Richard G Blann 

Owner Waters Edge Virtual Tours, LLC 

1500 Calming Water Dr Unit 3804 

Fleming Island, FL 32003

December 27, 2015

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590

RE: Petition For Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation 

Regulations from 14 C.F.R. Part 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 

91.409(a)(1)&(2); 91.417(a)&(b)

To whom it concerns,

I, Richard G Blann, Owner of Water’s Edge Virtual Tours, a Real Estate Photography Company, am

writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained 

within 14 C.F.R. 11, to request that I, operator of small unmanned aircraft such as the DJI Inspire 1, be 

exempted from the Federal Aviation Regulations (“FARs”) listed below so that on behalf of my company 

Water’s Edge Virtual Tours, I may operate ultra-lightweight unmanned aircraft systems (“UAS”) 

commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

I intend to use a DJI Inspire 1 with a High Definition still and video camera for aerial 

photography/videography/cinematography to enhance community awareness for those individuals and 

companies unfamiliar with or desiring a unique perspective of the geography of the community; and 

augmentation of real estate listing photos and videos following exemption and approval by the FAA, 

thereby enhancing their research for the area being reviewed.

This exemption request would permit operation of ultra-lightweight, unmanned (piloted by remote 

control) UAS(s) in a tightly controlled environment for preplanned flights in areas away from the general 

public, airports, heliports and vehicular traffic for community videos and within property boundaries for 

real estate listing videos/photos. 

I have developed the appropriate safety protocols and controls to prevent hazards to the public as well 

as manned aircraft. If deemed appropriate, use of these safety protocols is encouraged to further the 

safe utilization of ultra-lightweight UAS's specific to real estate video and photography usage as I will 

retain recorded flight data and other information gained through permitted flight operations to share 

with the FAA through any reports the FAA may request to assist with safety regulation. 
Granting my request comports with the Secretary of Transportation’s (FAA Administrator’s) 

responsibilities and authority to not only integrate UAS's into the national airspace system, but to

“...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace 

system” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate purposes. 

Further I will conduct my operations in compliance with the protocols described herein or as otherwise 

directed by the FAA. 

For reasons stated below I respectfully request the grant of an exemption allowing me to operate ultralightweight, remote controlled UAS’s for community awareness to benefit/stimulate attraction to our 

business market area and to enhance real estate listing videos for owners who cannot afford expensive 

manned aircraft for the same purpose. Both of these purposes promote local economic growth through 

increased employment and increased tax base. Additionally, the public’s safety is kept in mind by 

avoiding the use of heavier manned aircraft containing combustible fuel posing a potential public 

hazard. 

I. Contact Information:

Richard G Blann 

Owner Water’s Edge Virtual Tours 

1500 Calming Water Dr Unit 3804 

Fleming Island, FL 32003

Mobile: (904) 631-1150

Email: rich@watersedgevirtualtours.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Richard G Blann 

Requests Exemption are: 

14 C.F.R. 91.7(a) 

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) 

14 C.F.R. 91.409(a) (1) & (2); and, 

14 C.F.R. 91.417(a) & (b).

III. The Extent of Relief Richard G Blann Seeks and the Reason He Seeks Such Relief: 

I, Richard G Blann, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, 

seeking relief from the applicable FARs prohibiting me from performing commercial photographic, 

cinematic, and other flight operations within the national airspace system. The Reform Act in Section 

332 provides for such integration of civil unmanned aircraft systems into our national airspace system as 

it is in the public’s interest to do so. My ultra-lightweight UAS meets the definition of “small unmanned 

aircraft” as defined in Section 331 and therefore the integration of my ultra-lightweight UAS is expressly 

contemplated by the Reform Act. 
I am requesting this exemption to permit the operation of an ultra-lightweight UAS prior to the time 

period which the Reform Act requires the FAA to promulgate rules governing such craft. Approval of my 

request will provide direct experience and valuable data for implementation of regulations administered 

uniformly to all real estate related UAS aerial video and photography. 

