Enclosed Documents: 

Copy ofF AA/DOT Decision 

Copy of Aircraft Registration 

Addendum to FAR 333 Exemption request: 14 CFR 11.81 (d) and (e) 

Summary for Federal Registry 

'j ( _: ;-_ 

,_;.: 
US. Department 

of Transportation 

Federal Aviation 

Administration 

March 24,2015 

Brian Zamudio 

Persistence Mining, Inc. 

5666 La Jolla Boulevard, Suite 315 

La Jolla, CA 92037 

Dear Mr. Zamudio: 

800 Independence Ave .. S W. 

Washington. D.C. 20591 

This letter is to inform you that we are unable to process your request for an exemption. It 

explains why we cannot process your request and what you should do in the next 30 days. 

Why We Cannot Process Your Request 

We entered your March 4, 2015 exemption request on behalf of Persistence Mining, Inc. into 

the public docket (No. FAA-2015-0566), but we are unable to process your request any 

further. The information you sent does not comply with the requirements of§ 11.81 (copy 

enclosed). For us to consider the request any further, you must send us all of the following: 

• The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole. 

• Any additional information, views, or arguments available to support your request. 

What You Should Do 

If you want us to process your request any further, you must send the information described 

earlier to reach us within 30 days. Please note that § 11.63( d) requires you to send your 

petition for exemption at least 120 days before the proposed effective date of the exemption. 
If We Do Not Hear From You 

If we do not hear from you within 30 days, we will close the docket without notifying you 

further. If you have any questions or require additional time, you may call (202) 267-9521. 

Sinc~erely .· ;J ~·/ . ~ 0~ . .. / / / • 

.• . . • I 

J ak{ Troutman · l

1 

Program Analyst, Ai~ and 

Airspace Rules Division 

Enclosure 

2 
Amendment for Persistence Mining Inc. UAS FAR 333 Exemption Package 

Addendum for Requirement 14 CFR 11.81 

Public Docket No. FAA-2015-0566 

ARMDS 

Rotor Small Unmanned Air Vehicle Geological Mapping 

Aircraft Registration #N5414P 

Prepared by: Brian Zamudio 

Director, Persistence Mining Inc. 

5666 La Jolla Blvd #315 

La Jolla, CA 92037 

Zamudio@Me.com 

Public Docket No. FAA-2015-0566 

Date: April 10, 2015 

Dear Mr. Troutman, 

We have received your letter of Mar 24 2015, Here is the response you requested and thank 

you for your interest in aviation safety. 

Response for Section 11.81 (d) 

Granting Persistence Mining, Inc. a FAR 333 exemption is in the public interest to facilitate 

the reduction of negative environmental impacts on the land potentially caused by the 

mining of industrial minerals. Mineral discoveries are used as the basic inputs into all 

production and manufacturing. Natural resources benefit everyone; unfortunately, the 

mismanagement of these resources can potentially harm everyone. Negative impacts to the 

environment can and have had long lasting ramifications for future generations. The use of 

sUAS for surveying reduces environmental impacts by reducing the carbon footprint of 

manned aircraft. The accuracy provided from sUAS versus manned aircraft allow surveyors 

to accurately determine areas conducive to mining. Manned aircraft survey leaves room for 

error and negative environmental impact. 

The ARMDS was designed to increase accuracy of mineral surveying to reduce the negative 

impact on the land and planet from random drilling and inaccurate mining. We can increase 

mineral discoveries while decreasing the negative impacts to the earth through the use of 

the ARMDS sUAS. Current practices include driving through virgin environments 

potentially causing harm to vegetation, animals and disturbing the land in an effort to 

identify potential mineral discoveries. Once at the site, geologists then start to walk around 

further disturbing habitats that could remain pristine and untouched through the use of the 

ARMDS sUAS. The inaccuracy of manned aircraft can lead to the aforementioned practice of 

going into an area without an accurate survey. The speed at which manned aircraft operate 
and the undesirable vantage points they offer make the sUAS a better choice. The sUAS is 

much quieter reducing the noise impacts that manned aircraft present as well. 

