1 U.S. Department of Tran spo rtation Docket Management System 1200 New Jersey Ave., SE Washington, D

. C. 20590 Submitted via El ectronic Docket Petition System

Re: Petition of Matthew Wenzlau dba WLG Aerial for Exemption from Certain Federal Aviation Regulations to Operate Unmanned Aircraft Syst ems Pursuant to Section 333 of the FAA Modernization and Reform Act

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act (“FMRA” ) and 14 C.F.R. part 11, Matthew Wenzlau dba WLG Aerial (“ WLG ” ) hereby petitions the Fe deral Aviation Administration (“FAA” ) for exemption from 14 C.F

. R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 6 1.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.15l(a)(l), 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417( a) and (b), and any other rule s the FAA deems necessary, to

en ab le WLG to operate unmanned aircraft systems (“UAS” ) for aerial imagery collection. Specifically, WLG seeks to operate UAS for imagery collection , commercial production, and motion picture/photography production using the DJI Phantom 2, DJI Phantom 3 , and the DJI In sp ir e 1. Becau se this petition is similar in all material respects to other previou s ly

- granted Section 333 petitions, WLG request s expedited approval pursuant to the FAA’ s summary grant process.

I. PROPOSED OPERATIONS AND PUBLIC INTEREST BENEFITS

WLG
, a local media and content creation company , will be providing production marketing , and imagery solutions to various family

- owned entertainment companies

, motion picture production companies, and digital content creation companies in Arizona

WLG st rive s to provide high production and low cost solutions to local businesses that seek to provide their services and products to the residents of Arizona in a cost

- effective manner. As most of the current client ele seeking aerial footage are middle

- income family owned businesses, the cost reduction provided by WLG Aerial will afford these family owned businesses the ability to effectively carry on operations within a reasonable budget

.

UAS can provide a safe and cost

- effective way to achie ve this objective. WLG seeks to use UAS to conduct aerial imagery collection that will serve a variety of functions, including imagery gathering, commercial production, and other aerial inspection. Grant of this petition will enable WLG to better serve its viewers and clientele

, as WLG will be able to o btain key aerial footage for visual stories and other content and operate its business more safely, efficiently, and effectively than ever before.

Professional and Usable f ootage for c ontent creation via aerial footage is a central component of WLG 's intended use of UAS. To help businesses market their content be tter and make more educated business decision s , various perspectives of the filmed object s or persons is crucial, highly valuable , and lacks affordable substitutes

. Permitting WLG to use UAS will result in better content footage and safer imagery collection

.2 Through their geographic reach and unique views, UAS can provide a perspective that footage taken from the gr ound cannot, enhancing viewers' ability to gain information from news stories. Moreover, UAS can improve the accuracy and depth of information that WLG can convey to the public for better decision

- making and higher quality content . Authorization to operate UAS will enable WLG to provide information and imagery to the public that is otherwise unavailable given existing barriers, such as those created by environmental hazards. Using UAS, WLG can ensure the safety of its crewmembers while also gathering crucia l information for its viewers.

Pursuant to this authorization, WLG will conduct additional operations allowing it to bring content to its viewers more safely, efficiently, and effectively. First, several WLG is involved in the production of co mmercial and marketing content. WLG will use UAS to safely and efficiently obtain interesting aerial footage that will enhance this content and provide a unique perspective to viewers.

