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thanks, that will be a tricky one, I would guess that the element will have to rotate.
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fdog:If it's Photoshopped, it usually looks like it was pasted together. The interface is part of the art, like Mauricio's work here. Or the subject is connecting the air & water (usually why you're shooting over/under, anyway) like this image by Mr. Frink.
I'd be leary of just shooting away and counting on PhotoShop to fix the exposure. Blown highlights are gone forever.
All the best, James
Mike Veitch:Hi Dave,
The best way is to use a WA lens on a SLR camera. The key thing is to use a diopter on the lens. This diopter is a little darker on the top so that you can get the same exposure on the sky and underwater portions.
The trick is to get the waterline to cover up the split.
BEst done when you can stand in the water as opposed to free swimming.
As for digital point and shoots and things it can work, just have to mess with the exposures quite a bit whilst using a wide angle port