GVG ENGINEERING

CIVIL ENGINEERING - PLANNING - SUSTAINABLE DESIGN

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. 61.113 (a) & (b); 91.103(b); 91.119; 91.121; 91.151(a); 

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b). 

Dear Sir or Madam: 

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

Act") and 14 C.F.R. Part 11, GVG Engineering hereby applies for an exemption from the 

Federal Aviation Regulations ("FARs") listed in Section I below to allow commercial operation 

of its Small Unmanned Aircraft Systems ("sUASs") for aerial imaging and safety and 

monitoring of Project Sites so long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333 

of the Reform Act. As detailed in this document and the attached Addendum, the requested 

exemption would permit the operation of sUAS under controlled conditions in airspace that 

is 1) limited, 2) predetermined, 3) controlled as to access, and 4) would enhance quality, 

reduce environmental impacts, and provide safety enhancements to the already best 

practices safety protocols followed by GVG Engineering at each of its Project Sites. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA Administrator's) responsibilities to "...establish requirements for 

the safe operation of such aircraft systems in the national airspace system." Section 333(c) 

of the Reform Act. 

The name and address of the applicant is:

GVG ENGINEERING,

Greg V. Gladov, PE, LEED AP BD+C

Email: ggladov@gmail.com Phone: 314-246-0422

Address: 392 Falcon Hill Drive, O’Fallon MO, 63368

TEL 314 246-0422 EMAIL GGLADOV@GMAIL.COM

phone (314) 246-0422 

GGLADOV@GMAIL.COM 

June 21, 2015

U. S. Department of 

Transportation 

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590 
CIVIL ENGINEERING - PLANNING - SUSTAINABLE DESIGN

I. 

REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED 

• 14 C.F.R. 61.113 (a) & (b) 

• 14 C.F.R. 91.103

• 14 C.F.R. 91.119

• 14 C.F.R. 91.121 

• 14 C.F.R. 91.151 (a)

• 14 C.F.R. 91.405 (a)

• 14 C.F.R. 91.407 (a) (1)

• 14 C.F.R. 91.409 (a) (2)

• 14 C.F.R. 91.417 (a) & (b) 

STATUATORY AUTHORITY FOR EXEMPTIONS 

II. 

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This 

statutory authority includes exempting civil aircraft, as the term is defined under §40101 of 

the Act, including sUASs, from the requirement that all civil aircraft must have a current 

airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702‐44716 of this Title if the 

Administrator finds the exemption in the public interest.3 Section 333(b) of the Reform Act 

assists the Secretary in determining whether sUASs may operate in the National Airspace 

System ("NAS") without creating a hazard to the user, the public, or a threat to national 

security. In making this determination, the Secretary must consider: 

• The sUAS's size, weight, speed, and operational capability

• Whether the sUAS operates within the visual line of sight of the operator 

• Whether the sUAS operates outside of highly populated areas and away from close 

proximity to airports

If the Secretary determines that a sUAS "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. 

GVG Engineering proposed sUASs are multi‐rotor vehicles, weighing 15 or fewer lbs. 

including payload. They will operate under normal conditions at a speed of no more than 50 

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CIVIL ENGINEERING - PLANNING - SUSTAINABLE DESIGN

mph and have the capability to hover, and move in the vertical and horizontal plane 

simultaneously. They will operate only in line of sight. Such operations will ensure that the 

sUASs will "not create a hazard to users of the national airspace system or the public. 

Given the small size of the sUASs involved and the area within which they will operate, GVG 

Engineering's application falls squarely within the zone of safety (an equivalent level of 

safety) in which Congress envisioned that the FAA must, by exemption, allow commercial 

operations of sUASs to commence. Also due to the small size of the sUASs and the low 

altitudes and limited areas in which GVG Engineering’s sUASs will operate, approval of the 

application presents no national security issue. 

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

Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the 

proposed operations, and the significant public benefit, including enhanced safety and 

reduced environment impacts, the grant of the requested exemptions is in the public 

interest. Accordingly, GVG Engineering respectfully requests that the FAA grant the 

requested exemption without delay so an sUAS can be leveraged on several projects that 

are already in progress. 

III. PUBLIC INTEREST 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 

333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the NAS before 

completion of the rulemaking required under Section 332 of the Reform Act. By granting an 

exemption the FAA will fulfill Congress's intent of allowing sUASs to operate with significant 

safety precautions in low risk environments. 

