### Enclosed Documents: Copy ofF AA/DOT Decision Copy ofAircraft Registration Addendum to FAR 333 Exemption request: 14 CFR 11.81 (d) and (e) Summaryfor Federal Registry 'j (_:;-_

,_;.:US.Department ofTransportation Federal Aviation Administration 

### March 24,2015

Brian Zamudio Persistence Mining, Inc. 5666 LaJollaBoulevard, Suite 315 LaJolla, CA 92037 DearMr. Zamudio: 800 Independence Ave
.. SW. Washington. D.C. 20591



### This letter is to inform you that we are unable to process yourrequest for an exemption. It explains whywe cannotprocess your request and whatyou should do inthe next 30 days. Why We CannotProcess YourRequest We entered your March 4, 2015 exemptionrequest onbehalfofPersistence Mining, Inc. into the public docket (No. FAA-2015-0566), butwe are unable to process yourrequest any further. The information you sent does not comply with the requirements of§ 11.81 (copy enclosed). Forus to consider the request any further, you must send us all ofthe following: • The reasons why granting the request would be inthepublic interest; that is, howitwould benefit thepublic as a whole. • Any additional information, views, or arguments available to support your request. What You Should Do Ifyou want us to process your request any further, you must send the information described earlier to reachus 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 ofthe exemption.

### If

### We Do Not HearFrom You Ifwe do nothear from youwithin 30 days, we will close the docket withoutnotifying you further. Ifyouhave any questions orrequire additional time, youmay call (202) 267-9521.



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### 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 AirVehicle 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 receivedyourletter ofMar 24 2015, Here is the response you requested and thank you for your interestin aviation safety. Responsefor Section 11.81 (d) Granting Persistence Mining, Inc. a FAR 333 exemption is in the public interestto facilitate the reduction ofnegative environmental impacts on the land potentially causedbythe mining ofindustrial minerals. Mineral discoveries are used as the basic inputs into all production and manufacturing. Natural resources benefit everyone; unfortunately, the mismanagement ofthese resources can potentiallyharm everyone. Negative impacts to the environment can and have hadlong lasting ramifications for future generations. The use of sUAS for surveying reduces environmental impacts byreducing 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 surveyleaves room for error and negative environmental impact. The ARMDS was designed to increase accuracy ofmineral surveying to reduce the negative impact on theland and planetfrom random drilling and inaccurate mining. We can increase mineral discoveries while decreasingthe negative impacts to the earththrough the use of the ARMDS sUAS. Currentpractices include driving through virgin environments potentially causingharm to vegetation, animals and disturbing the land in an effortto identify potential mineral discoveries. Once atthe site, geologists then startto walk around further disturbinghabitats that could remain pristine and untouched through the use ofthe ARMDS sUAS. The inaccuracy ofmanned aircraft can lead to the aforementioned practice of going into an areawithout an accurate survey. The speed atwhich manned aircraft operateand the undesirable vantage points they offer make the sUAS a better choice. The sUAS is much quieter reducingthe noise impacts that manned aircraft present as well. The reduction ofcosts is anotherbenefit to the public interest. The U.S. competes in a global marketfor natural resources. Cost and the economics ofsupply are a large part ofthe mineral and mining industry. Various countries allow a large array ofpracticesto get a competitive cost advantage over other markets; unfortunatelythese cost savings come at a cost to the environment, humanlives and safety. Manned aircraft present a different cost structurethatis substantiallyhigher than the sUAS making it difficult to compete in the global market. The riskto persons on the ground is mitigated bythe sUAS because its footprint is vastly smaller than manned aircraft. As an example, an automobile maybe damaged ifit is struckbya sUAS butthe occupants would likelybe protected whereas a manned aircraftwould destroy an automobile causingharm or death to its occupants. The manned aircraft presents a greaterhazardto persons orpropertyon the ground byvirtue of fuel carried on board, altitude operated at and obstructions that are usuallylocated close to the ground.
Section 11.81 (e) The increase in accuracyfor mineral discoveries and the knowledge ofother elements present atpotential mining sites can help mitigate risks associated with mining materials where harmful byproducts are present and preventpossible water supply contamination throughthe knowledge ofall elements/minerals present at a given site. The sUAS does not adversely affect safetybecause the areas surveyed are traditionallyuninhabited. The equivalentlevel ofsafetyis metthrough ourprocedures andtraining in addition to the lesserimpact a sUAS would have during an incident or accidentversus the impact ofa manned aircraft.
In closing, please contact us immediatelywith anyfurther requests.

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

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### UAS FAR 333 Exemption Package Addendum Federal Registry Public Docket No. FAA-2015-0566 ARMOS 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 orMadam: 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 interestto facilitate the reduction ofnegative environmental impacts on the land potentially causedbythe mining ofindustrial minerals. Mineral discoveries are used as the basic inputs into all production and manufacturing. Natural resources benefit everyone; unfortunately, the mismanagement ofthese resources can potentiallyharm everyone. Negative impacts to the environment can andhave had long lasting ramifications for future generations. The use of sUAS for surveying reduces environmental impactsbyreducing the carbon footprint of manned aircraft. The accuracyprovided from sUAS versus manned aircraft allow surveyors to accurately determine areas conducive to mining. Manned aircraft surveyleaves room for error and negative environmental impact.The ARMDS was designed to increase accuracy ofmineral surveyingto reduce the negative impact on theland and planetfrom random drilling and inaccurate mining. We can increase mineral discoveries while decreasingthe negative impacts to the earththrough the use of theARMDS sUAS. Current practices include driving through virgin environments potentially causingharm to vegetation, animals and disturbing the land in an effortto identifypotential mineral discoveries. Once atthe site, geologists then startto walk around further disturbinghabitats thatcould remain pristine and untouched through the use ofthe ARMDS sUAS. Through an exemption we can operate to generate a large benefit to the public good while creating sustainabilitythrough conservation.

Brian Zamudio



# 6--\~ Persistence Mining, INC.REGISTRATION NOT TRANSFERABLE UNITED STATES OF AMERICA

l This certificate DEPARTMENT OF TRANSPORTATION- FEDERAL AVIATION ADMINISTRATION must be In the air- CERTIFJCATE OF AIRCRAFT REGISTRATION

craft when operated. NATIONALITY AND

l AIRCRAFT SERIAL NO. REGISTRATION MARKS N 5414P 012015 MANUFACTURER AND MANUFACTURER'S DESIGNATION OF AIRCRAFT PERSISTENCE MINING INC ARMDS ICAO Aircraft Address Code: 51557225

This certificate
is issued for r PERSISTENCE MINING INC
registration purposes s 5666 LA JOllA BLVD# 31 5

only and is not a s LA JOLLA CA 92037·7523

certificate of Iitle _ u

The Federal Aviation E

Administration does 0

not determine rights of ownership as T

between private 0

persons. Corporation

0 It is certified that the above described aircraft has been entered on the register of the Federal Aviation Administration, Unlted States of America,
in accordance with the Convention on International Civil Aviation dated December
7, 1944, and with Title 49, United Slates Code, U.S. Department and regulations issued thereunder. DATE OF ISSUE March 3, 2015 **~~-&~_)**

of Transportation Federal Aviation EXPIRATION DATE March 31,2018 AOMINISTRATOR Administration - AC Fotm 8050·3 (1012Q10) SlJpe<Sodes previOUs editions

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$ 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