### John Mullins **620 S. Scoville Ave. Oak**  **Park, IL 60304 708** 
**- 267** 
**- 8456** 

To whom it may

concern at the FAA,
I am writing to request an exemption from 14 CFR § 121.311(b) to the extent required for Molly Mullins to be able to use an FAA Approved Child Restraint Sy stem even though she exceeds the weight limits for the CRS. In addition, if m y petition is granted, I request that an y air carrier or commercial operator operating under part 121 while Molly is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow Molly 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 which we seek relief is Section 121.311 Seats, safet y belts, and shoulder harnesses. My daughter, Molly Mullins is 16 y ear’s old, weighs 82 pounds, and is 58 inches tall. Molly ’s phy sical condition is as follows: Cerebral Palsy with low muscle tone. As a result of her phy sical condition, she needs the support and security provided b y an FAA Approved Child Restraint, but because of her weight is incapable of compliance with the regulation. I am also submitting the following contact information: John Mullins, 620 S. Scoville Ave., Oak Park, IL 60304. Ican be reached via email at john@ejmco.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 Molly

be allowed to occupy

an FAA Approved Child Restraint (CARES, manufactured b y AmSafe, Inc.), even though she exceeds the manufacturer’s weight limits. This ensures a high level of safety for Moll y and a high level of safety for the other passengers and crew on the airplane. In f act, in Molly ’s case, safety is greatly enhanced by

the extra support and securit y that the FAA Approved Restraint System will provide during the entire flight. Enhancing safety

for Molly

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 Sy stem allows Molly 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 commerciall y. I also beli eve that, with certain limitations established 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 CARESrestraint has been certified 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 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 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 o f safet y as that provided by the affected regulation, I propose that the FAA establish a limitation in a grant to this petition that Molly only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a p assenger seated behind Molly while she is using the CARES restraint. Ialso propose that all operations under this exemption be conducted with at least one of Molly's parents or a caregiver accompan yi ng him or her. In addition, I propose that Molly 's parent or caregiver must carr y a cop y 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 April 28

- May 1, 2016. If y ou take the time to put this in the Fe deral 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 require d 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 phy sical challenges, without the support and securit y of this FAA Approved Child Restraint Sy stem, this child wo uld be unable to fl y. We request that this child be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured by AmSafe, Inc.), even though she exceeds the manufacturer’s weight limits of 44 pounds. In this case, the safet y of this child is gr eatl y enhanced by the extra support and securit y that the FAA Approved Restraint S ys tem will provide for her during the flight. Thank y ou for y our consideration of this request.

John Mullins