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January 26, 2015

To whom it may concern: 

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

for Darrell Carson Champine 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 Darrell Carson Champine is aboard its aircraft is granted an exemption from 14 

CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow Darrell Carson Champine to 

exceed the specified weight limit for an FAA-approved child restraint system during use 

of that 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 belts, and 

shoulder harnesses.

My son is 4 year’s old, weighs 50 pounds, and is 38 inches tall. My son’s physical 

condition is as follows: low tone cerebral palsy. As a result of his physical condition, he

needs the support and security provided by an FAA Approved Child Restraint, but 

because of his weight is incapable of compliance with the regulation. I am also

submitting the following contact information: Alicia Champine, 4331 125th St NE

Marysville, WA 98271 and achampine0302@gmail.com.

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 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 Darrell Carson Champine be allowed to occupy an FAA Approved Child 

Restraint (CARES, manufactured by AmSafe, Inc.), even though he exceeds the 

manufacturer’s weight limits. This ensures a high level of safety for Darrell Carson 

Champine and a high level of safety for the other passengers and crew on the airplane. 

In fact, in Darrell Carson Champine’s case, 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 Darrell Carson Champine 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 transportation. 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 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 manufacturer for use by 

children 22- 44 pounds. However, the components of the CARES restraint are the same 
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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 HIC 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 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 

Darrell Carson Champine only sits in a passenger seat with no passenger seated 

behind her. Therefore, no unsafe condition would exist for a passenger seated behind 

Darrell Carson Champine while he is using the CARES restraint. I also propose that all 

operations under this exemption be conducted with at least one of Darrell Carson 

Champine parents or a caregiver accompanying him or her. In addition, I propose that 

Darrell Carson Champine 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. We want to travel April 30, 2015. If you 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:

This 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 System on an aircraft, even though the 

child exceeds the weight limits for the CRS. Due to physical challenges, without the 

support and security of this FAA Approved Child Restraint System, this child would 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.

Thank you for your consideration of this request.

Alicia Champine

(mother of Darrell Carson Champine)