(Javier Gorordo) wrote in message om...
I think the letter you refer to dates back to November 1990, in
response to query from AOPA. It may be available from them.

Here is what I found

"The FAA letter is dated 11/5/1990 and is included in an AOPA packet
called
"Traveling with Children

FAA response to an AOPA request for clarification of an FAR wording
change.


[address omitted]

We are responding to your request for clarification of a wording
change in Federal Aviation Regulation (FAR) Section 91.205(b)(12) and
whether that change affects the carriage of two children in one seat
belt.

The July 15, 1986, letter you attached is an interpretation of then
FAR Section 91.14, now FAR Section 91.107. The Federal Aviation
Administration (FAA) policy is that FAA does not require separate
seats or separate safety belts for FAR Part 91 operations. One safety
belt may be fastened around two individuals provided that the strength
of the safety belt is not compromised and that the aircraft's weight
and balance remain within limits. This policy is based on the Preamble
to Amendment 91-89, effective in August 1971, and has not been
superseded by succeeding amendments.

The change in wording of FAR Section 91.205(b)(12) reflects the
current airworthiness requirements for newly manufactured, normal,
utility, or aerobatic category aircraft. The change in wording does
not affect the FAA's along-standing policy concerning bench seats and
safety belts enclosing two individuals, as stated above. However, to
quote from our 1986 letter, ". . .Experience has shown that the use
of one seat belt by one occupant affords less of a chance of injury,
in case of an accident, as opposed to multiple occupants using one
seatbelt..."

[further clarification on another issued omitted]

Sincerely,


Gabriel D. Bruno
Manager, Operations Brance