The use of sUASs can significantly promote safe and effective Project Site survey and 

inspection. sUASs can inspect, photograph, video and collect data on inaccessible areas 

that otherwise would require worker inspection. sUASs can also provide high resolution 

aerial imagery, elevation measurement, mapping, and thermal imagery data. Reducing 

manned flight and human inspection of such sites through sUAS use for site imaging will 

reduce risk to workers and ground personnel and create an improved safety operating 

environment. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or 

accident. The sUAS GVG Engineering will be using carries no fuel, and therefore the risk of 

fire following an incident or accident due to fuel spillage is eliminated. 

Additionally, sUASs could reduce the use of fixed‐wing aircraft to monitor sites. The sUASs 

GVG Engineering proposes to fly in this application weigh less than fifteen pounds, and carry 

no combustible material on board, as opposed to much larger conventionally powered 

aircraft. The limited weight significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. Lastly, sUASs 

reduce the environmental impact by dramatically decreasing the energy used for aerial 

imaging and data collection over a Project Sites. Operation of lightweight sUASs powered 

by rechargeable lithium ion batteries offers improved efficiencies as compared to the 

operation of other aircraft and vehicles that consume gasoline and present a significantly 

louder noise signature.

TEL 314 246-0422 EMAIL GGLADOV@GMAIL.COM 
CIVIL ENGINEERING - PLANNING - SUSTAINABLE DESIGN

IV. EQUIVALENT LEVEL OF SAFETY 

GVG Engineering proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These limitations 

provide for at least an equivalent or even higher level of safety to operations under the 

current regulatory structure. GVG Engineering will be bound by the following limitations 

when conducting its sUAS operations under this FAA issued exemption: 

 1. The sUAS will weigh less than 15 pounds. 

 2. Flights will be operated within visual line of sight of a pilot and/or observer. 

 3. The sUAS will operate during daylight‐only times (official sunrise to official sunset, 

local time. 

 4. The sUAS will yield right‐of‐way to other aircraft at all times. 

 5. The sUAS will be registered with the FAA and will include appropriate markings and 

labels 

on the body of the sUAS. 

 6. Maximum total flight time for each operational flight will be 25 minutes. The UAS 

calculates battery reserve in real time, and will return to its ground station with at 

least 20% battery power reserve should that occur prior to the 25 minute limit. 

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

 8. Minimum crew for each operation will consist of the trained sUAS Pilot (PIC) who will 

keep the sUAS within his visual line of sight (VLOS) at all times and one visual 

observer (VO). The VO and PIC will be able to communicate verbally at all times. 

 9. The sUAS Pilot will be trained in flight, operations, and safety procedures. 

 10. sUAS Pilot will be Pilot in Command (PIC). 

 14. The sUAS will not be operated at a distance from clouds less than 500' below or 

2000' horizontal, or when visibility is less than 3 miles.

 15. Holder will follow the manufacturer’s UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements.

 16. Pilot will have been trained in operation of the sUAS and receive up‐to‐date 

information on the particular sUAS to be operated should updates become 

available. 

TEL 314 246-0422 EMAIL GGLADOV@GMAIL.COM 
CIVIL ENGINEERING - PLANNING - SUSTAINABLE DESIGN

 17. If the sUAS loses communications or loses its GPS signal, it will have the capability 

to automatically and safely return to a pre‐determined location within the Security 

Perimeter and land with a predictable, automated flight maneuver.

 18. The radio frequency spectrum used for operation and control of the UAS will comply 

with the rules and regulations of the Federal Communications Commission (FCC). 

DESCRIPTION OF SPECIFIC REGULATIONS

14 C.F.R. §61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command 

Sections 61.113 (a) & (b) limit private pilots to non‐commercial operations. GVG Engineering 

proposes that its sUAS PIC will have completed a minimum 2‐Day Training Program and at 

least 25‐Hours of flight time in a safe and controlled environment prior to operating the sUAS 

on a Project Site. The airmanship skills necessary to operate the sUAS do not correlate 

significantly to the airmanship skills necessary for piloting manned aircraft and, thus, 

exemption from the need for the PIC to hold a commercial pilot certificate is also requested. 

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely 

controlled with no living thing on board. The risks associated with the operation of the sUAS 

are so diminished from the level of risk associated with commercial operations contemplated 

by Part 61 when drafted, that allowing operations of the sUAS as requested with a private 

pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

B. 14 C.F.R. §91.103: Preflight action 

This regulation requires each pilot in command take certain actions before flight to insure the 

safety of flight. An exemption is needed from this requirement as the PIC will take separate 

preflight actions, including checking for weather conditions, checking flight battery 

requirements, checking takeoff and landing distances, etc. 

