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

Jedidiah J. M. Braithwaite and Faith A. A. Braithwaite to be able to use an FAA Approved Child Restraint System even though they exceed the weight limits for the CRS. In addition, if m y petition is granted, I request that any air carrier or commercial operator operating under part 121 while Jedidiah and Faith are aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii) (B) to the extent necessary to allow Jedidiah and Faith to exceed the specified weight limit for an FAA
- approved child restraint s ys tem during use of that child restraint s ys tem 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 children 's physical condition s are as follows : They are both health y but each weighs very close to 40 pounds

. They travel on long International flights (i.e. Okinawa to the United States , 19
-21 hours through varying weather systems

. As a result , I believe they need the support and security provided by an FAA Approved Child Restraint, but because of their weight may be incapable of compliance with the regulation. 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 regulati on 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 the children be allowed to occupy an FAA Approved Child Restraint (CARES, ma nufactured by AmSafe, Inc.), even though they exceed the manufacturer’s weight limits. This ensures a high level of safety for Jedidiah and Faith and a high level of safety for the other passengers and crew on the airplane. In fact, in their cases , 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 Jedidiah and Faith 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 them to use commercial air transportation. W ithout the support and security of the FAA Approved Child Restraint System, they would be unable to fly commercially as safely during o ur long flights

. 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 manufa cturer for use by children 22
- 44 pounds. However, the com ponents 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 th at 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 accidentscenario and this might cause a higher HIC load for the person seated in the se at behind the

passenger using the CARES restraint (because the seatback moving forward more quickly would me an 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 Jedidiah and Faith only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind Jedidiah or Faith while they are using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of Jedidiah and Faith’s parents or a careg iver accompanying him or her. In addition, I propose that Jedidiah and Faith’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. Wewant to travel on or about 01 July 2012 . If it takes too long to to put this i n the Federal Register, it could delay the process and we may not be able to travel in this tim efram e. 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 two children to use FAA Approved Child Restraint System s on an aircraft, even though th e child ren exceed the weight limits for the CRS. W e request that these child ren be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured by AmSafe, Inc.), even though they exceed the ma nufacturer’s weight limits of 44 pounds. In this case, the safety of these child ren is greatly enhanced by the extra support and security that the FAA Approved Restraint System will provide for them during the flight.