July 11, 2015
Wi lberto and Doresmi S. Baez 13303 Graham Yarden Dr. Riverview, Florida 33579 U.S. Department of Transportation Federal Aviation Administration 800 Independence Avenue, S W Wa shington, DC 20591 1

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RE: Request a FAA Petition for Exemption FAA Staff, exemption

I am writing to request an exemption from 14 CFR § 121.311(b) to th e extent required for Stephanie A. Townsell 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 my petition is granted, Irequest that any air carrier or commercial operator operating under part 121 while Stephanie A. Townsell is aboard its aircraft is granted an exemptio n from 14 CFR § 121.311(b ) ( 2 ) ( iii ) ( B) to the extent necessary to allow Stephanie A. Townsell 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 is _ 10 ___ year’s old, weighs _ 80 ___ pounds, and is ___49 _ inches tall. My daughter’s ph ys ical condition is as follo ws ( developmental delay , aggressiveness, chromosomal disorder). As a result of her phy sical condition, she needs the support and security provided by 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: Wilberto Baez, 13303 Graham Yarden Dr. Riverview FL 33579, wbncat@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 propos e that Stephanie A. Townsell be allowed to occup y an FAA Approved Child Restraint (CARES, manufactured by Am Safe , Inc.), even though she exceeds the manufacturer’s weight limits. This ensures a high level of safety for Stephanie A. Townsell and a high lev el of safet y for the other passengers and crew on the airplane. In fact, in Stephanie ’s case, safet y is greatly enhanced b y the extra support and security that the FAA Approved Restraint Sy stem will provide during the entire flight.Enhancing safety for St ephanie 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 her to use commercial air transportation. Without the support and security of the FAA Approved Ch ild Restraint Sy stem, she would be unable to fl y commerciall y. I also believe 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 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 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 pe rson using the CARES restraint). In order to achieve an equivalent level of safet y as that provided by the affected regulation, I propose that the FAA establish a limitation in a grant to this petition that Stephanie onl y sits in a passenger seat with no p assenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind Stephanie while she is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of Stephanie ’s par ents or a caregiver accompan yi ng him or her. In addition, Ipropose that Stephanie ’s parent 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 Regi ster. We want to travel ( 16 July 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 follow ing: 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 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 request that this child be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured by Am Safe , Inc.), even though (she/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 support and securit y that the FAA Approved Restraint S ys tem will provide for (her/him) during the flight.

Thank y ou for y our consideration of this request.

Wilberto Baez, wbncat@gmail.com