II. THE UAS

WLG requests an exemption to operate th e DJI Phantom 2, DJI Phantom 3, and the DJI Inspire 1, all of which are below 55 pounds including payload. Through the Section 333 exemption process, the FAA has authorized use of all UAS for which exemption is requested herein. 1

III. REQUEST FOR SUMMARY GRANT

Because this petition is similar in material respects to previous petitions the FAA has granted, WLG requests that the FAA issue a summary grant of exemption pursuant to the agency's expedited summary grant process. Specifically, the public interest and safety benefits WLG 's operations will achieve are materially similar to those recognized in Grants of Exemption Nos. to Astraeus Aerial (see Docket No. F A A

- 2014

- 0352), to Clayco, Inc. (see Docket No. FAA

- 2014

- 0507), to VDOS Glo bal, LLC (see Docket No. FAA

- 2014

- 0382), and to Aeryon Labs, Inc. (see Docket No. FAA

- 2014

- 0642). WLG will adhere to a series of operating parameters that will offer the same level of safety as the conditions the FAA currentl y requires in its summary grants. 2

IV. APPLICANT INFORMATION

The name and contact information of the applicant is:

Matthew Wenzlau dba WLG Aerial

1 See Exemption No. 11274A to United Services Automobile Association, Regulatmy Docket No. FAA

- 2014

- 0796 (authorizing
use ofthe 3DR Solo, DJI Phantom 3, and DJl I nspire); Exemption No. 11875 to Green Bee Limited, Regulatory Docket No.

FAA

- 20 15

- 0698 (authorizing use of the DJI Phantom 2); Exemption No. 12023 to William J. Henderson, Regulatory Docket No.

FAA

- 2015

- 1518 (authorizing use of the Yuneec Q500 Typhoon).

2 See, e.g., Exemption No. 12160 to Star Engineering Services LLC, R egulator y Docket No. FAA

- 2015

- 1690 (Jul. 27, 2015).3 8644 East Keim Drive Scottsdale

, AZ 85250 T: 480

- 286

- 7144 F: 480

- 659

- 2987 E: info@arizonamusiclaw.com

Regulations from which exemption is requested:

14 C .F.R. §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 61.315(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b).

V. OPERATING PARAMETERS

WLG will adhere to the following operating parameters when operating UAS pursuant to a grant of the requested exemption:

1. Operations will be conducted using th e DJI Phantom 2, DJI Phantom 3, or DJI Inspire 1

.

2. The UAS will not be operated at a spee d exceeding 87 knots (1 00 miles per hour), at an altitude greater than 400 feet above ground level, or, when visibility is less than 3 statute miles, less than 500 feet below or 2,000 feet horizontally from a cloud. All operations will be conducted during the day under visual meteorological conditions and in accordance with airport, residential, commercial, and other applicable regulations

.

3. All operations will be conducted in accordance with a Certificate of Waiver or Authorization (“COA” ).

4. All ope ration s will use a pilot

- in

- command (“PIC” ) and a visual observer (“VO” ), and the UAS will remain within the visual line of sight of the PIC or the VO at all times. The PIC will maintain line of sight capability and the ability to communicate verbally with the VO at all times.

5. The PI C will hold a valid U.S. driver ’ s license and/or other required documentation . The PIC will meet any flight review requirements.

6. WLG will ensure prior to operation that the PIC has demonstrated the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distanc es from persons, vessels, vehicles and structure

. PIC qualification flight hours and currency will be logged in a4 manner consistent with 14 C.F.R. § 61.51(b ).

7. WLG’s operating documents will be accessible during UAS operations and made
available to any A dministrator upon request.

8. Prior to each flight, the PIC will conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

9. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, will undergo a functional test flight prior to conducting further operations under this exemption.

10. WLG w ill follow the UAS manufacturer ’ s maintenance, overhaul, replacement, inspection, and life limit requirements, as well as safety bulletins, for the aircraft and aircraft components

11. The PIC will abort the flight in the event of unpredicted obstacles or emergencies, and will yield to all manned aviation activities.

12. WLG has registered ( See Registration Attached) , and will maintain registratio n its UAS in accordance with 14 C.P.R. parts 47 and 45. WLG will mark the UAS as required by such registration.

13. Noting the increasing interest in and regulati on of UAS, WLG will meet or exce ed Federal, State, and Local requirements.