C. 14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. This exemption is for a multi‐rotor craft that flies similarly to a 

helicopter, with vertical take‐off and vertical landing, which will operate at altitudes up to 

400' AGL, so an exemption may be needed to allow such operations. As described in the 

Manual, the sUAS will never operate at altitude higher than 400' AGL and will be limited to 

the area with the security perimeter, where buildings and people will not be exposed to 

operations without their notification as described herein. The equivalent level of safety will be 

achieved given the size, weight, speed of the sUAS as well as the location where it is 

operated. Compared to flight operations with aircraft or rotorcraft weighing far more than the 

maximum 15 lbs. proposed herein and flammable fuel, any risk associated with GVG 

Engineering operations is far less than those presently presented with conventional aircraft. 

In addition, the low‐altitude operations of the sUAS will ensure separation between these 

sUAS operations and the operations of conventional aircraft that must comply with Section 

91.119. 

TEL 314 246-0422 EMAIL GGLADOV@GMAIL.COM 
CIVIL ENGINEERING - PLANNING - SUSTAINABLE DESIGN

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

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set "...to the elevation of the departure airport

or an appropriate altimeter setting available before departure." As the sUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An 

equivalent level of safety will be achieved by the operator, pursuant to The Addendum and 

Safety Check list, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. 

E. 14 C.F.R. §91.151 (a): Fuel requirements for flight in VFR conditions 

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. GVG 

Engineering's sUAS is limited has a limited range and flight time which require an exemption 

from 14 C.F.R. 91.151(a). 

The battery powering the sUAS provides approximately 25 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 C.F.R. §91.151.and considering the limitations 

on the sUAS's flight area and the location of the operations, a longer time frame for flight in 

daylight or night VFR conditions is reasonable. 

GVG Engineering believes that an exemption from 14 C.F.R. §91.151(a) falls within the scope 

of prior exemptions. Operating the sUAS, in a controlled area with less than 30 minutes of 

reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the sUAS. 

An equivalent level of safety can be achieved by limiting flights to 25 minutes, or enough 

battery reserve to ensure that the sUAS lands at the ground station with at least 20% of 

battery power (as determined by the onboard monitoring system and PIC), whichever 

happens first. Because of the limited operating area under which sUAS flights will be 

conducted, this restriction will be more than adequate to ensure return of the sUAS to its 

planned landing zone. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673, and 10808. 

F. 14 C.F.R. §91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections 

These regulations require that an aircraft operator or owner "shall have that aircraft 

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

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter...," and others shall inspect or maintain the aircraft in 

compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an Airworthiness

Certificate, these sections will not apply to GVG Engineering. Maintenance will be 

accomplished by the operator pursuant to the flight manual. An equivalent level of safety will 

be achieved because these sUASs are very limited in size and will carry a small payload and 

operate only in authorized areas for limited periods of time. If mechanical issues arise the 

TEL 314 246-0422 EMAIL GGLADOV@GMAIL.COM 
CIVIL ENGINEERING - PLANNING - SUSTAINABLE DESIGN

sUAS can land immediately and will be operating from no higher than 400 feet AGL. 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. Moreover, the 

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

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

———————————

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

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

Applicant seeks an exemption from the following rules: 14 C.F.R. §§ 61.113( a) & (b); 

91.103(b); 91.119; 91.121; 91.151(a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409

; (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (15 lbs. or 

less) for aerial imaging and monitoring of Project Sites. 

Approval of exemptions allowing commercial operations of sUASs to survey, monitor, and 

inspect the Project Sites will enhance safety by reducing risk. Conventional aerial survey and 

inspections by aircraft impacts the environment. In contrast, a sUAS weighing fewer than 15 

lbs. and powered by batteries eliminates virtually all of that risk and environmental impact 

given the reduced mass and lack of combustible fuel carried on board. 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 sUASs, weighing less than 15 lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the 

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

Part 21 and allowing commercial operations. These lightweight aircraft operate at slow 

speeds, close to the ground, and as a result, are safer than conventional operations 

conducted with fixed‐wing aircraft operating in close proximity to the ground and people. 

Privacy 

All flights will occur over the Project Sites. The notification signs will be posted notifying the 

Project Site personnel of the sUAS flyover. 

******** 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012—size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security ‐ provide more than adequate justification for the 

grant of the requested exemptions allowing commercial operation of applicant's sUASs.

Sincerely, 

Greg V. Gladov, PE, LEED AP BD+C

TEL 314 246-0422 EMAIL GGLADOV@GMAIL.COM