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U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE Washington, D.C. 20590

Submitted via Electronic Docket Petition System

Re: Petition of Matthew Wenzlau dba WLG Aerial for Exemption from Certain Federal 

Aviation Regulations to Operate Unmanned Aircraft Systems 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 Federal Aviation 

Administration (“FAA”) for exemption from 14 C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 

61.113(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 rules the FAA deems necessary, to 

enable 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 

Inspire 1. Because this petition is similar in all material respects to other previously-granted 

Section 333 petitions, WLG requests 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 strives 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 clientele 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 achieve 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 obtain key aerial footage 

for visual stories and other content and operate its business more safely, efficiently, and 

effectively than ever before. 

Professional and Usable footage for content creation via aerial footage is a central component of

WLG's intended use of UAS. To help businesses market their content better and make more 

educated business decisions, various perspectives of the filmed objects 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. 
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Through their geographic reach and unique views, UAS can provide a perspective that footage 

taken from the ground 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 crucial 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 commercial 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 the 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. FAA-2014-0352), to Clayco, Inc. (see Docket No. FAA-2014-

0507), to VDOS Global, 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 currently 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 Inspire); 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, Regulatory Docket No. FAA-2015- 1690 (Jul. 27, 2015).
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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 the DJI Phantom 2, DJI Phantom 3, or DJI Inspire 1.

2. The UAS will not be operated at a speed 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 operations 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 PIC 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 distances from persons, 

vessels, vehicles and structure. PIC qualification flight hours and currency will be logged in a 
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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 Administrator 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 will 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 registration 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 regulation of UAS, WLG will meet or exceed 

Federal, State, and Local requirements.

VI. 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 directs the Secretary of Transportation 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 national 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 authorizes 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 Aviation Regulations governs the 

FAA’s exemption 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.
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to date pursuant to its Section 333 and exemption authority, enabling commercial UAS 

operations in a wide variety of industries. 

VII. SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER 

Should the 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 of 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. WLG’s petition 

satisfies the criteria of Section 333 of the FMRA and is substantially similar to previous petitions 

the FAA has granted, meriting a summary grant of exemption. WLG respectfully requests that 

the FAA grant this petition to enhance WLGs ability to provide important media and content to 

its local businesses. 

Please do not hesitate to contact WLG Aerial’s owner and counsel with any 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. Wenzlau
Tuesday,	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 traffic

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

B4UFLY Smartphone Additional Resources