### 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 e xemption	is	in	the	publi c interest	to facilitate
the	reduction	of	n egative	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	u se	of sUAS	for	surveying	reduce s environmental	impact s	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

. W e	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	envir on ments 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.	Th e	speed	at	which	manned	aircraft	operate and	the	undesirable	vantage	points	they	offer	make	the	sUAS	a	better	choice. The	sUAS	is much	qui e ter	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.	T he	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	aircr aft	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	cl ose	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 by products	are	present	and	p revent	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	th rough	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.