The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our 

national airspace system. Considerations include: The weight, size, speed and overall capabilities of the 

UAS's; whether the UAS will be operated near airports or heavily populated areas; and, whether the UAS 

will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items aligns with my request for 

exemption. The DJI Inspire 1 utilizes four (4) counter-rotating propellers for balance, control and 

stability. The DJI Inspire 1 UAS is equipped with GPS and auto return safety technology. Weighing less 

than ten (10) pounds (far below the maximum 55-pound limit), including camera and gimbal mount. 

I consider safety foremost with each flight. The DJI Inspire 1 UAS is designed to hover in place via GPS 

and operate in relatively calm wind conditions. For safety and stability flight operations will not be 

conducted when winds exceed 10 knots. Built-in safety systems include a GPS mode allowing the DJI 

Inspire 1 UAS to hover in place when remote controls are released. 

Flight operations will utilize the “Ready To Fly” mode for aerial videography/photography. “Ready To 

Fly” restricts flight to programmed Special Area Limits, Max Height and Max Radius, further enhancing 

safety of operations and stability while preventing accidents and hazards. When pilot communication is 

lost the DJI Inspire 1 UAS is designed to return to the point of takeoff. 

My Exemption request would allow flight operations up to 200’ AGL outside of a 3 mile radius from 

towered airports and 2 mile from non-towered airports; outside of a 5 mile radius from any airport, 

maximum flight operating altitude will be 400’ AGL. I recognize previous exemptions have been granted 

prohibiting flight operations within 5 nautical miles of an airport. The control facility of any towered 

airport will be notified in advance of any operations falling within the control zone. I believe this is a 

reasonable request that will prevent hazards to aircraft and property while serving the community.

Flight operations will not be conducted over densely populated or congested areas, and at least 500’ 

from non-participating people, vessels, vehicles and structures. Constant vigilance will be maintained 

for any manned aircraft and the petitioner will be prepared to land/abort immediately to the nearest 

and safest ground point should a manned aircraft approach, or appear to approach the area of flight 

operations.

The DJI Inspire 1 UAS is capable of vertical and horizontal operations, and will be flown only within a 

visual line of sight. Utilizing battery power rather than combustible fuels, flights are generally expected 

to last no more than 10-15 minutes, utilizing 40 to 60% of the DJI Inspire 1’s battery capacity. Each flight 

will utilize a fresh, fully charged battery; full flight time limit for each battery is 25 minutes as tested. The 

UAS will not be operated below 40% of battery charge levels to maintain a safe operating reserve, 

ensuring adequate communication between the PIC remote control and the UAS. Reserve batteries are 

on hand for each flight to ensure an adequate source of power is available to safely complete each 

operation.

I intend to be extremely cautious when operating the aircraft and have no intention of creating a hazard 

to other aircraft, property or persons when operating the DJI Inspire 1 UAS/ultra-lightweight unmanned 

aircraft. My flight operations will not “create a hazard to users of the national airspace system or the 

public.” 112 P.L. 95 § 333 (b). Given the small size and weight of the DJI Inspire 1 UAS, it falls well within 
Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding 

directive to integrate UAS’s into the national airspace system. 

IV. How This Request Will Benefit the Public As A Whole: 

Aerial videography for geographical awareness and real estate marketing has been around for decades 

through manned fixed wing aircraft and helicopters. For small real estate companies and average 

homeowners the expense of such aerial videography is cost prohibitive. Typically upscale Realtors or 

luxury homeowners are in a position to afford such an expense. As a result, the expense of manned 

aerial photography deprives many homeowners and smaller Realtors of a valuable marketing tool.

Congress has proclaimed it is in the public’s interest to integrate commercially flown UAS's into the 

national airspace system, hence the passing of the Reform Act. Granting my exemption request furthers 

the public interest through visual awareness of the geographical benefits in and around the markets I 

serve. The DJI Inspire 1 ultra-lightweight UAS is battery powered and creates no emissions that harm the 

environment. 

