To whom it may concern:

I am writing to request an exempti on from 14 CFR § 121.311(b) to the extent required for Andrea Capaldo to be able to use an FAA Approved Child Restraint System even though she exceeds the height limits for the CRS. In addition, if my petition is granted, I request that any air carrier or commercial operator operating under part 121 while Andrea Capaldo is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow Andrea Capaldo to exceed the specified height limit for an FAA

- approved child restraint sy stem 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 daughter is 7 year’s old, weighs 42 pounds, and is 44 inches tall. My daughter ’ s physical condition is as follows : infantile spasms (seizure disorder), very high tone, and unable to sit up on her own. As a result of her physical condition , she needs the support and security p rovided by an FAA Approved Child Restraint, but because of

her h eight is incapable of compliance with the regulation. I am also submitting the following contact information: Brenda Hummel, 217 NE Circle Dr., Grimes, IA 50111, and b17hummel@yahoo.com

I understand that the regulation is written to create a high level of safety for each individual passenger by ensuring that they are securely restrained in their seats during all phases of f

light. 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 Andrea Capaldo be allowed to oc c upy an FAA Approved Child Restraint (CA RES, manufactured by AmSafe, Inc.), even though she exceeds the
manufacturer’s height limits. This ensures a high level of safety for Andrea and a high level of safety for the other passengers and crew on the airplane. In fact, in

Andrea ’s case, safet y is greatly enhanced by the extra support and security that the FAA Approved Restraint System will provide during the entire flight.Enhancing safety for Andrea is in the public interest. In addition, the public

interest is also served by the fact that th e use of this FAA Approved Child Restraint System allows her to use commercial air transportation. Without the support and security of the FAA Approved Child Restraint System, she would be unable to fly commercially.

I also believe that, with ce rtain limitations established 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 been certified by the manufacturer for use by

children 22

- 44 pounds and under 40 inches . Howe ver, 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 s of 44 pounds and 40 inches was established becau se, 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

restrai nt (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 of safety as that provided by the affected regulation, I propose that the FAA establish a limitation in a grant to this petition

that Andrea only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind Andrea

while sh e is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of Andrea parents or a caregiver accompanying him or her. In addition, I propose that Andrea ’ s parent or caregiver must carry a copy of this exemption.

I also request that the processing of this petition not be delayed for publication and comment in the Federal Register. We want to travel December 1

- 15 , 2014

. If you take the time to put this in the Fed eral 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 Approved Child Restraint System on an aircraft, even though the child exceeds the weight limits for the CRS. Due to physical challenges, without the support and security of this FAA Approved Child Restraint System, this child

wou ld be unable to fly. 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 height limits of 40 inches . In this case, the safety of

this child i s greatly enhanced by the extra support and security that the FAA Approved Restraint System will provide for her during the flight. Thank you for your consideration of this request.

Sincerely,

Brenda Hummel, Wish Mom

CC:

Joseph Roth
Wish Coordinator

, Make

- A

- Wish ® Iowa jroth@iowa.wish.org