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

Carson Gallardo to be able to use an FAA Approved Child Restraint Sy stem even though he exceeds the weight limits for the CRS. In addition, if this petition is granted, Irequest that an y air carrier or commercial operator operating under part 121 while Carson is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow Carson to exceed the speci fied weight limit for an FAA

- approved child restraint sy stem during use of that child restraint sy stem aboard an aircraft. I believe the pertinent section from 14 CFR part 121 from which we seek relief is Section 121.311 Seats, safet y belts, and shoulder h arnesses. Carson is 13 y ears old, weighs 112 pounds, and is 63 inches tall. His p hy sical condition is as follows: Carson suffers from Arteriovenous Malformation and Hy drocephalus which leave him unable to sit up unassisted. As a result of his ph ys ical cond ition, he needs the support and securit y provided b y an FAA Approved Child Restraint, but because of his weight is incapable of compliance with the regulation. Carson will be traveling for his wish through the Make

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- Wish Foundation and his parents have ac knowledged that he will require an FAA Approved Child Restraint. I am also submitting the followi ng contact information: Leslie Woodfill, Make

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- Wish Alaska & Washington 104 S Frey a St, Green Flag Bldg. S ui te 210, Spokane WA 99202 leslie@akwa.wish.org Christina Gallardo , Carson’s Mother 213 L inden Way , Sunny side WA 98944 christina_gallardo@hotmail.com I understand that the regulation is written to create a high level of safet y for each individual passenger b y ensuring that they are securel y restraine d 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 b y being thrown into them during turbulent or emergency conditions. I propose that Carson be allowed to occ upy an FAA Approved Child Restraint (CARES, manufactured b y AmSafe, Inc.), even though he exceeds the manufacturer’s weight limits. This ensures a high level of safety for Carson and a high level of safety for the other passengers and crew on the airplane. In fact, in Carson’s case, safety is greatl y enhanced by the extra support and securit y that the FAA Approved Restraint System will provide during the entire flight. Enhancing safety

for Carson is in the public interest. In addition, the public interest i s also served by the fact that the use of this FAA Approved Child Restraint Sy stem allows him to use commercial air transportation. Without the support and securit y of the FAA Approved Child Restraint Sy stem, he would be unable to fl y commerciall y. I also believe that, with certain limitations established by the FAA in a grant to this petition, there can be an equivalent level of safet y to that provided by the affected regulation. The CARES restraint has been certified by the manufacturer for use by childre n 22

- 44 pounds. However, thecomponents of the CARES restraint are the same as those used in restraints for adults on aircraf t and would maintain their integ rit y if used b y 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 us ing 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 lev el of safet y as that provided by the affected regulation, I propose that the FAA establish a limitation in a grant to this petition that Carson only sits in a passenger seat wi th no passenger seated behind him . Therefore, no unsafe condition would exist fo r a passenger seated behind Carson while he is using the CARES restraint. Ialso propose that all operations under this exemption be conducted with at least one of Carson’s parents or a caregiver accompan yi ng him. In addition, I propose that Carson’s parent or caregiver must carry a cop y of this exemption.
I also request that the processing of this petition not be delay ed for publication and comment in the Federal Register. We want to travel July 12, 2015. If y ou take the time to put this in the Federal Reg ister, 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 c hild to use an FAA Approved Child Restraint Sy stem on an aircraft, even though the child exceeds the weight limits for the CRS. Due to phy sical challenges, without the support and securit y of this FAA Approved Child Restraint Sy stem, this child would be un able to fl y. We request that this child be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured by AmSafe, Inc.), even though he exceeds the manufacturer’s weight limits of 44 pounds. In this case, the safet y of this child is greatl y enhanced by the extra support and securit y that the FAA Approved Restraint S ys tem will provide for him during the flight. Thank y ou for y our consideration of this request.