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

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.