To Whom It May Concern: 

I am writing to request an exemption from 14 CFR § 121.311(b) to the extent required for 

Brookelyn Corbin to be able to use an FAA Approved Child Restraint System even though she 

exceeds the weight limits for the CRS. In addition, if my petition is granted, I request that any 

air carrier or commercial operator operating under part 121 while Brookelyn is aboard its 

aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to 

allow Brookelyn to exceed the specified weight limit for an FAA-approved child restraint system 

during use of that child restraint system aboard an aircraft.

I believe the pertinent section from 14 CFR part 121 from which we seek relief is Section 

121.311 Seats, safety belts, and shoulder harnesses.

The wish child is 5 year’s old, weighs 55 pounds, and is 3 feet 6 inches tall. Her physical 

condition is as follows: Seizures and Autonomic Storms. As a result of her physical condition, 

she needs the support and security provided by an FAA Approved Child Restraint, but because 

of her weight is incapable of compliance with the regulation. I am also submitting the 

following contact information: 

Jamie and Dan Corbin

171 S. Monroe Ave. 

Bradley, IL 60915

jamewow@att.net

I understand that the regulation is written to create a high level of safety for each individual 

passenger by ensuring that they are securely restrained in their seats during all phases of 

flight. The regulation also ensures that an individual does not cause harm to other passengers 

on the airplane by being thrown into them during turbulent or emergency conditions.

I propose that Brookelyn be allowed to occupy an FAA Approved Child Restraint (CARES, 

manufactured by AmSafe, Inc.), even though she exceeds the manufacturer’s weight limits. This 

ensures a high level of safety for Brookelyn and a high level of safety for the other passengers 

and crew on the airplane. In fact, in Brookelyn’s case, safety is greatly enhanced by the extra 

support and security that the FAA Approved Restraint System will provide during the entire 

flight.

Enhancing safety for Brookelyn is in the public interest. In addition, the public interest is also 

served by the fact that the use of this FAA Approved Child Restraint System allows her to use 

commercial air transportation. Without the support and security of the FAA Approved Child 

Restraint System, she would be unable to fly commercially.

I also believe that, with certain limitations established by the FAA in a grant to this petition, 

there can be an equivalent level of safety to that provided by the affected regulation. The 

CARES restraint has been certified by the manufacturer for use by children 22- 44 pounds. 

However, the components of the CARES restraint are the same as those used in restraints for 
adults on aircraft and would maintain their integrity if used by someone who weighed several 

hundred pounds.

I believe that the limit of 44 pounds was established because, with the additional weight of the 

child attached to the seatback, the seatback would move forward more quickly in an accident 

scenario and this might cause a higher HIC load for the person seated in the seat behind the 

passenger using the CARES restraint (because the seatback moving forward more quickly 

would mean that it would not be there to attenuate the energy from the impact of the person 

seated behind the person using the CARES restraint).

In order to achieve an equivalent level of safety as that provided by the affected regulation, I 

propose that the FAA establish a limitation in a grant to this petition that Brookelyn only sits 

in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would 

exist for a passenger seated behind Brookelyn while she is using the CARES restraint. I also 

propose that all operations under this exemption be conducted with at least one of Brookelyn’s 

parents or a caregiver accompanying him or her. In addition, I propose that Brookelyn’s parent 

or caregiver must carry a copy of this exemption.

I also request that the processing of this petition not be delayed for publication and comment in 

the Federal Register. We want to travel October 14-October 20, 2014. If you take the time to put 

this in the Federal Register, it will delay the process and we may not be able to travel in this

timeframe.

If it is necessary to put a summary in the Federal Register, I submit the following:

This is a request for an exemption from FAR 121.311 (b) to the extent required for a child to use 

an FAA Approved Child Restraint System on an aircraft, even though the child exceeds the 

weight limits for the CRS. Due to physical challenges, without the support and security of this 

FAA Approved Child Restraint System, this child would be unable to fly. We request that this 

child be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured by 

AmSafe, Inc.), even though she exceeds the manufacturer’s weight limits of 44 pounds. In this 

case, the safety of this child is greatly enhanced by the extra support and security that the FAA 

Approved Restraint System will provide for her during the flight.

Thank you for your consideration of this request.

Sonja Arnesen

Wish Coordinator

312-602-9421 (direct)

312-943-9813 (fax)

Arnesen@illinois.wish.org