Cashman Professional

Attn: David Chadd 3595 S. Highland Dr.

#3 Las Vegas, NV 89103 August 4, 2015

US Department Of Transportation Federal

Aviation Administration 800 Independence Ave SW Washington DC 20591

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modern ization and Reform Ac t of 2012(the reform act) and CFR Part 11, Cashman Professional, owner a nd operator of Small Unmanned Aircraft Systems (UAS), request to be exempted from the Federal Aviation Regulations{FAR) listed below so that Cashman Professional may operate UAS commercially in airspace regulated by the FAA., as long as such operations are conducted within and under the conditions outlined herein or as maybe established by the FAA as required by Section 333.

As described below, the requested ex ception would permit the operation of light weight (less than 55 lbs. total takeoff weight) UAS under c ontrolled conditions for commercial use by an experienced operator thereby enhancing safety and fulfilling the Secretary of Transportation's (the FAA Administrator's) responsibility to" establish requirements for sa fe operation of such aircraft systems in national airspace systems." Section 333(c), of the Reform Act.

Cashman Professional’s UAS is a rotorcra ft weighing less than 55 pounds including payload. (The DJI Inspire 1.) They operate at a speed less than 50 knots and have the capability to hover and move in the vertical and horizontal plan e simultaneously. Both have an auto return to launch point when battery power is under 25%. The UAS w ill operate within the line of sight with

in a protected flight area as desc ribed below and at 200 feet AGL or less with an observer located

close at hand as to make voice comm unication possible. These operations will not create a hazard to users of the nation airspace, public nor the environment.

Cashman Professional respectfully request s the grant of an exception to the following specific sections of the Title 14 C ode of Federal regulations a11owing it to

operate lightweight UAS for commercial use,

14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109, 91.119, 91.121,91.151,(a), 91.203(a) &{b},91.405(a),91.407(a)(1), 91.409(a)&(b).

Cashman Professional submits this applica tion in accordance with the Reform Act, 112 P.L. 95 331-334, seeking relief from any currently ap plicable FAR'S operating to prevent Cashman

Professional future commercial use of small UAS to operate in the national airspace system as described below. The reform Act section 332 provides for such integration of civil unmanned

aircraft into our national airs pace system as it is in the public's interest to do so. Cashman

Professional’s UAS meet the definition of "small unmanned aircraft" as defined in Section 331 and therefor the integration of these UAS are expr essly contemplated by the Reform Act. Cashman

Professional would like to operate its light weight UAS prior to the time period by which the Reform Act requires the FAA to promul gate rules governing such aircraft.The Reform Act directs the Secretary of Tr ansportation to consider whether certain unmanned aircraft systems may opera te safely in national airspace before completion of the rule making required under Section 332 of the reform Act. In making this determination, the Secretary of Transportation is required to determine which UAS do create a hazard to users of the national airspace system or the public or pose a threat to national security in light of the following:

The UAS size, speed, weight and operational capability

Operation of the UAS in close proximity to ai rports and populated ar eas Operation of the

UAS within visual line of sight of the operator

Reform Act 333(a}. If the secretary determines that such vehicles "may operate safely in National Airspace System, the secretary sh all establish requirements for the safe operation in national airspace.

Cashman Professional’s UAS is a rotorcraft weighing less than 55 lbs. and it operates at speeds less than 50 knots and has the capability to operate in the vertical and horizontal plane simultaneously. The UAS will operate only within the line of sight of the operator within a protected flight area and at 200 feet AGL or less. These will not present a hazard to the national airspace nor the public.

The very small nature of thes e UAS combined with the safe guards presented below, will allow for the safe operation greater than that e nvisioned by Congress for the FAA to establish and by exemption allow commercial operations of UAS to commence immediately. Also, due to the size of UAS and the areas and altitudes they will operate approval of this exception presents no national security issues and absolutely minimal sa fety concerns which have been mitigated through our rigorous risk management process. Given the clear direction given in Section 333 of the Reform Act, the authority contained in the Federal Aviati on Act, as amended, the strong equivalent level of enhanced safety, reduced emissions utilizing UAS ve rses traditional aircraft as well as the economic impact of greatly reducing the co st of aerial photography thereby benefiting the greater public's interest. Accordingly, the appli cant requests that the FAA grant the requested exemption without delay.