The public’s interest is furthered by minimizing potential ecological damage by permitting aerial 

video/photo capture through the DJI Inspire 1 battery operated ultra-lightweight UAS. Permitting me to 

immediately fly within the national air space system furthers economic growth. Granting my exemption 

request substantially furthers the economic impact for the community I serve by assisting companies 

considering our market for relocation or building, as well as individuals relocating for career 

advancement by providing our aerial photographic services and improving geographical awareness. Both 

aspects serve as a stimulus to the community.

V. Reasons Why This Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide 

a Level of Safety At Least Equal To Existing Rule:

My exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me 

to log flight time in FAA controlled airspace, communicate with the FAA, and allow me to contribute to 

the innovation and implementation of new safety protocols. In addition I submit the following 

representations of enhancements to current aerial videography and photography for real estate: 

The DJI Inspire 1 UAS weighs less than 10 pounds with max payload, high definition video camera and 

gimbal mount; 

Flight operations will be limited to a maximum height of 400’ AGL outside of a 5 nautical mile radius of 

any airport; 

Flight operations will be conducted for the DJI Inspire 1 UAS a maximum of 15 minutes per flight; 

The DJI Inspire 1 UAS will be landed prior to manufacturer recommended minimum level of battery 

power; 

The DJI Inspire 1 UAS will be operated through remote control by visual line of sight; 

The DJI Inspire 1 UAS has a GPS flight safety fail-safe feature whereby it returns to its point of takeoff 

and lands if communication with the remote control pilot is lost; 

Flight data and other sources of information are continually reviewed to update and enhance safety 

protocols; 
Flight operations will be conducted in a safe manner and tightly controlled environment, away from 

power lines, elevated fixtures, structures and lights, airports and congested and densely populated 

areas; 

Extensive pre-flight inspections along with weather and risk assessments are conducted prior to each 

flight, the objective being execution of a safe flight operation being the first priority; 

All necessary permissions and notification will be obtained prior to operation; 

Finally, procedures are established to abort flights in the event of safety breaches or potential danger.

My safety protocols provide a level of safety equal to or greater than existing rules. It should be 

important to note that absent the integration of commercial UAS into the national airspace system, 

helicopters are the primary means of aerial video and photography for community education and real 

estate marketing. While the overall safety record of such helicopters may be satisfactory, the exposure 

to the risk involved, potential loss of life and substantial property damage cannot be ignored; it is far 

safer to operate a battery powered ultra-lightweight UAS. 

First, the potential loss of life is diminished because UAS's carry no passengers or crew on board and 

flight operations are conducted away from densely populated areas. Second, with no combustible fuel 

on board a UAS, the potential for fire or explosion is eliminated. Third, the small size and extreme 

maneuverability of the DJI Inspire 1 UAS enables quick and safe avoidance of hazards. 

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary airworthiness certificates in relation to FAR § 

91.203(a)(1). The size, weight and limited operational area of the DJI Inspire 1 UAS permits exemption 

from Part 21 because the UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 

of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces 

of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in 

consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and 

dense populations. The DJI Inspire 1 UAS meets or exceeds each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no onboard pilots or 

passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety

will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. 

The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings are inapplicable insofar as the DJI Inspire 1 UAS utilizes 

electronic global positioning systems with a barometric altimeter sensor. 
14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. 

They are inapplicable for the same reasons described above. 

B. 14 C.F.R. § 45.23: Marking of The Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. 

The DJI Inspire 1 UAS is, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot 

station on which to mark certain words or phrases. Further, two-inch lettering is difficult to place on 

such small aircraft with dimensions smaller that minimal lettering requirement. The FAA has previously 

issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. 

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. 

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations but the

DJI Inspire 1 UAS does not carry any pilots or passengers. 

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be 

operated at lower altitudes in certain conditions. The DJI Inspire 1 UAS will never operate at an altitude 

greater than 400’ AGL. I will operate the DJI Inspire 1 UAS safely, away from densely populated and 

congested areas, providing a level of safety equivalent to or in excess of those in relation to minimum 

safe altitudes. Given the size, weight, maneuverability and speed of the DJI Inspire 1 UAS an equivalent 

or greater level of safety will be achieved. 

