I am writing to request an exemption from 14 CFR § 121.311(b) to the extent required for FRÉDÉRICK COMEAU to be able to use an FAA Approved Child Restraint System even though he 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 FRÉDÉRICK COMEAU is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow FRÉDÉRICK COMEAU to ex ceed the specified weight limit for an FAAapproved child restraint system during use of t hat 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 belt s, and shoulder harnesses.

My son's physical condition is as follows, he has cerebr al palsy, he cannot use his legs or arms ,he needs to wear a corset to be able to sit strai ght in his wheelchair which has a restraint device similar to Cares and in which he travels in our ad apted mini-van, he is 15 years old , 4 feet and 6 inches tall and is still growing. As a result ofhis physical condition, he needs the support and security provided by an FAA Appr oved Child Restraint, but because of his 70 pounds weight and probably heavier in the future is incapable of compliance with the regulation.

I understand that the regulation is written to cr eate a high level of safety for each individual passenger by ensuring that they ar e 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 FRÉDÉRICK COMEAU be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured by AmSafe Corporation) , even though he exceeds the manufacturer’s weight limits. This ensures a high level of safety for FRÉDÉRICK COMEAU and a high level of safety for the other passengers and crew on the airplane. In fact, in FRÉDÉRICK COMEAU’S case, safety is greatly enhanced by the extra support and security that the FAA Approved Restraint System will provi de during the entire flight.
Enhancing safety for FRÉDÉRICK COMEAU 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 him to use commercial air transportati on. Without the support and security of the FAA Approved Child Restraint System,he would be unable to fly commercially.

I also believe that, with certain limitations establis hed by the FAA in a grant to this petition, there can be an equivalent level of safety to thatprovided by the affected regulation. The CARES restraint has been certified by the manufacturer fo r 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 establish ed because, with the additional weight of the child attached to the seatback, the seatback w ould move forward more quickly in an accidentscenario and this might cause a higher HIC load for the person seated in the seat behind the passenger using the CARES restraint (because t he seatback moving forward more quickly would mean that it would not be there to attenuate t he energy from the impact of the person seated behind the person using the CARES restraint).

In order to achieve an equivalent level of safetyas that provided by the affected regulation, I propose that the FAA establish a limitation in a grant to this petition that FRÉDÉRICK COMEAU only sits in a passenger seat with no pass enger seated behind him. Therefore, no unsafe condition would exist for a passenger seated behind FRÉDÉRICK COMEAU while he is using the CARES restraint. I also propose that all operatio ns under this exemption be conducted with at least one of FRÉDÉRICK COMEAU’S parents or a caregiver accompanying him or her. In addition, I propose that FRÉDÉRICK COMEAU’S par ent or caregiver must carry a copy of this exemption.

I also request that the processing of this petit ion not be delayed for publication and comment in the Federal Register. We want to travel APRIL 27, 2012 TO MAY6 ,2012. If you take the time to put this in the Federal Register, it will delay t he 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 121.31 1 (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 chall enges, without the support and security of this FAA Approved Child Restraint System, this child w ould 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 he 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 him during the flight.



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