V I. THE FAA ’ S AUTHORITY TO GRANT THIS PETITION

The FAA has authority to grant the exemption requested herein under the FMRA and the Federal Aviation Act. Section 333 of the FMRA deals specifically with integrating UAS into the national airspace, and dire cts the Secretary of Transpor tation to determine which UAS, “ as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the nation al airspace system or the public or pose a threat to national security. ” 3 Section 333 further directs the Secretary to "establish requirements for the safe operation of such aircraft systems in the national airspace system." 4 The Federal Aviation Act auth orizes the Administrator of the FAA to grant exemptions from regulations prescribed under certain provisions of the Act where such exemptions are in the public interest. Part 11 of the Federal Aviat ion Regulations governs the FAA ’ s exe mption process and requirements. The FAA has granted more than 1,100 exemptions

3 Pub. L. No. 112

- 95, 126 Stat. 75

- 76 (codified as a Note to 49 U.S.C. § 40101).

4 Ibid.5 to date pursuant to its Section 333 and exemption authority, enabling commercial UAS operations in a wide variety of industries.

VI I. SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER

Should th e FAA determine that publication in the Federal Register is required, WLG offers the following summary pursuant to section 11.81 of the FAA's rules:

Petitioner: Matthew Wenzlau dba WLG Aerial

Sections o f 14 C.F. R . Affected: 14 C.F.R. §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 61.315(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.15l(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 C. F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b).

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 61.315(a); 14 C.F.R. § 91.7(a); 14C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b) to operate unmanned aerial systems for motion picture production imagery , content production, and facilities inspection.

VIII. CONCLUSION

As demonstrated above, the UAS operations WLG has proposed in this petition for exemption will garner significant public benefits while presenting minimal safety risks. W LG ’ s petition satisfies the criteria of Section 333 of the FMRA and is substantially similar to previous petitions the FA A has gran ted, meriting a summary grant o f exemption. WLG respectfully requests that the FAA grant this petition to enhance WLG s abil ity to provide important media and content to its local businesses

.
Please do not hesitate to contact WLG Aerial’s owner and counsel with a ny questions about this filing :
Matthew Wenzlau, Esq. 8644 East Keim Drive Scottsdale, Arizona 85250 T: 480

- 286

- 7144 F: 480

- 659

- 2987 E: info@arizonamusiclaw.com

Best Regards

,

Matthew B. WenzlauTuesday,	February	9,	2016	at	5:46:21	PM	Mountain	Standard	Time

Page	1	of	2 Subject: FAA	UAS	Cer)ficate

Date: Monday,	January	25,	2016	at	9:12:28	AM	Mountain	Standard	Time

From: UAS.Registry@faa.gov

To: info@arizonamusiclaw.com

Federal Aviation Administration

Small UAS Certificate of Registration

CERTIFICATE HOLDER: Matthew Wenzlau

UAS CERTIFICATE NUMBER: FA3CFWFLX7

ISSUED: 01/25/2016 EXPIRES: 01/25/2019 For U.S. citizens, permanent residents, and certain non-citizen U.S. corporations, this document constitutes a Certificate of Registration. For all others, this document represents a recognition of ownership.

For all holders, for all operations other than as a model aircraft under sec. 336 of Pub. L. 112-95, additional safety authority from FAA and economic authority from DOT may be required.

Safety guidelines for flying your unmanned aircraft:
Fly below 400 feet Never fly near other aircraft Keep your UAS within visual line of sight Keep away from emergency responders Never fly over stadiums, sports events or groups of people Never fly under the influence of drugs or alcohol Never fly within 5 miles of an airport without first contacting air tra ffi c control and airport authorities



# Remember these simple safety guidelines when flying your unmanned aircraft:

Don't be careless or reckless with your UAS
Fly below 400 feet and remain clear of obstacles
Stay away from other aircraft at all times
Keep your UAS within your sight
Don't fly near airports, stadiums, or other people
Don't fly under the influence of drugs or alcohol
Keep away from emergency responders

For more information, visit: www.faa.gov/uas/model_aircraft



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