To whom it may concern:

I am writing to request an exemption from 14 CFR § 121.311(b) to the extent required for Zachary Swett to be able to use an FAA Approved Child Restraint Sy stem even though ( **he or she**  ) exceeds the weight limits for the CRS. In addition, if my petition is granted, Irequest that any air carrier or commercial operator operating under part 121 while Zachary Swett is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(i ii)(B) to the extent necessary to allow Zachary

Swett to exceed the specified weight limit for an FAA

- approved child restraint sy stem during use of that child restraint s ys tem aboard an aircraft. I believe the pertinent section from 14 CFR part 121 from wh ich we seek relief is Section 121.311 Seats, safet y belts, and shoulder harnesses. My son is 8 y ear’s old, weighs 55 pounds, and is 48 inches tall. My sons **’s** p hy sical condition is as follows limited due to Lissencephal y. As a result of his phy sical conditi on, he needs the support and securit y 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: Jill Russi, 6550 Landis Ave, Carmichael,**  **CA 95608, swissninerfan@gmail.com.**  I understand that the regulation is written to create a high level of safet y for each individual passenger b y ensuring that they are securel 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 turbulent or emergency conditions. I propose that Zachary

Swett be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured b y AmS afe, Inc.), even though he exceeds the manufacturer’s weight limits. This ensures a high level of safety for Zachary

Swett and a high level of safet y for the other passengers and crew on the airplane. In fact, in Zachary Swett’s case, safety

is greatly enh anced by the extra support and securit y that the FAA Approved Restraint System will provide during the entire flight. Enhancing safety

for Zachary

Swett 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 him to use commercial air transportation. Without the support and security of the FAA Approved Child Restraint Sy stem, he would be unable to fl y commerciall y.

I also believe that, with certain limitations est ablished 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 certified by the manufacturer for use by children 22

- 44 pounds. However, the components o f 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 addition al 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 thepassenger using the CARES restraint (because the seatb ack 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 safet y as that provided by the affec ted regulation, I propose that the FAA establish a limitation in a grant to this petition that Zachary Swett only

sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind Zachary Swett while he is using the CARES restraint. Ialso propose that all operations under this exemption be conducted with at least one of Zachary ’s parents or a caregiver accompany ing him or her. In addition, Ipropose that Jill Russi 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 May 8 th and 10 th . I f 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 App roved 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 reques t 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 safet y of this child is greatl y enhanced by the extra supp ort and securit y that the FAA Approved Restraint S ys tem will provide for him during the flight. Thank y ou for y our consideration of this request.

Jill Russi, Zachary ’s mom