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

The above-cited Regulations require, amongst other things, aircraft owners and operators to “have [the] 

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....” 

These Regulations apply to aircraft with an airworthiness certificate. They will not, therefore, apply to 

the DJI Inspire 1 UAS. As a safety precaution, I will perform a thorough preflight inspection of the DJI 

Inspire 1 UAS just as I would any aircraft I am PIC of before each flight.

In summary, Richard G Blann seeks an exemption from the following Regulations:

14 C.F.R. § 91.7 (a); § 91.109; 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. § 91.409 (a ) (2); and, 14 C.F.R. §§ 

91.417 (a) & (b) to commercially operate the DJI Inspire 1 UAS, small unmanned vehicle/lightweight 

unmanned aircraft vehicle in community awareness and real estate operations, and to develop 

economic platforms for real estate to enhance the experience of those seeking to relocate to the 

markets my business services. 

Currently, geographic area awareness and real estate aerial videography/photography relies primarily 

on the use of larger aircraft carrying significant quantities of, and running on combustible fuel, posing 

potential risk to the public. Granting my request for exemption will reduce current risk levels and 

thereby enhance safety. The DJI Inspire 1 UAS does not contain potentially explosive fuel, is smaller, 

lighter and more maneuverable than conventional real estate video and photographic aircraft and 

achieves aerial objectives in much less flight time. 
Further, by operating at lower altitudes and in controlled airspace, the potential public risk is avoided 

without the need to fly to and from established airfields. I will compile safety protocols and the 

implementation of a flight operation’s manual for real estate usage that exceeds currently accepted 

means and methods for safe flight. 

Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish 

protocols for complying with the FAA Modernization and Reform Act of 2012. Since there is no crew or 

passengers aboard a UAS, the likelihood of death or serious bodily injury is minimized. My operation of 

the DJI Inspire 1 UAS, weighing less than 10 pounds and travelling at lower speeds within limited areas 

will provide an equivalent level of safety as that achieved under current FARs. Accordingly I respectfully 

request the FAA grant my exemption request and am willing to cooperate in sharing information to 

benefit the FAA, safety of manned aircraft, and the general public at large.

Petitioner’s Proposed Conditions and Limitations

The following documents provided by the petitioner –

1) DJI Inspire 1 User Manual v1.8,

2) DJI Inspire 1 Quick Start Guide,

3) Smart Flight Battery Safety Guidelines, 

4) DJI Inspire 1 Pilot Training Guide v1.1,

5) UAS Safety & Flight Operating Procedures, hereinafter referred to as operating documents. 

Petitioner agrees that failure to comply with any of the conditions and limitations of the requested 

exemption is grounds for the immediate suspension or rescission of this exemption. 

1) Operations authorized by this grant of exemption are limited to the quad-rotor aircraft DJI Inspire 1

Unmanned Aircraft System. 

2) The UAS will not be flown in excess of 40 knots. 

3) The UAS will be operated at an altitude of no more than 200’ AGL outside of a 3 nautical mile radius 

from towered airports and 2 nautical miles from non-towered airports, maximum flight operating 

altitude will be 400’ AGL. All altitudes will be reported to ATC in feet AGL. 

4) The UAS will be operated within visual line of sight (VLOS) of the Pilot In Command (PIC) at all times. 

This requires the PIC to be able to use human vision unaided by any device other than corrective lenses.

5) The operating documents and the grant of exemption will be accessible during UAS operations and 

made available to the Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, the conditions 

and limitations herein take precedence and must be followed. Otherwise, the operator will follow the 

procedures as outlined in its operating documents. The operator may update or revise its operating 

documents. It is the operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator upon request. The operator will also present updated and revised 

documents if he petitions for extension or amendment to this grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the FAA granted this 

exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the 

operating documents. 
6) Prior to each flight, the PIC will inspect the UAS to ensure it 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. The Ground Control Station will be included in the preflight inspection. All maintenance and 

alterations will be properly documented in the aircraft records. 

