I'd say if you can see the cameo on the obverse strongly without tipping the coin at certain angles , but if you have to tip it to see a strong cameo contrast it isn't . From your pics I'd say yes , with the reverse a lot stronger .
Neither NGC nor PCGS would NOT designate this as a cameo because both sides of the coin do not have the cameo contrast. It looks like this coin was stamped with a newer reverse die and an older obverse die which the frost has worn off. It's unfortunate that both dies weren't changed at the same time, then both sides would have a nice cameo.
As I posted in your other thread about whether this same coin would qualify as a cameo, it'd probably get the CAM designation, but would definitely not get DCAM for the weakness in the obverse face and rim lettering.
Why would they? They don't give stars to 90% of Franklin Cameos or DCams. This has the look of a typical proof Franklin not quite making a cameo.