The reduction of costs is another benefit to the public interest. The U.S. competes in a global 

market for natural resources. Cost and the economics of supply are a large part of the 

mineral and mining industry. Various countries allow a large array of practices to get a 

competitive cost advantage over other markets; unfortunately these cost savings come at a 

cost to the environment, human lives and safety. Manned aircraft present a different cost 

structure that is substantially higher than the sUAS making it difficult to compete in the 

global market. The risk to persons on the ground is mitigated by the sUAS because its 

footprint is vastly smaller than manned aircraft. As an example, an automobile may be 

damaged if it is struck by a sUAS but the occupants would likely be protected whereas a 

manned aircraft would destroy an automobile causing harm or death to its occupants. The 

manned aircraft presents a greater hazard to persons or property on the ground by virtue of 

fuel carried on board, altitude operated at and obstructions that are usually located close to 

the ground. 

Section 11.81 (e) 

The increase in accuracy for mineral discoveries and the knowledge of other elements 

present at potential mining sites can help mitigate risks associated with mining materials 

where harmful byproducts are present and prevent possible water supply contamination 

through the knowledge of all elements/minerals present at a given site. The sUAS does not 

adversely affect safety because the areas surveyed are traditionally uninhabited. The 

equivalent level of safety is met through our procedures and training in addition to the 

lesser impact a sUAS would have during an incident or accident versus the impact of a 

manned aircraft. 

In closing, please contact us immediately with any further requests. 

Brian Zamudio 

Persistence Mining, Inc. 
CALIFORNIA ALL-PURPOSE ACKNOWLEDGMENT CIVIL CODE§ 1189 

• 

A notary public or other officer completing this certificate verifies only the identity of the individual who signed the 

document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. 

State of California ) 

County of ,5a D b I C: fj (] ) 

on.Aatil 101 d..ol5 betoreme,An;ta Wood, Miil~ Pub_l,c I Date . Here Insert Name and · e of the Officer 

personally appeared Btl o.. r) 2 q M u. d I () 

who proved to me on the basis of satisfactory evidence to be the person~ whose name~ is/¥ 

subscribed to the within instrument and acknowledged to me that. he/~/ti).ey executed the same in 

his/1J.ef/tl).e1r authorized capacity(i~. and that by his/~/tt]¢r signatur~ on tile instrument the person¥, 

or the entity upon behalf of which the persot)(sr acted, executed the instrument. 

r • • • .• . , . 1~T; ;:,00~ + • • •t 

' Commission # 1954210 

~ Notary Public - California ~ z . ' . San Diego County ::: 

) "'"'""'' My Comm. Expires Oct 24, 2015 ~ ............. , ..... 

Place Notary Sea/ Above 

I certify under PENAL TV OF PERJURY under the laws 

of the State of California that the foregoing paragraph 

is true and correct. 

WITNESS my hand and official seal. 

----------------------------------------------------------oPTIONAL-----------------------------------------------------------

Though this section is optional, completing this information can deter alteration of the document or 

fraudulent reattachment of this form to an unintended document. 

Description of Attached Doc~mentficld.J2.A1~ ...... ~~ l'f CFR. :/,&/. __ 

Title or Type of Document:C/-u(}u/i/?_e1J-. #- N51fl 4 t' Document Date: ~ilfSuld/..5 Number of Pages: -d. - Signer(s) Other Than Named Above: _____ l[L.J______ _ 

Capacity(ies) Claimed by Signer(s) 

Signer's Name: ___________ _ Signer's Name: ____________ _ 

0 Corporate Officer - Title(s): ______ _ 0 Corporate Officer - Title(s): ______ _ 

0 Partner- 0 Limited 0 General 0 Partner - 0 Limited 0 General 

0 Individual 0 Attorney in Fact 0 Individual 0 Attorney in Fact 

0 Trustee 0 Guardian or Conservator 0 Trustee 0 Guardian or Conservator 

0 Other: _____________ _ 0 Other: _____________ _ 

Signer Is Representing: ________ _ Signer Is Representing: ________ _ 

• 

©2014 National Notary Association • www.NationaiNotary.org • 1-800-US NOTARY (1-800-876-6827) Item #5907 
UAS FAR 333 Exemption Package Addendum Federal Registry 

Public Docket No. FAA-2015-0566 

ARM OS 

Rotor Small Unmanned Air Vehicle Geological Mapping 

Aircraft Registration #N5414P 

Prepared by: Brian Zamudio 

Director, Persistence Mining Inc. 