The following will be considered as the bi nding limitation on operations of Cashman Professional,1. Flights will only occur in the day time hours,

2. Flights will be operated in th e line of sight of the operato r{ PIC) and Observer,(VSO)

3. Flights will be terminated at any time w eather and wind deteriorate to "unsafe for flight" by manufacturers recommendations,

4. The UAS will weigh less than 55 lbs.,

5. Flights will be operated at 200 feet AGL or less.

6. Crew will be at a minimum of operato r(PIC) and an observer and/or camera operator(VSO),

7. Operator and crew will remain in c ontact during the flight operation,

8. The UAS operator will perform a check of the flight area and make certain of the safety of all persons in the area,

9. Consent will be obtained from all persons with in the video capabil ities of the units to

further reduce the chance of violating anyone's privacy.

10. All required FAA clearances, will be obtaine d and distances from airports strictly

observed.

11. All UAS will have the capability to return automatically to the operator in a safe manner with the auto return function checked and working.

12. When operated in conjunction with fishing vessels in the gulf, a chase boat will be assigned to operate the UAS at a safe distance from the main fishing boat.

13. Flights will only operate in VFR conditions.

14. UAS have a function on the control to tell operator the distance away from the operator and its battery power remaining.

15. Flight team will communicate by voice and th e use of two-way radio if the area is too big to hear voice from all team members.

16. UAS will be used to video and capture images at private outings and functions from a

safe distance.

17. The PIC will hold a minimum of a sports pilot license

14 CFR part 21 Subpart H: Airworthin ess Certificate 14 CFR 91.7(a}, 91.203(a)(1) Subpart H, entitled Airworthin ess Certificates, sets forth requirements for procurement of necessary certificates in rela tion to FAR 91.203(a)(1). The size, weight and defined area of operations for Cashman Professiona l UAS flights permits excepti on from Part 21 because they meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft fr om the airworthin ess certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS from airworthiness certificates in consideration of weight, size, speed,maneuverability and proximity to areas such as airports and de nse populations. Cashman

Professional meets or exceeds each of these elements

As of March 23, 2015 the FAA has stated that it will automatically grant a "blanket" COA for flights at or under 200 AGL to any UAS operator with a section 333 exemption. 14 CFR 91.203(a&b) provides for carrying of civil ai rcraft certifications and registrations. These are inapplicable for the same reasons stated a bove. The equivalent level of safety will be achieved by maintaining such certif ications and registrations at Cashman Professional operations

center.

14CFR91. 7 (a) prohibits the operation of an aircraft without an airworthin ess certificate. As no such certificate will be appli cable in the form contemplated by FAR's this regulation is inapplicable.

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft

14 CFR 91.9(b)(2) requires an airc raft flight manual in the aircra ft. As there are no pilots or passengers, and given the size of th e UAS this regulation is inapplic able. An equivalent level of safety will be achieved by maintaining such certifications and registrations at Cashman Professional operations center.

The FAA has previously issued exemptions to this regulation in Exemptions No's 8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and 32827. 14 CFR 91.119 Minimum safe altitudes, prescribes safe altit udes for operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Cashman Professional will only operate its UAS at or below 200AGL. They will be operated on a will defined AOR that has been carefully reviewed fo r hazards and minimizes the presence of any persons not essential for these operations. Flights will only be over private property that the owner has consented and all persons within this video area also give consent for this filming. Compared to flight operations

of conventional and traditional ai rcraft or rotorcraft weighing fa r more than 50 lbs., operating

below 500 AGL with flammable fuel UAS operations pres ent a far smaller risk to the public.

Approval of these 333 Exemptions allowing commercial operations of small UAS in the service of aerial photography & videography will greatly enhance safety by reducing the overall

risk associated with traditiona l aircraft. Traditional aerial pho tography requires large aircraft with flammable fuel to fly in close proximity of populated areas and people in general. With the use of small UAS of 55 lbs. or less, ba ttery operated and fling below 200 feet AGL the risk of injury of people on the ground or the crew has been redu ced or almost erased. The granting of the use of these small UAS by Cashman Professional will give the people another avenue to express

themselves and to have a video record to sh are with family and friends forever. Granting Cashman Professional the above exemption will allo w for the expansion of UAS systems into the future for the safe conduct of free enterprise and the enjoyment of the masses.Cashman Professional respectfully requests th e FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by Cashman Professional pursuant to the Federal Aviation Act, 85 P.l. 726 {1958) as amended {the ACT).

David Chadd

Cashman Professional 3595 S. Highland Dr.

#3 Las Vegas, NV 89103