A0k6*k4jjk Engineers ♦ Surveyors ♦ Inspectors ♦ Construction Managers ♦ GIS 

MERCADO 

CONSULTANTS, INC. 

April 27, 2015 

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: Petition for Exemption under Section 333 of Public Law 112-95 in 

reference to 49 U.S.C. § 44704. Relief from 14 CFR part 21, Certification 

procedures for products and parts, Subparrt H—Airworthiness Certificates in 

accordance with the statutory criteria provided in Section 333. 

Dear Sir or Madam: 

Please consider this a request for an exemption of the above applicable sections for Mercado 

Consultants, Inc. for the purpose of conducting commercial aerial operations with its small 

Unmanned Aircraft System. These operations include aerial imagery, construction management 

observations, storm-water management photography, and observation of obscured elements of 

bridges during bridge inspection tasks. 

Mercado Consultants, Inc. 

Established in 1989, Mercado Consultants, Inc. is a multi-disciplined engineering company 

providing transportation infrastructure services throughout the Washington, DC and Baltimore 

areas. 

Description of Aircraft System and Performance Characteristics: 

Aircraft Type: DJI-Phantom II - Vision Plus 

Aircraft Registration Marks: N 646ZM 

In accordance with § 44711 which requires that all aircraft, including UAS, be 

registered in accordance with part 47 of the regulations and must provide 

identification markings in accordance with part 45, Subpart C) 

Climb Rate: 1,740 feet/minute 

Descent Rate: 420 feet/minute 

Turn Rate: 200 Deg/sec 

Approach Speed: 10 feet or less/sec 

Cruise Speed: 49 feet/sec (Max), 1 foot/sec (Min) 

Goss Takeoff Weight: 2.9 Ibs. 

Launch/Recovery: 2.9 Ibs. 

Power Source: DJI 5200 mAh battery 

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

www.mercadoeng.com 
Proposal for conducting flight operations: 

The flight operations include: aerial imagery, construction management observations, storm 

water management photography, and observation of obscured elements of bridges during 

bridge inspection tasks. 

The following system safety procedures and protocols will be implemented for each flight: 

1. Flights will be operated within line of sight of a pilot and/or visual observer (VO). 

2. Flights will be terminated at or before the automatic battery low voltage signals 25% 

battery power reserve. Actual data for flight endurance will be compiled for each aircraft 

battery configuration prior to the aircraft being deployed for service. Such data will be 

used to limit flights more accurately than the voltage alert can provide. 

3. The UAV will operate at altitudes up to but not exceeding 400 feet AGL within a 

specifically defined area. At no time will the UAV be operated directly over a person. In 

The event flight takes place over public lands Mercado Consultants will obtain 

permission to operate. The UAV is capable of an emergency landing in a vertical manner 

and requires no runway or horizontal landing area in the event of such an emergency 

4. Minimum crew for each operation will consist of the pilot in command (PIC) and a visual 

observer (VO). 

5. The UAS will only operate within a pre-defined controlled area. This area will 

be secured prior to the flight operation. If the property over which the flight is to be 

conducted is privately owned, the property owner's permission to conduct the flight will 

be obtained prior to the flight operation to be conducted. 

6. The PIC and VO will be required to complete training in accordance with the 

requirements of this exemption. 

7. Observer and pilot will at all times be able to communicate by voice. 

8. AII required permissions and permits will be obtained from state, county or city 

jurisdictions, including local law enforcement or appropriate governmental agencies. 

9. Prior to each flight the aircraft will be tested in accordance with the manufacture's setup 

manual for preflight check. This will include: altitude, distance limiting feature; test of the 

battery low voltage warning; and a test of the failsafe system. The level of safety will be 

achieved by the Pilot in Command following Mercado Consultants, Inc. UAS Policies and 

Procedures manual as well as the DJI User's Manuals. The operator will ensure that the 

UAS is in working order prior to each flight and maintain a detailed log of maintenance 

performed. The operator is the person rnost familiar with the aircraft and can provide the 

equivalent level of safety as intended by the rule. 

10. The operator will obtain the consent of all persons involved in the operation and ensure 

that only consenting persons will be allowed within 30 feet of the flight operation. This 

radius may be reduced further based upon an equivalent level of safety determination 

with the advanced permission of the relevant FSDO. 

11. The sUAS is powered by a battery, which provides up to 30 minutes of powered flight. 

Because of the absence of flammable operating fluids, a sUAS would not pose the same 

level of risk as a conventional aircraft. 

12. The Phantom II does not have a barometric altimeter, but rather an imbedded GPS 

based altitude reporting system. The UAV altitude limiting feature will remain below an 

altitude appropriate for the flight and one in which the visual observer can maintain line 

of site. At no time will the UAV be allowed to operate any higher than 400 feet AGL. 
Airwori:hiness cer- tificate 

Part 21 Subpart I-I prescribes procedural requirements for the issue of airworthiness certificates. 

Mercado Consultants, Inc. requests exemption from this subpart to operate the DJI Phantom II 

without the requirement for an airworthiness certificate. This position is based on the proposed 

UAS being limited in its current scope of capability, weight, speed, and operating envelope. The 

UAV carries no passengers or flammable materials such as gasoline or jet fuel. The UAV will be 

operated within visual line of site. 

Private Pilot Pr•ivileges and Limitations: Pilot in Command 

At this time, Mercado Consultant's does not eniploy a qualify pilot meeting all the requirements 

of 14 C.F.R. 61.113(a) &(b): Private Pilot Privileges and Limitations: Pilot in Command. 

Upon approval of this waver application we will retain and train a pilot in conformance with the 

articles of this section as well as all the requirements of waiver conditions and limitations. 

Any additional information, views or arguments available to support your request: 

Please see attachments. 

If you want to exercise the privileges of your exemption outside of the United States, 

and the reason why you need to do so: 

The commercial, demonstrations and development operations described in this exemption 

request will be conducted wholly within the United States. 

Description of Relief Sought: 

Mercado Consultants Inc. seeks relief from the all applicable section of this request based on 

previously FAA's issued grants of exemption as follows grant of exemptions: 

✓ 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352); 

✓ 11109 to Clayco, Inc. (see Docket No. FAA-2014-0507); 

✓ 11112 to VDOS Global, LLC (seeDocket No. FAA-2014-0382); 

✓ 11213 to Aeryon Labs, Inc. (see Docket No.FAA-2014-0642). 

Should you have any questions or require addition information, please feel free to contact me at 

bmercadoCa-),mercadoenq.comor by phone at (240)722-6314. 

;eived an ICAO registration: # 51570201. 

nsultants, Inc. UAS Policies and Procedures Manual