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

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

marja Hubbard to exceed the specified weight limit for an FAA

- approved child restraint s ys tem during use of that child restr aint 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 harnesses. My daughter is 13 year’s old, weighs 93 pounds, and is 4 ft 7 inches tall. My daughter’s phy sical condition is as follows : neurological disorder, r efractory epileps y , c annot sit up unaided. As a result of her phy sical condition, she needs the support and securit y 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 conta ct information: Teresa Hubbard, Guardian, (617) 817

- 6835 , 16 Fidelis Way , Apartment 432 (3rd Floor) , Brighton , MA, 02135

. I understand that the regulation is written to create a high level of safety for each individual passenger b y ensuring that they are s ecurel y 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 b y being thrown into them during tur bulent or emergency

conditions. I propose that Key

marj a Hubbard 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 Keymarja Hubbard and a high level of safety for the othe r passengers and crew on the airplane. In fact, in Key marja ’s case, safet y is greatly enhanced b y the extra support and security that the FAA Approved Restraint Sy stem will pr ovide during the entire flight. Enhancing safety

for Key marja is in the public interest. In addition, the public interest is also served b y the fact that the use of this FAA Approved Child Restraint Sy stem allows her to use commercial air transportation. Without the support and security of the FAA Approved Child Restraint Sy stem, she w ould 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 certi fied 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 integrit 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 perso n 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 per son using the CARES restr aint). In order to achieve an equivalent level 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 Keym arja onl y sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind Key marja while she is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of her parents or a caregiver accompan yi ng him or he r. In addition, I propose that Teresa Hubbard parent or caregiver must carry

a copy 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 June 1

- 7, 2016. If you take the time to put this in the Federal Register, it will delay the process and we may

not be ab le to travel in this timeframe. If it is necessary

to put a summary

in the Federal Re gister, I submit the following: This is a request f

or an exemption from FAR 121.311 (b) to the extent required for a child 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 unable to fl y. 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 safet y of this child is greatl y enhanced by the extra support and security that the FAA Approved Restraint S ys tem will provide f or her during the flight. Thank you for your consideration of this request.