5666 La Jolla Blvd #315 

La Jolla, CA 92037 

Zamudio@Me.com 

Public Docket No. FAA-2015-0566 

Date: April10, 2015 

Dear Sir or Madam: 

Persistence Mining, Inc. seeks exemption from the following rules: 

91.1(b)(2) 

91.9(c) 

91.103(b)(1) 

91.1 03(b)(2) 

91.1 05(a)(2) 

91.109(a) 

91.203(a)(1) 

91.203(a)(2) 

91.207(a)(2) 

91.211 (a) 

91.405(a) 

91.405(b) 

91.407(a)(1) 

91.409(a)(1) 

91.409(b) 

91.417(a) 

Granting Persistence Mining, Inc. a FAR 333 exemption is in the public interest to facilitate 

the reduction of negative environmental impacts on the land potentially caused by the 

mining of industrial minerals. Mineral discoveries are used as the basic inputs into all 

production and manufacturing. Natural resources benefit everyone; unfortunately, the 

mismanagement of these resources can potentially harm everyone. Negative impacts to the 

environment can and have had long lasting ramifications for future generations. The use of 

sUAS for surveying reduces environmental impacts by reducing the carbon footprint of 

manned aircraft. The accuracy provided from sUAS versus manned aircraft allow surveyors 

to accurately determine areas conducive to mining. Manned aircraft survey leaves room for 

error and negative environmental impact. 
The ARMDS was designed to increase accuracy of mineral surveying to reduce the negative 

impact on the land and planet from random drilling and inaccurate mining. We can increase 

mineral discoveries while decreasing the negative impacts to the earth through the use of 

the ARMDS sUAS. Current practices include driving through virgin environments 

potentially causing harm to vegetation, animals and disturbing the land in an effort to 

identify potential mineral discoveries. Once at the site, geologists then start to walk around 

further disturbing habitats that could remain pristine and untouched through the use of the 

ARMDS sUAS. 

Through an exemption we can operate to generate a large benefit to the public good while 

creating sustainability through conservation. 

Brian Zamudio 6--\~ Persistence Mining, INC. 
STRATION NOT TRANSFERABLE 

UNITED STATES OF AMERICA l This certificate 

NSPORTATION- FEDERAL AVIATION ADMINISTRATION must be In the air- 

CATE OF AIRCRAFT REGISTRATION craft when operated. 

l AIRCRAFT SERIAL NO. 

5414P 012015 

UFACTURER'S DESIGNATION OF AIRCRAFT 

G INC ARMDS 

51557225 

This certificate is 

issued for 

NG INC registration purposes 

LVD# 31 5 only and is not a 

37·7523 certificate of Iitle _ 

The Federal Aviation 

Administration does 

not determine rights of ownership as 

between private 

persons. 

Corporation 0 

scribed aircraft has been entered on the register of the Federal 

 States of America, in accordance with the Convention on 

d December 7, 1944, and with Title 49, United Slates Code, 

U.S. Department 

der. 

 2015 

~~-&~_) 

of Transportation 

1,2018 Federal Aviation AOMINISTRATOR Administration 

iOUs editions 

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P.O. 

CtviiAviahon 

Box 25504~ Re~ ..,w;;;.,...~-gu,.&; 

Oklahoma City, OK 73125-0504 

Official Business 

Penalty for Private Use $300 

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02 1M $ 00.48° 

0004234213 fVIAR05 2015 

MAILED FROM ZIP CODE 7 31 6 9 

AC Form 8050-3 {10/2010) Supersedes previous edition 5414P 

TO: PERSISTENCE MINING INC 

5666 LA JOLLA BLVD# 315 

LAJOLLA CA 92037·7523