Submitted via Regulations.gov 105 Baltic Street, Apt 501 Comment on FAA-2007-0001-0001 Brooklyn, NY 11201

February 27, 2006

Re. Request to Use CARES Child Restraint System for Disabled Teenager

To whom it may concern:

I am writing to request an exemption from 14 CFR § 121. 311(b) to the extent required for my son, Samuel J. Hinton (“Sam”) to be able to use an FAA A pproved Child Restraint System even though he exceeds the weight limits for the CRS. In addition, if my petit ion is granted, I request that any air carrier or commercial operator operating under part 121 while Sa muel Hinton is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the ex tent necessary to allow Samuel Hinton to exceed the specified weight limit for an FAA-approved child re straint 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 14 year’s old, weighs 65 pounds, and is 60 inches tall. My son’s has cerebral palsy and is quadriplegic. As a result of his physical conditi on, 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: P aul Hinton parent of Samuel Hinton, 105 Baltic Street, Apt. 501, Brooklyn, NY 11201 and PaulJamesHinton@gmail.com.

I understand that the regulation is written to create a hi gh level of safety for each individual passenger by ensuring that they are securely rest rained 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 Samuel Hinton 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 Sam and a high level of safety for the other passengers and crew on the airplane. In fact, in Sam’s case, safety is greatly enhanc ed by the extra support and security that the FAA Approved Restraint System will provide during the entire flight.

Enhancing safety for Sam is in the public interest. In addi tion, the public interest is also served by the fact that the use of this FAA Approved Child Restraint Syst em 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 establishe d 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 beencertified by the manufacturer 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 fo rward more quickly in an accident scenario and this might cause a higher HIC load for the person seated in the seat be hind the passenger using the CARES restraint (because the seatback moving forward more qui ckly would mean that it would not be there to attenuate the energy from the impact of the person seated behind the per son 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 petit ion that Samuel Hinton only sits in a passenger seat with no passenger seated behind him. Therefore, no unsafe condition would ex ist for a passenger seated behind Sam while he is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of Sam’s parents or a caregiver accompanying him or her. In addition, I propose that Sam’s pa rent or caregiver must carry a copy of this exemption.

I also request that the processing of this petiti on not be delayed for publication and comment in the Federal Register. We want to travel in March 26, 2016 and again at the end of the year. If you take the time to put this in the Federal Regi ster, it will delay the pr ocess and we may not be able to travel in this
timeframe.

If it is necessary to put a summary in th e 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 ex ceeds 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 requ est 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.

Paul Hinton