1 December 2016

Re: Request for Information FAA-2015-8149 dtd 21SEP2016

To whom it may concern: This letter is submitted on behalfof NaturChem, Inc., in response tothe Federal Aviation Administration's ("FAA"} September 21, 2016 request for additional information from NaturChem in support ofthe above-reference petition for exemption ("Petition"). Set forth below are NaturChem's requested reliefs and responses. NaturChem, Inc. is hereby requesting relieffrom the Federal Aviation Regulations detailed below in conjunction with Special Airworthiness Certificate ofthe Stark Hx8 equipped with spraying apparatus. Such relief has previously been granted to Yamaha MotorCorporation under a Section 333 approval granted bythe U.S. DOT /FAA Decision on May 1, 2015 (See FAA2014-0397-0014}.
Relief Requested
14 CFR 61.113: NaturChem, Inc. is requesting an exemption from the limitation in 61.113(a) that prohibitsthe holderofa private pilot certificate from acting as a PIC for compensation or hire. Alternatively, NaturChem, Inc. is requesting an exemption from 61.113(b) thatwould allowthe holderofa private pilot certificate to act as PIC for compensation or hire even iftheflight is not incidental to the business or employment ofthe PIC. Either ofthese requests, ifgranted, would allow a person holding a private pilot certificate to act as PIC ofa Stark Hx8 operation for compensation or hire. Additionally, Naturchem, Inc. requests that astate issued driver's license be used in lieu ofa FAA Medical Certificate forthe Visual Observer.
In granting reliefto Part 61.113 the FAA granted reliefto 61.113(a) and found that relieffrom 61.113(b) was not necessary. Underthe grant ofexemption, the FAA stated "a PIC must hold either an airline transport, commercial, private, recreational, orsport pilot certificate. The PIC must also hold acurrent FAA airman medical certificate oravalid U.S. driver's license issued by astate, the District of Columbia, Puerto Rico, aterritory, a possession, orthe Federal government. The PIC must also meettheflight review requirements specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate." Naturchem, Inc. is requesting the same relieffor operations conducted underthe proposed SAC.

14 CFR 91.151(b):Naturchem, Inc. is requesting an exemption from the limitations set forth in 91.151(b) Fuel Requirements forflight in VFR conditions. Prior UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) conditions. The conditions and limitations below prohibit the PIC from beginning a UAS flight unless (considering wind and forecast weather conditions) there is enough available fuel for UAS to operateforthe intended operational time and to operate afterthatfor at least five minutes or with the reserve fuel recommended by the manufacturer ifgreater. The FAA found thatthis provides sufficient reason to grantthe relieffrom 14 CFR 91.151. Naturchem, Inc. is requesting the same relieffor operations conducted underthe proposed SAC.
14 CFR 91.121 (a): Yamaha is requesting an exemption from the limitations set forth in 91.121(a) Altimeter Settings. The primary altitude reporting forthe Stark Hx8 is GPS altitude. In previous petitions, the FAA has found that "When the UA is not equipped with a barometric altimeter, an alternate means for measuring and reporting UA altitude is necessary, such as GPS. As stated in the conditions and limitations below, the FAA requires altitude be reported in feet AGL. The petitioner may choose to set the altitude indicatorto zero feet AGL ratherthan local barometric pressure orfield altitude before flight." As such relieffrom 14 CFR 91.121 was granted to Yamaha forthe RMAX, Naturchem, Inc. is requesting the same relieffor operations conducted underthe SAC.
Point of Contact: Mr. Adam Gunter NaturChem, Inc. 270 Bruner Road Lexington, SC 29072 Telephone: (803) 600-4633
Public Interest The enhanced safety achieved using a UA with the specifications described in Yamaha's exemption request, subsequently reviewed by the FAA, and the factthatthe unmanned aircraft does not carry passengers or crew, ratherthan a manned aircraft ofsignificantly greater proportions, carrying crew in addition to flammable fuel, is in the public interest.
Please do not hesitateto contact me should you have further questions orfurther information is required. 

# )~----- 

# l.m Gunter

NaturChem, Inc.