December 10, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Amendment to Section 333 Exemption 11957 issued on the Federal Aviation Regulations in 

Regulatory Docket No. FAA-2015-1401.

Dear Sir or Madam:

DronEye Imaging LLC. was issued an Exemption numbered 11957 (hereinafter the

Exemption) for the purpose of aerial photography, cinematography, videography, mapping, 

crop surveying, and inspections. DronEye Imaging LLC requests an amendment to the 

exemption to allow relief from the restriction #25 which states: 

25. The UAS may not be operated by the PIC from any moving device or vehicle.

DronEye Imaging LLC. wishes to operate the approved UASs listed in our exemption (as well as 

the UASs currently under application for amendment to our exemption) under the same 

conditions contained in the exemption, only allowing a very limited application of use from a 

land based moving vehicle. 

We have been approached by multiple road and excavating contractors to document road and 

excavation progress by flying miles of road construction projects monthly and/or bimonthly in 

order to accurately document the progress of such projects. DronEye Imaging wishes to use a 

moving vehicle traveling at low speeds along the path of the road construction and fly the 

drone either manually or utilizing the “follow me” feature, which allows the UAS to follow the 

controller wherever it goes. By utilizing this technology, the active “home point” is dynamic, 

and follows the location of the GPS enabled mobile device that is connected to the UAS, 

thereby safely allowing this type of activity without risking a “return to home” event near the 

takeoff location should a lost link event occur. The technology for this application is changing 

rapidly and DronEye Imaging believes the necessary safety precautions are not feasible to allow 

the limited use of this function commercially and without undue burden or safety risk to the 

general public. 

DronEye wishes to conduct this type of activity, following all other requirements of our 

exemption, and utilizing the following restrictions for relief of line item 25:

1. Maximum speed of the UAS to be 20 mph

2. PIC in moving vehicle to always have direct line of sight of the UAS, as well as the visual 

observer to also always have line of site view of the UAS
3. A third person is required to drive the vehicle exclusively and that person cannot serve 

as the visual observer

4. PIC, vehicle, and the visual observer to never be more than 200 feet away from the UAS

5. UAS to never be operated or flown directly over the roadway in question, rather, always 

to the left or right of the road to prevent any unwanted altitude loss event to affect any 

other moving vehicle in the roadway

6. Minimum altitude of the UAS to be 150’ AGL and maximum altitude to be 200’ AGL at all 

times

DronEye Imaging operates its UASs with the utmost regard for safety and believes this to be a 

reasonable request that would not put any person, vehicle, building or other structure at risk of 

damage or harm. We respectfully request that the FAA consider our request that would help 

the general road construction industry better understand the full progress of its projects and 

potentially identify ways to speed up such public projects. 

Please contact the undersigned should you have any questions concerning this request

for amendment to the Exemption. Thanks in advance for your time in this request and we look 

forward to your response. 

Sincerely,

Brian A. Pfaehler

DronEye Imaging LLC

5127 S 200 W

Trafalgar, IN 46181

Tele: (317) 443-7013