To : F ederal Aviation A dministration

From Tro y Stockstad 726 North Tamarisk Street Chandler, AZ 85224 Telephone (480) 406

- 7239 Email : tstockstad@q.com Re : Petition for exemption for FAR 121.311

I am writing to r equest an exemption from FAR 121.311 (b) to the extent re quired for m y daughter Sonja Stockstad to be able to use an FAA Approved Child Restraint Sy stem even though she exceeds the weight limits for the CRS. Ibelieve the pertinent section from which we s eek relief is:
§ 121.311 Seats, safety belts, and shoulder harnesses.
* * * * * (b) Except as provided in this paragraph, each person on board an airplane operated under this part shall occupy an approved seat or berth with a separat e safety belt properl y secured about him or her during movement on the surface, takeoff, and landing. A safet y belt provided for the occupant of a seat may not be used b y more than one person who has reached his or her second birthday . Notwithstanding the preceding requirements, a child may : (1) Be held b y an adult who is occup yi ng an approved seat or berth, provided the child has not reached his or her second birthday and the child does not occupy or use any restraining device; or (2) Notwithstanding an y o ther requirement of this chapter, occup y an approved child restraint s ys tem furnished by the certificate holder or one of the persons described in paragraph (b)(2)(i) of this section, provided: (i) The child is accompanied by a parent, guardian, or attendant designated by the child's parent or guardian to attend to the safet y of the child during the flight; (ii) Except as provided in paragraph (b)(2)(ii)(D) of this section, the approved child restraint s ys tem bears one or more labels as follows: (A) Seats m anufactured to U.S. standards between January 1, 1981, and February

25, 1985, must bear the label: “This child restraint s ys tem conforms to all applicable Federal motor vehicle safety

standards.”(B) Seats manufactured to U.S. standards on or after February 26, 1985, must bear two

labels: ( 1 ) “This child restraint sy stem conforms to all applicable Federal motor vehicle safet y standards”; and ( 2 ) “THI S RESTRAINT I S CERTIFIED FOR USE I N MOTOR VEHICL ES AND AIRCRAFT” in red lettering; (C) Seats that do not qualify under paragraphs (B)(2)(ii)(A) and (b)(2)(ii)(B) of this section must bear a label or markings showing: ( 1 ) That the seat was approved b y a foreign government; ( 2 ) That the seat was manufactured under the standards of the United Nations; or ( 3 ) That the seat or child restraint device furnished by the certificate holder was approved b y the FAA through T yp e Certificate or Supplemental Ty pe Certificate. ( 4 ) That the seat or child restraint device furnished by the certificate holder, or one of the persons described in paragraph (b) (2) (i) of this section, was approved by the FAA in accordance with §21.305(d) or Technical Standard Order C

– 100b, or a later version. (D) Except as provided in §121.311(b)(2)(ii)(C)( 3 ) and §121.311(b)(2)(ii)(C)( 4 ) , booster

- ty

pe child restraint sy stems (as defined in Federal Motor Vehicle Safet y Standard No. 213 (49 CFR 571.213)), vest

- and harness

- ty pe child restraint s ys tems, and lap held child restraints are not approved for use in aircraft; and (iii) The certifi cate holder complies with the following requirements: (A) The restraint s ys tem must be properl y secured to an approved forward

- facing seat or berth; (B) The child must be properly secured in the restraint sy stem and must not exceed the specified weight lim it for the restraint s ys tem; and (C) The restraint sy stem must bear the appropriate label(s). * * * * *
My daughter Sonja’s physical condition is categorized as quadriplegia spastic cerebral pals y. Sonja is not mobile, requires a wheelcha ir, and cannot sit in a standard chair without support. To sit in a chair such as an airplane seat, Sonja requires a a harness or similar supports to sit without assistance. She is currently 10 y ears old, 58 lbs., at a height of 4ft. 10 in. As a result o f her physical condition, she needs the supportand securit y provided b y an FAA Approved Child Restraint, but because of her weight is

incapable of compliance with the regulation. I understand that the regulation is written to create a high level of saf et y for each individual passenger b y 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 b y being thrown into them during turbulent or emergency

conditions.
I propose that Sonja Stockstad be allowed to occupy an FAA Approved Child Restraint (CAReS, manufactured b y AmSafe Corporation), even though she slightly exceeds the manufacturer’s weight limits. This ensures a high l evel of safety for Sonja, and a high level of safet y for the other passengers and crew on the airplane. In fact, in Sonja’s case, safet y is greatly enhanced b y the extra support and securit y that the FAA Approved Restraint S ys tem will provide for her dur ing the entire flight. Enhancing safety

for Sonja 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 securit y of the FAA Approved Child Restraint Sy stem, she would be unable to fl y commercially. Standard car seats are not large enough at her current size. The CAReS restraint would be an ideal solution for Sonja to use commercial airlines to travel.
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 manufactur er 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 HI C 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 orde r 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 Sonja only

sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a pass enger seated behind Sonja while she is using the CAReS restraint.
I also request that the processing of this petition not be delay ed for publication and comment in the Federal Register. We would like to travel from October 10 toOctober 14 , 2011 . If y ou 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:
T his 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 Sy stem on an aircraft, even though the child exceeds the weight limits for the CRS. Due to physical challenges, without the su pport and securit y of this FAA Approved Child Restraint Sy stem, this child would be unable to fly . We request that this child be allowed to occupy an FAA Approved Child Restraint (CAReS, manufactured b y AMSAFE IN C.), even though she slightly exceeds the manufacturer’s weight limits of 44 pounds. In this case, the safet y of this child is greatl y enhanced b y the extra support and security that the FAA Approved Restraint Sy stem will provide for Sonja during the flight.