1 December 2016 

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

To whom it may concern: 

This letter is submitted on behalf of NaturChem, Inc., in response to the Federal Aviation 

Administration's ("FAA"} September 21, 2016 request for additional information from 

NaturChem in support of the above-reference petition for exemption ("Petition"). Set forth 

below are NaturChem's requested reliefs and responses. 

NaturChem, Inc. is hereby requesting relief from the Federal Aviation Regulations detailed 

below in conjunction with Special Airworthiness Certificate of the Stark Hx8 equipped with 

spraying apparatus. Such relief has previously been granted to Yamaha Motor Corporation 

under a Section 333 approval granted by the 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 prohibits the 

holder of a private pilot certificate from acting as a PIC for compensation or hire. Alternatively, 

NaturChem, Inc. is requesting an exemption from 61.113(b) that would allow the holder of a 

private pilot certificate to act as PIC for compensation or hire even if the flight is not incidental 

to the business or employment of the PIC. Either of these requests, if granted, would allow a 

person holding a private pilot certificate to act as PIC of a Stark Hx8 operation for compensation 

or hire. Additionally, Naturchem, Inc. requests that a state issued driver's license be used in 

lieu of a FAA Medical Certificate for the Visual Observer. 

In granting relief to Part 61.113 the FAA granted relief to 61.113(a) and found that relief from 

61.113(b) was not necessary. Under the grant of exemption, the FAA stated "a PIC must hold 

either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC 

must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by 

a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight 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 relief for operations conducted under the proposed 

SAC. 

14 CFR 91.151(b): 
Naturchem, Inc. is requesting an exemption from the limitations set forth in 91.151(b) Fuel 

Requirements for flight 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 

operate for the intended operational time and to operate after that for at least five minutes or 

with the reserve fuel recommended by the manufacturer if greater. The FAA found that this 

provides sufficient reason to grant the relief from 14 CFR 91.151. 

Naturchem, Inc. is requesting the same relief for operations conducted under the 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 for the 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 indicator to zero feet AGL rather than local barometric 

pressure or field altitude before flight." As such relief from 14 CFR 91.121 was granted to 

Yamaha for the RMAX, Naturchem, Inc. is requesting the same relief for operations conducted 

under the 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 fact that the unmanned aircraft 

does not carry passengers or crew, rather than a manned aircraft of significantly greater 

proportions, carrying crew in addition to flammable fuel, is in the public interest. 

Please do not hesitate to contact me should you have further questions or further information 

is required. 

)~-----

l.m Gunter 

NaturChem, Inc.