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- 11, L. , Nolan Miller's Request to Extend Exemption of 10642 from 14 CFR, part

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.1i ·, .J RE: Doc# FAA-2012-1022; Exemption 10642 Please see up dated request as follows: I am writing to request an extension ofexemption from 14 CFR 

### § 121.311(b) to the extent required for Nolan Miller to be able to use an FAA Approved Child Restraint System even though he exceeds the weight limits for the CRS. In addition, ifmy petition is granted, I request that any air carrier or commercial operator operating under part 121 while Nolan Miller is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allowNolan Millerto exceed the specified weight limit for an FAA-approved child restraint system during use ofthat child restraint system aboard an aircraft. I believe the pertinent section from 14 CFRpart 121 from which we seek reliefis Section 121.311 Seats, safety belts, and shoulder harnesses. My 

### son is 35year's old, weighs approximately 70 pounds, and is 56 inches tall. My son's physical condition is cerebral palsy. As a result ofhis physical condition, he needs the support and security provided by an FAA Approved Child Restraint, but because ofhis weight is incapable ofcompliance with.the regulation.

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- ' I understand that the regulation is written to create a high levei.ofsafety for each individual passenger by ensuring that**th~y** are .sec:urely restrained in their seats during all phases offlight: !he-regulation.also**~nsures** thatan individual**;d9.~~·**nQt; cause harm;to otherpassengers onthe airplane by being thrown into them during turbulent oremergency conditions.

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-**~** . . . I propose thatNolan Miller be allowed to occupy an FAAApproved Child Restraint (CARES, manufactured by

### AmS~fe, Inc.): even though he exceeds the manufacturer's weight limits. This ensures a high level ofsafety for Nolan Miller and a high level ofsafety for the otherpassengers and crew onthe airplane. In fact, inNolanMiller's case, safety is greatly enhanced bythe extra support and security that the FAA Approved Restraint System will provide during the entire flight. Enhancing safety for_Nolan Miller is inthe public interest. In addition, the public-interest is also served by the fact that the use.ofthis.FAA Approved Child Restraint System allows himto use commercial air,transportation. Without the support and security ofthe FAA Approved Child Restraint System, he would be unable to fly commercially

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### 1-aJso believethat;

### with certainlimitations·established.by·the FAA:in a grant tothis petition,-- there can be an equivalent level cfsafety• to that provided by-the·affected·iegulatibn. The CARES restraint has been certified**by~.the** manufacturer for use by children 2:?:. 44•poUiids. However, the components ofthe CARES restraint are the same as those used in restraints for adults on aircraft and wouldmaintain their integrity ifused by someone who weighed several hundred pounds.I believe that the limit of44 pounds was established because, with the additional weight ofthe 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 inthe seat behind the passengerusing 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 ofthe person seated behind the person using the CARES restraint). In order to achieve an equivalent level ofsafety as that provided by the affected regulation, I propose that the FAA establish a limitation in a grant to this petitionthat Nolan Miller only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind Nolan Miller while he is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one ofNolan's parents or a caregiver accompanying him orher. In addition, I propose that Nolan's parent or caregiver must carry a copy ofthis exemption. I also request that the processing ofthis petition notbe delayed for publication and comment in the Federal Register. We want to travel in late October. Ifyou take the time to put this in the Federal Register, it will delay the process and we may not be able to travel inthis timeframe. Ifit 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 ChildRestraint System on an aircraft, even though the child exceeds the weightlimits for the CRS. Due to physical challenges, without the support and security ofthis 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.), eventhough he exceeds the manufacturer's weight limits of44 pounds. 1n this case, the safety ofthis child is greatly enhanced by the extra support and security that the FAA. Approved Restraint System will provide for him during the flight. · ·

Bestregards: /

# r!M/dt--- Guardian and parent ofNolan Miller 

# J 3J -?oJ-3-tctfDate: 6/19/2014 Exemption No: 10642 from 14 CFR (FAR Section)- Part: 121.311 (b) will expire on 10/31/2014. If appropriate, please submit your request to extend this exemption (including the docket number FAA-2012-1022) within 30 days ofthe date ofthis notice. Otherwise, the FAA may not be able to process your request for extension before the expiration date. You may either submit your request electronically through the internet using the Docket Management System web site at: http:I/Regulations.gov/ or mail your request to: U.S. Department ofTransportation Docket Operations, M-30 West Building ground floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590 Submission to other locations may delay processing. Any request for extension must meetthe requirements of 14 CFR part 11. Ifyou have already requested an extension for this exemption or no longer need this exemption, please ignore this notice. 0 l6H26522091 

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Ot> 20,201-\ US POSTAGE William Miller 1576 Horseshoe Drive Manasquan,NJ 08736