12 Dec 14 11:09a First Steps Wollness Cent 13065223793 p.2 

12/1.2/2014 10:42 FAX 0000Y/OOOs 

~~ ildr~n's Wisf~ 

'F 11c 6:6ai[2&rnn'a Wis4 ~s 

C ouaeeirtk'sean of a,.anttd<'n 

December 11, 2074 

RE: Request to Use C.ARrS for 1:arger/(71der Persons: 

1 ani writing to request an exemption from 14 CFR § 121.31 1(b) to the extent required for ,lared 

Scott'1'hornuon t'o be able to use an PAA Approved Child Restraint System even though he 

exceeds the weiglat limits for the C:RS. In addition, if rny pelition is graitt'ed, I reqtlest that any 

air carrier or commercial operator operaling tutder part 121 while Jared is aboard its aircraft is 

granted an exentption 1'ront 14 CFR § 121.311(b)(2)(iii)(B) to the extent nccessary to allow 

Jared to excecd the specifaed weight limit for an FAA-approvcd child restraint system during 

use of that child restraint system aboard an aircraft. 

I believe the pertinent section from 14 CFR part 121 1'rom which we seek relief is Section 

121.311. Seats, safety belts, and sltoulder harnesses. 

My son is 18 year's old, weighs 152 potrnds, and is 71 incihes tall. Please note that althougli 

Jared is over the age of niajority, ltis illness prevents him from signing his own nalne. My son's 

physical condition is as follows; he has a C4 ASIA A(completc) spinal cord injury resulting in 

complete paralysis of his upper and lower extretnities. As a result of his physical cortdition, he 

needs the support and security provided by an FAA Approved Child Restraint, but because of' 

his weiglht is incapable of cotnpliance with the regulation. ! am also sabmit6ng the following 

eontact information: Mr•. & Mrs. Mark & Cayle Tlrornton, PO Box 2484 Kindersley, SK, 

SOL 1S0 and thorntons@sasktcl.net. 

I understand that t'he regulation is written t'o create a high level of saPety for each individual 

passenger by ensuring tltat they are securely restrained in their seats during alt phases of flight. 

The regulation also ensures that an individual does not cause harm to otlter passengers on the 

airplane by being thrown into theln during turbuleut or emergency conditions. 

I propose that Jared Scott 'I'hornton be allowed to occupy an FAA Approved Child Restraint 

(CAR$S, nianufactured by AmSafe, Ine.), even though he excecds the matiufacturer's weight 

lintits. This ensures a high level of'safety for Jared and a high level of safety for the other 

passengers and crew on the airplane• In fact, in Jared's case, safety is greatly enhanced by the 

extra support and security that the PAA Approved Restraint System will provide during ttie 

entire flight. 

Rnharncing safety for Jared is in the public interest. In addition, the public interest is also served 

by the fact that ttie use of this FAA flpproved Child Restraint System allows him to use ~ 

SASKATCNEWAN CHAPTER - PO Box 309, Saskatoon, SK S7K 3t3 

T:30&955-fl511 F:306-653-9474 1-800-267-9474 sk@chlldrenswish.ca 

BuslnessNumber(BN)• 12403867Bftft0001 . .vwvr.lihildrvn.tFd@slt.cd 
12 Doc 14 11:09a First Steps Wollnoss Cent 13065223793 p.3 

12/12/2014 10:43 rAX RI0003/0003 

commercial air transportation. Withotit the support and secw -ity ofthe FAA Approved Clhild 

Restraint Systcm, he would be unablc to fly contmereially. 

I also believe that, with certaiat luttitat'ions cstablished by the PAA in a grant to this petition, 

thcre can be an eqnivalent level ofsafety to that provided by the aftected regulation.'I'hc 

CARL^:S restraint has been certified by the manufacturcr for use by children 22- 44 potmds. 

I-lowever, the componelts of the CAI21.S restraint arc the same as those used in restraints for 

adults on aircraft and would tnaintain tlteir integrity if used by someone who weighed several 

Itundred pounds. 

I believe that the litttit of44 pounds was established because, wit'h the additional weight of the 

child attaclted to the seatback, the seatback would tnove forward nlore quickly in an accident 

scenario and this might cause a higher H1.0 load for thc person seated in the seat behiud the 

passenger using the CARES restraint (bccause the seatback moving tbrwat -d more quickty 

would ntean that it would not be there to atleuuate tlte energy fiom t3te impaet of tlte person 

seated behind the person using the CARI;S resn -aint). 

In order to acliieve an equivalent level of safety as that provided by the affected regulation, 1 

propose that the FAA establish a limitation in a grant to this petition that .lared only sits in a 

passenger seat with no passcnger seated behind hirn. Thereforc, no unsafe coatdition would exi st 

for a passenger seated behind Jared wlrile lie is usinig the CARGS resh•aint. 1 also propose that 

all operations under this exernption be conducted with at least one of Jared's parents or a 

caregiver aceoinpanying hint. In addition, I propose that Jared's parent or caregiver must cany a 

eopy of tltis exemplion. 

I also request that ille processing of t11is petition not be delayed for publication and contment in 

thc Federal Register. We want to travel Januar•y 28, 2015. Ifyou take the time to put tllis in the 

1=ederal Register, it will delay the process and we may not be able to travel in this tirneframc. 

]f it is necessary to put a summary in the Federal Register, I submit thc following: 

1'his is a request for an exemption fronl hAl2 121.31 I(b) to the extent required for a cliild to 

use an PAA Approved Child Restraint Systeni on an aircraft, even thouglt the child exceeds the 

weigltt limits for the CRS. Due to pltysical challettges, without the support and security of this 

1'AA Approved Child Restraint Systetn, this child would be unable to ily. Wc request that this 

child be allowed to occupy an FAA Approved Child Restraiut (CARES, manufactured by 

AmSafe, Cttc.), even though he exceeds the manufacturcr's weight linlits 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. 

Sintcerely, 

Mark & Gayle Thorntott 

Jared's Parents 

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