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 Modernization and Reform Act of 2012(the reform act) 

and CFR Part 11, Cashman Professional, owner and 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 exception would permit the operation of light weight (less 

than 55 lbs. total takeoff weight) UAS under controlled 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 safe operation of such aircraft 

systems in national airspace systems." Section 333(c), of the Reform Act. 

Cashman Professional’s UAS is a rotorcraft 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 plane simultaneously. Both have an auto return to 

launch point when battery power is under 25%. The UAS will operate within the line of sight with 

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

close at hand as to make voice communication possible. These operations will not create a hazard 

to users of the nation airspace, public nor the environment. 

Cashman Professional respectfully requests the grant of an exception to the 

following specific sections of the Title 14 Code 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 application in accordance with the Reform Act, 112 P.L. 

95 331-334, seeking relief from any currently applicable 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 airspace 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 expressly 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 promulgate rules governing such aircraft. 
The Reform Act directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate 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 airports and populated areas 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 shall 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 these UAS combined with the safe guards presented below, will 

allow for the safe operation greater than that envisioned 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 safety 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 Aviation Act, as amended, the strong equivalent level of 

enhanced safety, reduced emissions utilizing UAS verses traditional aircraft as well as the economic 

impact of greatly reducing the cost of aerial photography thereby benefiting the greater public's 

interest. Accordingly, the applicant requests that the FAA grant the requested exemption without 

delay. 

The following will be considered as the binding limitation on operations of Cashman 

Professional,
1. Flights will only occur in the day time hours, 

2. Flights will be operated in the line of sight of the operator{ PIC) and Observer,(VSO) 

3. Flights will be terminated at any time weather 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 operator(PIC) and an observer and/or camera

operator(VSO), 

7. Operator and crew will remain in contact 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 capabilities of the units to 

further reduce the chance of violating anyone's privacy. 

10. All required FAA clearances, will be obtained 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 the 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: Airworthiness Certificate 14 CFR 91.7(a}, 91.203(a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of 

operations for Cashman Professional UAS flights permits exception 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 from the airworthiness 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 dense 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 aircraft certifications and registrations. These 

are inapplicable for the same reasons stated above. The equivalent level of safety will be 

achieved by maintaining such certifications and registrations at Cashman Professional operations 

center. 

14CFR91. 7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable 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 aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UAS this regulation is inapplicable. 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 altitudes 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 for 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 aircraft or rotorcraft weighing far more than 50 lbs., operating 

below 500 AGL with flammable fuel UAS operations present 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 traditional aircraft. Traditional aerial photography 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, battery operated and fling below 200 feet AGL the risk of injury 

of people on the ground or the crew has been reduced 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 share with family and friends forever. Granting 

Cashman Professional the above exemption will allow 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 the 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