crossing the bridge. 

The only time the UAS will be at an altitude above the top surface 

of the bridge would be to take an overall site photo or video of 

the bridge. This can be accomplished without having to be over 

live traffic. 

4.3.5 Operating above Live Traffic 

4.3.5.1 The UAS will never be operated over live traffic. This includes both 

traffic that may be over the bridge or passing under the bridge. 

4.3.6 Licensed Professional Engineer 

4.3.6.1 A licenses professional engineer must always be at the site during 

this operational scenario. 

4.4 Scenario 3- Aerial Mapping 

4.4.1 Altitude 

4.4.1.1 Aerial mapping/photogrammetry involves taking high quality 

photographs at precise locations. It is anticipated that in order to 

take these photos, the UAS will need to be near its upper altitude 

limit of 400 feet above the ground. At all times the UAS shall be 

operated above any obstruction (tree or building) provided it does 

not go higher than an elevation of 400 feet above the ground. 

4.4.2 Quality of Deliverables 

5.0 Training Focus 

5.1 Overview 

4.4.2.1 Aerial mapping requires high quality photographs that will be 

projected and post processed for use in applications. To ensure 

the quality of these photographs, the UAS should be operated a 

slow speed with as little turning as possible. See section 3.4 for 

more information. 

5.1.1 This section provides the training requirements and guidelines for 

providing individuals the necessary experience to operate the UAS in the 

operational scenarios described in section 1.0. 

5.2 Hours of Experience Requirement 

5.2.1 A minimum of 25 hours of operation time experience must be 

accumulated before an individual can become an operator and pilot the 

UAS in the operational scenarios described in section 1.0. Operation time 

experience must be attained under the direct instruction of another 

individual in the company who has obtained the 25 hours of operation 

time experience. 

5.2.1.1 At least 15 hours of experience must be in general operation 

training, see section 5.3. 

5.2.1.2 At least 10 hours of experience must be in bridge inspection 

training, see section 5.3. 

Page 8 of 10 
6.4.1 All control system software and firmware must be kept up to date. 

6.5 Batteries 

Announcements on software and firmware updates for the UAS are 

available on the UAS manufacturer website 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 using the software application from 

DJS which checks the battery life. 

6.5.1.2 If the batteries will be stored for prolonged periods of time, they 

should be stored at 50% charged capacity. 

6.5.2 Range Extender Charge 

6.5.2.1 The range extender must be charged before each flight. This is 

accomplished using a standard 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 Prior to beginning each flight and immediately after each flight, the 

compass must be inspected for any damage. If damage can be visibly 

seen or a hardware error message appears on the screen during compass 

calibration before the flight, the UAS must be brought into the office 

immediately and the manufacturer contacted. 

Additional Information: This document was created by Mercado Consultants, Inc. to provide 

the system safety assessment required to operate the DJI Phantom 2 Vision+ UAS for 

commercial applications. If additional 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 10 
REGISTRATION 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 

It is certified that the above described 0 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 

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Official Business 

Penalty for Private Use $300 

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

TO: MERCADO CONSULTANTS INC 

17830 NEW HAMPSHIRE AVE S

ASHTON MD 20861-3643 

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EFFECT 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 T

FOR FUT

CHAN

Federal Aviation Regulations requir

aircraft shall report in writing within 

mailing address. A revised Certific

without charge. The Application fo

be used to report a change of addre

REPLACEM

If this certificate is lost, destroyed, o

be obtained at the written request o

and $2.00 (check or money order m

Administration) to: 

Aircraft 

P

Oklahoma Ci

NOTE: All correspondence should 

m~nufacturer, model, and s

To offer your feedback regarding th

visit our website at http://registry.fa