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INTERIM ATIOIMAL 

A I R RESPONS E . G \ 03^ 

12 May 2011 

International Air Response 

3644 South Hangar Drive 

PO Box 67 

Coolidge, AZ 85128-0067 

Email: bill.grantham@internationalairresponse.com 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

RoomW12-140 

Washington. DC 20590 

SUBJECT: Addendum 1 to petition for exemption from 14 CFR§ 91.313(a)(1), 14 CFR 

§ 91.313(c), and 14 CFR § 91.313(d). 

Dear Sir or Madam, 

The purpose of this addendum id to further explain why the petition for exemption 

from 14 CFR §91.313(a)(1), 14 CFR § 91.313(c), and 14 CFR § 91.313(d) submitted by 

International Air Response, Inc. (lAR) on May 9 , 2011 is in the public interest and 

therefore will benefittbe pubti&as a whola^ For convenience, thi& has beenbreken 

down into three categories. 

1. Public interest as it relates to the creation of U.S. jobs: As mentioned before, 

the request dated May 9*^, 2011 was made for the purpose of allowing lAR, a U.Sbased specialized aerial services company, to provide parachute services to Warner 

Brothers Entertainment. The provision of this service by lAR will result in significant 

domestic (U.S.) job creation as both companies intend to employ a substantial number 

of U.S. citizens for this purpose. 

The following statement from one of the officials involved with production of this project 

further demonstrates this point, "...the public would benefit from the (waiver being 

approved). ..i.e. inherent public benefit in the entertainment value of the film, U.S. job 

benefit from the production of the film - In which this scene is a crucial component." 

International Air Response, Inc. 3644 South Hangar Drive Coolidge, AZ 85128 P (520) 723-6555 F (520) 723-6550 

www.intemationalairTesponse.com 
2. Public interest as it relates to Increased U.S. federal and state tax revenues: 

The creation of a significant number of U.S. jobs for the purpose of producing this 

sequence will result in increased corporate and income tax receipts by the U.S. 

Treasury and various state governments. These increases In tax revenues will result in 

reductions in the sizes of current federal and state deficits which will subsequently 

reduce the substantial downward pressure on U.S. and state credit ratings. 

Tax revenue basis growth and job creation meet the legal definition of public Interest. 

As confirmed by the 2005 U.S. Supreme Court decision in Kelo v. City of New London, 

an economic project that creates new jobs and increases tax revenue meets the "public 

use" test because it is in the public interest. 

3. Public Interest as it relates to enhanced safety: Conducting parachute 

operations from an lAR C-130 aircraft will provide Warner Brothers Entertainment the 

benefit of conducting jump operations from an aircraft purpose built for this task. The 

aircraft will be operated by a flight crew fully qualified and highly experienced in 

parachute operations. The parachute operation procedures employed by lAR were 

developed by the U.S. Air Force and are currently approved and in use by multiple 

Department of Defense (DoD) entities. lAR C-130s and flight crews routinely provide 

parachute services to the DoD. 

All lAR C-I30s are subject to FAA surveillance under lAR's Part 137 operating 

certificate. lAR C-130s, flight crews, and parachute operations are also routinely 

scrutinized by DoD inspection team personnel. 

lAR's multiple layers of oversight and use of approved parachute procedures results in 

a very high standard of safety. If the use of an lAR C-130 is not approved for this 

project, the alternative will be an Antonov turboprop operated by a Moldavian company. 

This will expose those participating in this project to greater level of risk than they would 

be subject to if an lAR C-130 is used. This is due primarily to the unknown level of 

aircraft^lght crew oversight and the potential impact of a language barrier between a 

non-native English speaking flight crew and the U.S. parachutists and film crews. 

I hope helps to further explain and clarify the benefit to the public associated with the 

issuance of an exemption from the sections of 14 CFR § 91.313 listed above. 

Thank you for your consideration regarding this matter. 

Sincerely, 

/y 

William N Grantham 

Director of Business Development 

International Air Response 

International Air Response, Inc. 3644 South Hangar Drive Coolidge, AZ 85126 P (520) 723-6555 F (520) 723-6550 

www. intemationalaiiTesponse.com