Richard G Blann

Owner Waters Edge Virtual Tours, LLC 1500 Calming Water Dr Unit 3804 Fleming Island, FL 32003

December 2 7 , 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; 9**  **1.121; 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 Virtua l 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 photograp hy/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 exempti on 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 fli ghts 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 ha zards 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 flig ht 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 Administrato r’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 Refo rm 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 ultra

lightweight, 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 ca nnot 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 ai rcraft 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 Whi ch 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).
**I II. 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 perform ing 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 exempt ion 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 r egulations 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 airp orts 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 a nd 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 In spire 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, furt her 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’ A GL 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 man ned 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 horiz ontal 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. E ach 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 b etween 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 intenti on 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 withinCongress’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 T his 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 thro ugh 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 a ffect 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 t he 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 limi ted 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 recomme nded 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 assessment s 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 flight s 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, he licopters 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 substa ntial 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 ai rworthiness 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 o f 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 airwo rthiness 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 operat ion 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 ther e 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 e lectronic 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 Exe mptions 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 ca rry 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 In spire 1 UAS will never operate at an altit ude 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

- cit ed 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 discrepa ncies 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 veh icle 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 ae rial 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 ther eby 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.Furt her, 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 und er 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 imm ediate 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 4 0 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 gr ant 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 con ditions 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 dete rmines 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 reg arding 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 docume nted 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 ma ke 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 docum ents. 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 servic e. 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 PI C 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 cons istent 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 regulati ons 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 train ing 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 und er 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 build ing, 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 conductedduring 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, incl uding 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 mete orological conditions (VMC). 18) The UAS will not operate within 5 nautical miles of a towered airport and 3 nautical mile of a non

towered airport reference point as denoted on a current FAA

- published aeronautical chart. 19) The UAS will not be operat ed 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 t he 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 o btain 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 a dvance, 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 acco rdance 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 o r 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 ar e 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 hazar d 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 represent ative 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