7) Any UAS maintenance or alterations affecting the UAS operation or flight characteristics, e.g. 

replacement of a flight critical component, will undergo a functional test flight. The PIC conducting the 

test flight will make an entry in the aircraft records. 

8) The pre-flight inspection section in the operating documents will account for all discrepancies, i.e. 

inoperable components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

9) The operator will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

10) The operator will carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, and alterations will be noted in 

the aircraft records, including total flight hours, description of work accomplished, and the signature of 

the authorized person returning the UAS to service. 

11) Any UAS operated under this exemption will comply with all manufacturer Safety Bulletins. 

12) The authorized person will make an entry in the aircraft record of the corrective action taken 

regarding discrepancies discovered between inspections. 

13) UAS operations will be conducted by a PIC possessing a commercial pilot certificate and at least a 

current third-class medical certificate. The PIC will also meet the flight review requirements specified in 

14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14) Prior to operations conducted for the purpose of aerial videography/cinematography and 

augmenting real estate listing videos (or similar operations), the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft 

pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior documented flight 

experience that was obtained in compliance with applicable regulations may satisfy this requirement. 

Training, proficiency, and experience-building flights may also be conducted under this grant of 

exemption to accomplish the required flight time. However, training operations will only be conducted 

during dedicated training sessions. During training, proficiency, and experience-building flights the PIC 

will operate the UAS with appropriate distances in accordance with 14 CFR 91.119. 

15) Prior to operations conducted for the purpose of aerial videography/cinematography and 

augmenting real estate listing videos (or similar operations), the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the make and 

model of the UAS to be used in operations under the exemption; 5 hours make and model time may be 

included in the 10 hours of multi-rotor time prescribed above. The PIC will accomplish 3 take-offs and 

landings in the preceding 90 days (for currency purposes). Training, proficiency, experience building, 

and take-off and landing currency flights can be conducted under this grant of exemption to accomplish 

the required flight time and 90 day currency. However, said training operations will only be conducted 
during dedicated training sessions. During training, proficiency, and experience-building flights the PIC 

will operate the UA with appropriate distances in accordance with 14 CFR 91.119. 

16) The PIC will not operate the UAS for the purpose of aerial videography/cinematography and 

augmenting real estate listing videos (or similar operations), unless the PIC has demonstrated and 

logged in a manner consistent with 14 CFR 61.51(b), 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 people, vessels, vehicles and structures. 

17) UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will be 

conducted under visual meteorological conditions (VMC). 

18) The UAS will not operate within 5 nautical miles of a towered airport and 3 nautical mile of a nontowered airport reference point as denoted on a current FAA-published aeronautical chart. 

19) The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC. 

20) If the UAS loses communications or loses its GPS signal, it will return to a pre-determined location 

within the planned operating area and land or be recovered in accordance with the operating 

documents. 

21) The PIC will abort the flight in the event of unpredicted obstacles or emergencies in accordance with 

the operating documents. 

22) The PIC will not initiate a flight unless (considering wind and forecast weather conditions) there is 

enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% 

battery power remaining. 

23) The operator will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under a grant of exemption. This COA also 

requires the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but 

not less than 48 hours prior to the operation. 

24) All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N- Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

25) Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA will comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

26) The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground 

Control Station of the UAS any time the UAS is operating. These documents will be made available to the 

Administrator or any law enforcement official upon request. 

27) The UAS will remain clear and yield the right of way to all manned aviation operations and activities 

at all times. 

28) The UAS will not be operated by the PIC from any moving device or vehicle. 
29) The UAS will not be operated over congested or densely populated areas. 

30) Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UAS and/or debris in the event of an accident. The operator will 

ensure nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations will 

cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such 

vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the 

risk of operating closer to those objects and determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, operator trainees or essential persons do not present an undue hazard 

to those persons per § 91.119(a). 

31) All operations will be conducted over private or controlled-access property with permission from the 

land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight to be conducted. 

32) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office 

(AFS-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov.

Contact me at: (904) 631-1150 or rich@watersedgevirtualtours.com if you have any questions or 

require additional information.

Thank You, 

Richard G Blann

Owner: Water’s Edge Virtual Tours, LLC